Flat Tax for New Residents in Italy: Eligibility, Cost and How Article 24-bis Works
Figures current as at 1 January 2026
Article 24-bis of the TUIR lets a new Italian tax resident swap ordinary tax on their foreign income for one fixed annual sum. From 1 January 2026 that sum is EUR 300,000 a year for the person taking the option, plus EUR 50,000 a year for each family member added to it, under L. 199/2025. Two older figures still circulate: EUR 100,000, which applied until 10 August 2024, and EUR 200,000, which applied from 9 August 2024 to 31 December 2025. Neither one applies to anyone transferring residence today, and a page still quoting either is out of date.
By Alessandro Ferri, Tax and Accounting Lead, Rome office. Reviewed by Marta De Luca, Regulatory and Licensing Lead. Updated 11 September 2026.
Definition. The flat tax for new residents, in one sentence: a lump-sum substitute tax, currently EUR 300,000 a year, that a qualifying new Italian tax resident can elect instead of ordinary tax on their foreign-source income.
This page covers one thing: the individual's election under Article 24-bis. It is not about becoming an Italian tax resident in the first place, a separate test explained on /tax-foreigners-italy/, and it does not repeat the mechanics of Company in Italy: corporate tax in italy, which a founder's own company keeps paying no matter what the owner elects personally. What follows sets out who qualifies, what the current figure actually buys, what stays outside it even for a qualifying resident, the two levers built into the regime, the three-step procedure, how long the option runs, two regimes it is often confused with, and the point where a founder's own election and their company's tax position meet.
What Article 24-bis actually is, and what this page does not cover
What Article 24-bis is, in one line
Article 24-bis of the TUIR (Testo unico delle imposte sui redditi, the consolidated income tax act) creates a lump-sum imposta sostitutiva (substitute tax) on foreign-source income for a qualifying new Italian tax resident. One flat sum, declared and paid every year, stands in place of ordinary progressive tax on the income it reaches. The Agenzia delle Entrate administers the option: it publishes the current amount, receives the application, and sets how the tax is paid.
What this page does not develop, and where that lives
Five related questions sit outside this page on purpose, each with its own home:
- Whether a person actually becomes an Italian tax resident in the first place: the Article 2 TUIR test, covered in full on
/tax-foreigners-italy/. - IRES mechanics and the company's own residence test: covered on
/corporate-tax-italy/. - Esterovestizione (reverse company residence) on the merits: its own page,
/corporate-tax-residence-italy/. - General capital-gains mechanics, beyond the single threshold this page needs:
/capital-gains-tax-italy/. - The impatriati relief and the Article 24-ter pensioner regime, beyond one paragraph disambiguating each, further down this page.
Who actually needs this page
The reader here has usually already decided, or is seriously weighing, a personal move to Italy, and wants this regime's current terms stated plainly rather than summarised from memory. A good number are already running a company, in Italy or somewhere else, and want to know exactly where their own election ends and their company's own tax position starts. That connection gets a full section further down, because almost nothing published on this topic states it at all.
Who is eligible: the nine-of-ten-years look-back
The nine-of-ten-years condition, stated exactly
A person transferring tax residence to Italy can elect Article 24-bis only if they were not an Italian tax resident for at least nine of the ten tax periods immediately before the option starts. Nine years out of the ten immediately preceding, not any nine out of a longer stretch. Article 24-bis of the TUIR sets this out in its first paragraph, and every other section on this page assumes it has already been cleared.
This sits on top of, not instead of, the ordinary residence test
Nine of ten years is a precondition, not the residence test itself. A person has to establish Italian tax residence under the ordinary Article 2 TUIR test before this second condition means anything at all. That test, built around the 183-day count, domicile and Anagrafe registration, is covered in full on tax in Italy for foreigners. Readers who have not yet worked through that question should start there rather than here. Everything below this point assumes residence is already settled, and asks only whether this specific regime is also open.
