Italy’s Flat Tax Regime, commonly called the lump sum tax regime or regime forfettario per neo-residenti, allows new-resident high-net-worth individuals replace ordinary Italian taxation on foreign-sourced income and related wealth taxes and reporting obligations with a single annual substitute tax of €300,000.
The program is valid for up to 15 years, can be extended to family members for an extra €50,000 per person per year, and removes foreign-asset reporting obligations such as quadro RW while enrolled.
The flat tax applies only to foreign-sourced income; domestic Italian income remains subject to ordinary rules. The program is tax only and does not confer immigration status, so participants must secure lawful residence through the appropriate visa or permit.
Core Eligibility Requirements
A prospective applicant must establish Italian tax residency and not have been tax resident in Italy for nine of the previous ten years. Eligible persons include any nationality, and the rule applies equally to former Italians returning from abroad.
The taxpayer elects the substitute tax in the first Italian tax return after becoming resident or seeks advance confirmation by filing an advance ruling. Once elected, the substitute tax replaces ordinary Italian taxation of foreign-sourced income and the related reporting obligations for the period of the program.
Residency Test
An applicant meets Italian tax residency requirements if, for the majority of the tax year, they satisfy one of the following:
Authorities expect factual substance, including accommodation, family ties, banking, utilities, and economic life in Italy.
Advance Ruling
Advisors often recommend filing an advance ruling (interpello) for complex cases because it confirms eligibility and clarifies treatment of trusts, qualified shareholdings, crypto, and other foreign income. Practitioners report that rulings take a few months and are essential in high-value cases.
Election Timing
One may file a pre-move ruling or elect the program in their first tax return after relocation.
Documentation
Typical evidence required includes:
Key Limits
Domestic Italian income remains taxable under ordinary rules. Capital gains on sales of “qualified” shareholdings realized within the first five years may face special taxation (commonly at 26%) unless a ruling provides otherwise. The program permits exclusion of one or more countries from the substitute tax so that income from those jurisdictions is taxed under ordinary rules and foreign tax credits remain available.
The flat tax is a tax program only. Participation in the regime does not, by itself, prevent or promote access to permanent residence or naturalization. Standard immigration and naturalization requirements still apply, including continuous legal residence, integration, and physical-presence tests.
Non-EU/EEA nationals must secure the appropriate visa or permit to reside and work lawfully in Italy. A common approach for non-EU applicants is the Italy Investor Visa. If relocating to Italy, investors frequently coordinate the Investor Visa with the flat tax election.
Tax residency is established separately by registration in the Anagrafe or by meeting the domicile, habitual residence, or 183-day test. Applicants commonly coordinate the advance ruling and the immigration application to align fiscal and immigration timing.
Explore your immigration options in this destination and beyond on the IMI Program Pages.
The program began under Budget Law 2017 (Law No. 232/2016) and was amended by Law Decree No. 113/2024 and implementing measures, which established the €200,000 annual substitute tax for new applicants after August 2024. The HNWI flat tax operates as an substitute tax covering foreign-sourced income and provides exemptions from IVIE, IVAFE, and quadro RW reporting.
Advisers strongly recommend filing an advance ruling (interpello) with the Agenzia delle Entrate because it provides binding clarity on eligibility and treatment, notably for trusts, crypto, and complex shareholdings. The ruling process typically takes a few months. Electing the program without a ruling remains possible but carries higher audit and adjustment risk.
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