Italy a special tax regime targeted at new residents holding substantial sources of income abroad. This lump sum tax scheme is similar to non-habitual tax regime offered by Portugal, allows new residents to substitute regular taxation on their entire worldwide income generated outside Italian territory by paying, once a year, a €100,000 flat tax. It is best suited for millionaires and ultra rich families who wish to move to Italy as a non-domiciled resident. Italy also has a golden visa program specifically designed for millionaires.
The regime is available to to anybody who is willing to move their tax residence to Italy, under the condition that he or she has not been resident in the country for at least 9 out of the last 10 years. It is only available upon request with the Italian tax authority. This beneficial regime aims at enhancing investments and attracting to Italy high-net-worth individuals.
Lump Sum Tax
The €100,000 flat tax is to be paid in one instalment by 30 June of each year. Family members may also be covered by the scheme by paying an additional €25,000 for each dependent. Once granted, the regime is valid for 15 years and the taxpayer can opt out at any time. The status automatically lapses in the event of failure to pay the annual lump sum, partly or in full. It will not be reactivated.
Another important benefit this scheme, is inheritance tax – which only covers assets located in Italy – and to transfers of foreign assets from abroad, are untaxed.
The Italian tax law does not provide for a minimum number of days that the individual has to spend in Italy in order to be considered tax resident. An individual is considered “resident” in Italy for tax purposes if, for the greater part of the fiscal year (i.e.: 183 days or more) he is:
– registered with the Registry of the Italian Resident Population or
– has his “domicile” in the territory of the Italian State, or
– has his “residence” in the territory of the Italian State