Lump-Sum Tax Regime (HNWIs) — Italy Special Tax Regime

Lump sum EUR 300,000 minimum tax EUR 300,000

Duration 15 years

Prior non-residency 9 years required before applying

Standard top income tax 43.0% Italy, without the regime

Overview

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

Other regimes in Italy
Name	Type	Rate
Impatriate Regime	Percentage exemption	—

View source PwC Worldwide Tax Summaries