On December 30, 2025, Italy officially approved an increase to its special flat tax regime for new tax residents.
With the approval of the 2026 Budget Law, the annual lump-sum tax applicable to qualifying individuals has been raised from €200,000 to €300,000, while the flat tax for qualifying family members has increased from €25,000 to €50,000 per person.
This reform marks the second significant increase in just two years and confirms Italy’s clear and deliberate policy choice: positioning itself as a long-term hub for ultra-high-net-worth individuals (UHNWIs).
Grandfathering Confirmed
As in the previous reform, Italy has fully respected the grandfathering principle.
The new €300,000 flat tax applies only to individuals who transfer their tax residence to Italy after the entry into force of the new law.
Those who moved to Italy before that date and validly opted for the flat tax regime will continue to apply the lump sum in force at the time of their relocation, with no retroactive effects.
This approach mirrors the 2024 reform, when the flat tax was increased from €100,000 to €200,000. In both cases, Italy has demonstrated a strong commitment to legal certainty, predictability, and investor confidence, which are key elements for internationally mobile individuals making long-term relocation decisions.
A Clear Strategic Direction: Italy as a UHNWI Destination
With the increase to €300,000, Italy has confirmed that the flat tax regime is not designed to attract mass migration, but rather a particular profile: individuals and families with substantial international income and assets.
The higher entry cost serves multiple purposes:
- Increasing fiscal contribution per taxpayer,
- Reinforcing the exclusivity of the regime,
- And filtering for genuinely high-income and high-net-worth profiles.
This reform leaves little doubt: Italy has chosen to compete at the top end of the market, positioning itself alongside traditional European UHNWI destinations such as Switzerland and Monaco, within the broader European wealth ecosystem.
Does the Flat Tax Still Make Sense at €300,000?
For the right profiles, the answer is still yes.
The Italian flat tax remains highly attractive for individuals or families earning €1 to €1.5 million per year and above, particularly when income is predominantly foreign-sourced.
In many European jurisdictions, top marginal tax rates reach or exceed 45 to 50%, often combined with:
- Progressive taxation on dividends and capital gains,
- Wealth or net worth taxes,
- Inheritance and gift taxes,
- And extensive reporting obligations on foreign assets.
Under the Italian flat tax regime, qualifying individuals benefit not only from a fixed annual income tax but also from a full exemption from Italian gift and inheritance tax on the gratuitous transfer of foreign assets.
This feature is particularly relevant for UHNW families engaged in intergenerational wealth planning and succession strategies.
For UHNW individuals, the Italian flat tax therefore allows:
- A substantial reduction in the effective tax rate,
- Full certainty on the annual tax burden,
- Exemption from Italian wealth taxes on foreign assets,
- Exemption from reporting obligations on foreign assets,
- And exemption from Italian gift and inheritance tax on foreign assets.
Even at €300,000 per year, the regime remains highly competitive when compared with ordinary taxation in most EU countries.
The Family Flat Tax: From €25,000 to €50,000
The increase in the flat tax for qualifying family members is equally significant.
While this change raises the overall cost for families, it aligns with the regime’s new positioning. The flat tax is now clearly tailored to UHNW households, for whom the aggregate tax burden under ordinary rules, including inheritance and succession planning, would still be materially higher.
For couples and families with consolidated income of €2 to €3 million per year, the Italian flat tax remains a compelling and efficient solution.
Timing Remains Decisive
With grandfathering confirmed, timing remains a critical factor.
Individuals who transferred their tax residence to Italy before the entry into force of the new law will permanently retain access to the €200,000 regime, potentially saving €100,000 per year for up to 15 years.
As a result, the approval of the new law may set in motion a familiar pattern: a concentration of relocations immediately before legislative changes take effect.
Is This the Last Hike?
The progression from €100,000 to €200,000 and now to €300,000 suggests that Italy may be approaching a natural ceiling for the regime.
Further increases could risk undermining competitiveness relative to other European destinations or diluting the regime’s appeal.
At the same time, the consistent application of grandfathering confirms that Italy understands the importance of trust and stability in attracting globally mobile capital.
For many observers, the €300,000 threshold may represent the regime’s final structural adjustment, a last dance that consolidates Italy’s role as a premium European destination for UHNWIs.
Thus, the approval of the €300,000 flat tax does not signal the end of Italy’s special tax regime. Instead, it marks its full maturation.
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