IMMIGRATION AND SPECIAL TAX REGIMES

HIGH NET WORTH INDIVIDUALS

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Italy offers an attractive flat tax regime for high-net-worth individuals who become new tax residents.

Under this scheme, foreign income is taxed at a fixed rate of €200,000 per year, regardless of amount. The regime can be extended to family members for an additional €25,000 each. It is available for up to 15 years and excludes Italian-source income.

PENSIONERS AND SOUTHERN ITALY

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Italy provides a favourable tax regime for foreign pensioners who move to qualifying towns in Southern Italy.

Those who transfer their tax residence can opt to pay a flat tax of 7% on all foreign income, including pensions, for up to 10 years. To qualify, the person must not have been an Italian resident in the last five years.


STANDARD VISA REQUIREMENTS

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There are several visa options for moving to Italy. Common routes include the Elective Residence Visa for those with passive income, the Investor Visa for those investing significant capital in Italy, and the Work Visa for individuals with a job offer.

For freelancers, the Self-Employment Visa is available, although it involves stricter quotas and regional authorisations.

PW JENNINGS LLP

THE DIFFERENT TYPES OF VISA

FISCAL RESIDENCE RULES
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When moving to Italy, establishing your tax residency status is crucial. Under Italian tax law (Art. 2 of the TUIR – Testo Unico delle Imposte sui Redditi), you will be considered an Italian tax resident if you spend more than 183 days in Italy in a calendar year, maintain your habitual abode here, or have your “centre of vital interests” in Italy. Italy’s extensive network of Double Taxation Treaties (DTTs), largely based on the OECD Model, governs how income is taxed to prevent double taxation.
 
You must register with the Italian tax authorities and carefully manage income reporting, including worldwide income, as Italy taxes residents on their global income. Special regimes, such as the flat tax on new residents, may be available but require compliance with strict criteria and formal applications.
 

RESIDENCE PERMIT
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Italy distinguishes between fiscal residence (for tax purposes) and anagrafic residence (official registration in the local population registry). To become an anagrafic resident, you must register your address at the local town hall (Comune) by applying at the Ufficio Anagrafe. EU/EEA/Swiss citizens must provide a valid ID, proof of accommodation, sufficient financial means, and proof of health coverage—either by registering with the national health service (SSN) if eligible or by obtaining private health insurance. Non-EU citizens must first obtain a long-stay visa (type D), then apply for a residence permit (permesso di soggiorno) within 8 days of arrival, and use the receipt to register with the Comune.

They must also provide evidence of health insurance, either private or by enrolling in the SSN for an annual fee. In both cases, local police may visit to confirm you live at the declared address. Once confirmed, you receive a residency certificate, which is essential for accessing healthcare, registering for services, and may support your status as a tax resident.


WEALTH PLANNING
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When relocating assets to Italy, it is essential to consider how property ownership, corporate holdings, and other investments will be treated under Italian law. Real estate transfers in Italy are subject to registration, cadastral, and mortgage taxes, and inheritance taxes apply on worldwide assets for residents. Italy recognises trusts through Law No. 364/1989, but their treatment differs from common law jurisdictions, so foreign trusts may face complex recognition issues.
 
Strategic use of Italian companies, foundations, or trusts can protect assets and optimize tax exposure, but must comply with strict transparency requirements under CRS and anti-money laundering legislation. Professional advice is vital to align asset structures with both Italian and international legal frameworks to ensure protection, tax efficiency, and regulatory compliance.

SUCCESSION LAW CONFLICTS
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Italian inheritance law provides for mandatory forced heirship shares, ensuring close relatives receive a defined portion of the estate under Articles 536 to 564 of the Codice Civile. Foreign nationals moving to Italy should be aware that under Regulation (EU) No 650/2012 (the Succession Regulation), their succession law will, by default, be that of their last habitual residence unless they elect to apply their nationality’s law. This choice can have profound consequences on testamentary freedom and the distribution of assets.
 
It is essential to review and possibly update your will according to Italian formal requirements and consider the recognition of foreign wills and succession instruments. Careful estate planning helps to avoid unintended disinheritance and costly legal disputes.

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Legal Briefing

PW JENNINGS LLP
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HOW TO FIND US

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Via dei Banchi Nuovi 56, Int 1
Rome, Italy, 00186

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+39 334 7436570
+44 7936287501

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HOW TO FIND US

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Via dei Banchi Nuovi 56, Int 1
Roma 00186


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