A common path in: the investor visa
Many people who end up eligible for Article 24-bis arrive in Italy through the investment route, an immigration path rather than a tax one. The visa itself decides nothing about eligibility for this regime. Residence, once established, still has to clear the nine-of-ten-years test on its own, entirely separately from however the person got their permit. The two questions run on separate tracks that happen to meet in the same file.
How much the flat tax costs today, and the ladder that got here
The current figure: EUR 300,000, plus EUR 50,000 per family member
Confirmed live against Article 24-bis on 2026-09-11: EUR 300,000 a year for the person electing the regime, plus EUR 50,000 a year for each family member added to the option, in force for anyone transferring residence to Italy from 1 January 2026 under L. 199/2025, Art. 1, comma 26 (the 2026 Budget Law). Those are today's figures. The EUR 100,000 and EUR 200,000 amounts described below are history, not alternatives.
The full historical ladder
The amount has moved twice before reaching its current level. EUR 100,000 a year for the principal taxpayer, plus EUR 25,000 for each family member, applied to anyone transferring residence up to 10 August 2024. EUR 200,000 a year, with the family figure still at EUR 25,000, applied to transfers between 9 August 2024 and 31 December 2025. Only the 1 January 2026 figures reach a transfer of residence happening today.
| Period residence is transferred | Principal taxpayer (per year) | Per family member (per year) | Legal basis |
|---|---|---|---|
| Up to 10 August 2024 | EUR 100,000 | EUR 25,000 | Art. 24-bis(2) TUIR, pre-2024 wording |
| 9 August 2024 to 31 December 2025 | EUR 200,000 | EUR 25,000 | D.L. 113/2024 |
| From 1 January 2026 (current) | EUR 300,000 | EUR 50,000 | L. 199/2025, Art. 1, comma 26 |
The substitute-tax amount doubled in August 2024 and rose again from 1 January 2026; a source quoting EUR 100,000 or EUR 200,000 today is citing a superseded figure.
What triggered the August 2024 doubling
D.L. 113/2024 doubled the amount from EUR 100,000 to EUR 200,000 for anyone transferring residence after 9 August 2024, the single change most searches for "Italy to double flat tax for wealthy new residents" are chasing. Eighteen months later the 2026 Budget Law raised the figure again, this time to EUR 300,000, and lifted the family-member amount from EUR 25,000 to EUR 50,000 in the same move. Two increases inside under two years is not a pattern that argues for treating today's number as fixed for the long run either.
What income the flat tax actually covers
Foreign-source income, defined by cross-reference to Article 165
The substitute tax reaches income identified as produced abroad, using the same sourcing test the ordinary foreign tax credit rule applies under Article 165 TUIR. Article 24-bis borrows that test rather than writing its own, and the borrowing matters more than it sounds: the scope of this regime is fixed by reference to a rule built for a different purpose entirely, the foreign tax credit, not for this one.
What stays outside: your own Italian-source pay and dividends
Income counted as Italian-source under that same test, including a founder's own salary, director's fees or dividends drawn from their own Italian company, is not covered by the option and stays taxed under ordinary IRPEF. Nobody had to write a separate carve-out for this into Article 24-bis. It falls out automatically from the scope already defined: if the income was never foreign-source to begin with, the lump sum was never going to reach it.
Also relieved: the foreign-asset monitoring return and the wealth taxes
An update note attached to Article 24-bis, referencing a 2016 enabling law, states that electing taxpayers are relieved of the quadro RW foreign-asset monitoring return, and exempt from the IVIE and IVAFE wealth taxes, on foreign real estate and foreign financial assets respectively, on the assets the option covers. Treat this as a genuine, useful relief rather than a footnote. For someone holding foreign investments and foreign property, it removes an entire layer of annual reporting that a new resident might otherwise assume still applies in full.
