Lump-Sum Tax Regime (HNWIs) — Italy Special Tax Regime
🇮🇹 LUMP-SUM TAX REGIME (HNWIS)
Italy — Special Tax Regime
Status
Active
Effective From
Jan 1, 2017
📋 DETAILS
Summary
Flat annual tax on foreign-source income for high-net-worth individuals transferring residence to Italy. New arrivals from 2026 are subject to EUR 300,000; earlier opt-ins remain grandfathered under prior rules.
Eligibility
Must not have been tax resident in Italy in at least 9 of 10 prior years.
Benefits
EUR 300,000 flat annual tax covers foreign-source income regardless of amount for new opt-ins. Italian-source income is taxed normally; family-member substitute tax remains separate.
Requirements
Must become Italian tax resident.
Limitations
EUR 300,000 annual substitute tax applies to transfers of residence from 2026. Family members are subject to a separate EUR 50,000 annual substitute tax. 2024 and 2025 opt-ins retain the EUR 100,000/EUR 200,000 treatment under their existing rules.
Income Types Covered
All foreign-source income
Duration Details
Up to 15 years
💰 FINANCIAL
Lump Sum
EUR 300,000
Minimum Tax
EUR 300,000
Duration
15 years
Prior Non-Residency Required
9 years
🏛 COUNTRY TAX CONTEXT
Tax System
Worldwide
Top PIT Rate
43.0%
Corporate Tax
24.0%
IVA
22.0%
Capital Gains
26.0%
Treaty Count
100
📋 OTHER REGIMES IN ITALY
| Name | Type | Rate |
|---|---|---|
| Impatriate Regime | Percentage exemption | -- |
📚 SOURCE
PwC Worldwide Tax Summaries
View source →