The Italian government’s latest draft of the 2026 Budget Law confirms a major revision of the country’s flat tax regime for new residents. The proposal raises the annual substitute tax from €200,000 to €300,000 and increases the amount for each family member from €25,000 to €50,000.
At the same time, the government has decided to drop the earlier idea of linking access to the regime to an investment in Italy, a requirement that had been under discussion for weeks.
As of today, the text is still in draft form and subject to parliamentary approval, but it gives a clear indication of the direction policymakers intend to take.
No investment requirement
Earlier versions of the proposal suggested that beneficiaries might have to invest in Italian businesses, startups, or government bonds. That idea has been abandoned.
The likely reason is practical: creating a regulated investment framework similar to the Investor Visa program would have required detailed rules, eligible instruments, and administrative oversight. Instead, the government seems to prefer a simpler, faster approach, raising the tax instead of adding bureaucracy.
Grandfathering protection for current participants
The draft law fully respects the rights of existing participants.
Those already under the flat tax will continue to pay under the old rules, without any retroactive increase:
- Individuals who entered before August 2024 will keep the previous version at €100,000 for the main taxpayer and €25,000 for each dependent.
- Those who joined after that reform but before the new law enters into force will remain under the €200,000 + €25,000 structure.
- Only new applicants after the new law takes effect will fall under the €300,000 + €50,000 program.
This confirms Italy’s long-standing approach: no retroactive taxation and full respect for taxpayers’ legitimate expectations.
What the government hopes to achieve
The motivation is primarily fiscal. Italy faces budget constraints and is looking to increase revenue without dismantling its internationally successful relocation program.
Raising the flat tax preserves the framework while extracting additional revenue from the very high-net-worth individuals who benefit from it.
It is a politically easier move than creating a complex investment-based system, and it signals the government’s desire to monetize rather than restrict the program.
From a policy perspective, this is a calibrated tightening: the regime remains available and competitive, but at a higher cost for newcomers.
Implications for new applicants
For potential applicants, timing will be crucial.
Until the new law comes into force, the current rules remain valid, meaning that anyone who completes their relocation and opts for the regime now should still qualify for the €200,000 flat tax (plus €25,000 per family member).
Based on Italy’s consistent legislative practice, those who establish residency before the new law is enacted will be “grandfathered” under the current rates for up to 15 years.
Filing a tax ruling with the tax authorities may also help as an additional demonstration of intent to apply the regime, strengthening one’s position in case of interpretative uncertainty during the transition.
Broader impact
Even with a higher rate, the flat tax continues to offer a level of certainty and simplicity unmatched by most European jurisdictions.
Its appeal lies in the exemption of all foreign-source income from Italian taxation, a decisive advantage for globally mobile families, entrepreneurs, and investors.
By abandoning the investment condition, the government preserves the regime’s operational clarity.
The increase to €300,000 will narrow the net benefit for some, but Italy will likely remain a competitive destination for high-net-worth individuals (HNWIs) looking to relocate their tax base, especially as other countries such as the UK and Portugal abolish their special tax regimes.
The draft confirms the direction of Italy’s fiscal policy: More revenue, but still openness to international taxpayers.
The key takeaway is stability for existing residents and a predictable transition for newcomers.
Italy’s message remains clear: The door is still open, but the entry ticket may soon cost more.