Two levers inside the regime: excluding a country and adding family members
Excluding a specific country from the substitute tax
A person electing Article 24-bis can declare that the substitute tax should not apply to income produced in one or more named foreign countries. Once excluded, that income reverts to ordinary tax treatment, with the ordinary foreign tax credit available against it. This is a genuine planning lever rather than a footnote. It typically gets used where a treaty, or an available foreign tax credit, already makes a specific country's slice of income cheaper to tax normally than to fold into the flat amount.
Extending the option to family members
The option can be extended to one or more family members, a familiare as defined by Article 433 of the Civil Code, at EUR 50,000 a year each for options taken from 1 January 2026, provided each family member independently meets the same nine-of-ten-years condition. The extension is separately revocable: withdrawing it for one family member touches neither the principal election nor any other family member's own extension.
Who counts as a "family member" here
Article 433 of the Civil Code sets out priority categories rather than a single definition: broadly, the spouse, children, parents and certain other close relatives, in a set priority order. That description is deliberately not a verbatim quotation of the statute's own list, since the exact wording was corroborated through a secondary legal reference rather than confirmed directly against Normattiva's own article text. Anyone relying on the precise boundary of who qualifies as a listed family member should have that boundary checked against the statute itself before extending an option to a specific relative.
How to apply: interpello, tax return, F24 payment
Step one: a favourable interpello
The option cannot simply be claimed on a tax return. It has to be preceded by a favourable answer to a specific interpello (ruling request), submitted to the Agenzia delle Entrate's Divisione Contribuenti. Treat the interpello as a precondition, not as paperwork filed alongside the return afterward. A person who files the return first and asks the question later has the sequence backwards, and the option is not validly exercised that way.
Step two: exercising the option in the tax return
Once the ruling comes back favourable, the option is exercised in the tax return for the relevant year. This is a formal step in its own right, not an automatic consequence of the interpello's outcome, and it has to land in the correct year's filing rather than a later one.
Step three: paying via F24, codes NRPP and NRRE
The substitute tax itself is paid in a single instalment, by the income-tax balance-payment date, using the F24 form "Versamenti con elementi identificativi" and tax code NRPP. A refund or an offset against the amount uses code NRRE instead. Full detail on both codes, and on the amounts currently in force, sits on the Agenzia delle Entrate's neo-residents page.
Step 1: become an Italian tax resident under Article 2 TUIR. Step 2: confirm the nine-of-ten-years condition. Step 3: submit a favourable interpello. Step 4: exercise the option in the tax return. Step 5: pay via F24, code NRPP. Optional, at any point: exclude a country, or extend the option to family members.
How long the option lasts: fifteen years, correctly
The fifteen-year maximum
The option is revocable, and in any case ceases to have effect after fifteen years from the first tax period it applied to. Article 24-bis(4) TUIR states it in one clause, "cessa di produrre effetti decorsi quindici anni dal primo periodo d'imposta", checked directly against the article's own text on 2026-09-11. Fifteen years, not ten, and not indefinite.
Revoking the option early
A taxpayer can revoke the option at any point before the fifteen-year ceiling arrives. The statute gives no further procedural detail beyond that revocability, so this page states none beyond what the text itself supports.
What happens on a missed or partial payment
A missed or partial payment of the substitute tax ends the option automatically, and bars the same person from electing it again afterward. That is a harder consequence than an ordinary late-payment penalty elsewhere in the tax system. Elsewhere a late payment typically costs interest and a fine. Here it costs the regime itself, permanently, for that person.
Why this page says fifteen years, not ten
Some published summaries describe this regime as lasting ten years. Article 24-bis(4) TUIR's own text says fifteen, checked directly against Normattiva on 2026-09-11, and the statute controls over any summary that says otherwise. Ten years is not a defensible reading of the operative wording. Fifteen years is the figure to carry forward from this page, and the only one used here.
Two regimes this is not: the 7% pensioner tax and the impatriati relief
The 7% flat tax for foreign pensions (Article 24-ter)
The separate 7% regime for foreign pensions, Article 24-ter TUIR, taxes recipients of foreign pension income at a flat 7% for nine tax periods, but only for people moving to a municipality of 30,000 inhabitants or fewer in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia. Different eligibility group, different rate, different duration, and a narrow geographic condition Article 24-bis does not carry at all.
The impatriati relief (Article 5, D.Lgs. 209/2023)
The impatriati relief exempts 50% of qualifying employment or self-employment income, up to EUR 600,000 a year, for five years, and needs only three years of prior non-residence rather than nine. A percentage exemption on a specific type of income, not a lump sum on foreign income generally, and a mechanism that suits an employed relocator more naturally than a director-shareholder living mostly off investment income. Full treatment of this relief sits on /tax-foreigners-italy/, not here.
Why these get confused with this page's regime
All three share the phrase "flat tax", and all three target people relocating to Italy, which is exactly why a search for "Italy flat tax 7" so often lands on the wrong regime. Checking which one actually applies before quoting a figure matters more here than in most corners of Italian tax, since three different rates, durations and eligibility tests all answer to some version of the same name.
The founder scenario: your personal election and your company's own tax
Your personal election does not change what your company owes
An Italian-incorporated company, or one otherwise tax resident in Italy, keeps paying the standard IRES rate of 24% on its own profits, whether or not its owner has elected Article 24-bis personally. A conditional 20% rate applies to FY2025 profits meeting reinvestment and employment conditions, but that is a separate mechanism entirely, unconnected to the owner's personal tax status. The two positions, personal and corporate, stay legally separate. Full IRES mechanics, rates and filing sit on /corporate-tax-italy/, not here.
What the lump sum covers for you personally, and what it does not
For up to fifteen years, the lump sum shelters the founder's own genuinely foreign-source income and gains: foreign investment income, foreign real estate income, dividends from non-Italian holdings. It does not touch the company's own IRES bill, and it does not touch the founder's own Italian-source pay or dividends drawn from their own Italian company, which stay under ordinary IRPEF exactly as described earlier on this page.
Covered by the lump sum: foreign investment income, foreign real estate income, dividends from non-Italian holdings. Not covered, taxed under ordinary rules: salary or dividends from your own Italian company, gains on a qualifying shareholding in the first five years, your company's own IRES.
Where the two positions can collide
A founder who becomes personally Italian tax resident while still directing a foreign company from Italy can separately trigger that company's own corporate reverse-residence presumption, esterovestizione, under Article 73(5-bis) TUIR, independent of whether they elect Article 24-bis at all. Electing the personal regime neither causes nor prevents that separate corporate risk. The conditions for the presumption, and how to rebut it, sit on the residence test, a page built specifically for that question.
Where our incorporation service fits
A personal move to Italy and a decision to incorporate there tend to land on the same desk, in either order. Where our incorporation service fits into that sequence, and what a founder's own company will owe once it exists, is a conversation for a call rather than a page. No price and no timeline pressure attaches to that conversation, only the facts of the specific structure involved.
Frequently asked questions about the Italian flat tax for new residents
What is the flat tax for new residents in Italy?
A lump-sum substitute tax, currently EUR 300,000 a year, that a qualifying new resident can elect to pay instead of ordinary Italian tax on their foreign-source income, under Article 24-bis of the TUIR (Art. 24-bis(1), (2) TUIR, accessed 2026-09-11).
How much is the Italian flat tax for new residents right now?
EUR 300,000 per tax period for the principal taxpayer, effective for anyone transferring residence from 1 January 2026 onward. EUR 200,000 applied to transfers between 9 August 2024 and 31 December 2025, after D.L. 113/2024 doubled the original EUR 100,000 figure (Art. 24-bis(2) TUIR + Agenzia delle Entrate, accessed 2026-09-11).
Who can qualify for the Italian flat tax for new residents?
Anyone who first becomes an Italian tax resident under the ordinary Article 2 TUIR test and was not an Italian tax resident for at least nine of the ten tax periods immediately before the option starts; the residence test itself is covered separately (Art. 24-bis(1), Art. 2 TUIR, accessed 2026-09-11).
What income does the flat tax actually cover?
Only income identified as foreign-source under the same criteria used for the foreign tax credit, Article 165 TUIR; Italian-source income, including pay or dividends from the person's own Italian company, is not covered and stays under ordinary IRPEF (Art. 24-bis(1) TUIR, accessed 2026-09-11).
If I own an Italian company, does the flat tax cover the company's tax too?
No. The company remains liable to IRES at the standard 24% rate on its own profits regardless of the owner's personal election; the two positions are legally separate (Agenzia delle Entrate, IRES page, accessed 2026-09-06).
Are capital gains on my own company's shares covered by the flat tax?
Not in the first five tax periods of the option, if the shareholding is "qualifying": for an unlisted company that means more than 20% of voting rights or more than 25% of capital, a threshold most founders exceed in their own company (Art. 24-bis(1), Art. 67(1)(c) TUIR, accessed 2026-09-11).
How long does the flat tax regime last?
Up to fifteen years from the first tax period it applies to. It is also revocable at any time, and it ends automatically on a missed or partial payment of the substitute tax (Art. 24-bis(4) TUIR, accessed 2026-09-11).
How do I actually apply for the regime?
By obtaining a favourable answer to a specific interpello, a ruling request, from the Agenzia delle Entrate, then exercising the option in the tax return for the relevant year (Art. 24-bis(3) TUIR, accessed 2026-09-11).
How is the substitute tax paid?
In a single instalment by the income-tax balance-payment date, using form F24 "Versamenti con elementi identificativi" with tax code NRPP; a refund or offset uses code NRRE (Agenzia delle Entrate, accessed 2026-09-06).
Can I exclude a specific foreign country from the flat tax?
Yes. The option can be declared not to apply to income produced in one or more named foreign countries, which then reverts to ordinary tax treatment with the ordinary foreign tax credit available (Art. 24-bis(5) TUIR, accessed 2026-09-11).
Can family members be added to my option, and who counts as a family member?
Yes, at EUR 50,000 per tax period each for options taken from 1 January 2026 (EUR 25,000 applied to earlier transfers), provided each meets the same nine-of-ten-years condition; "family member" is defined by cross-reference to Article 433 of the Civil Code, broadly the spouse, children, parents and certain other close relatives, in a set priority order (Art. 24-bis(2), (6) TUIR, accessed 2026-09-11).
Does the flat tax also reduce inheritance or gift tax?
No. Article 24-bis contains no inheritance or gift tax provision; it governs only the annual substitute tax on foreign-source income. Any separate inheritance-tax treatment of neo-residents is out of scope for this page (Art. 24-bis TUIR, full text checked, accessed 2026-09-11).
Am I exempt from reporting foreign assets if I take this regime?
An update note to Article 24-bis, referencing the 2016 enabling law, states that electing taxpayers are relieved of the foreign-asset monitoring return and of the IVIE and IVAFE wealth taxes on the assets the option covers (Art. 24-bis update note, accessed 2026-09-11).
Is this the same as Italy's 7% flat tax?
No. The 7% rate is a separate regime, Article 24-ter TUIR, for foreign pension income of people moving to small municipalities, population 30,000 or below, in specific Southern regions, lasting nine tax periods: a different eligibility group, rate and duration from this page's regime (Art. 24-ter TUIR, accessed 2026-09-11).
Is this the same as the impatriati regime?
No. The impatriati relief exempts 50% of qualifying employment or self-employment income, not a fixed lump sum, lasts five years, and needs only three years of prior non-residence: a different mechanism suited more to an employed relocator than to a director-shareholder (Art. 5 D.Lgs. 209/2023, accessed 2026-09-06).