Last year, the official data on Italy’s preferential tax regimes told a relatively simple story: the country’s inbound tax incentives were growing rapidly, attracting workers, academics, pensioners, and high-net-worth individuals at a scale that made them increasingly relevant to Italy’s broader fiscal and migration strategy.
The newly released Ministry of Economy and Finance data for tax year 2024 confirm that trend. But they also add an important nuance: Italy’s special tax regimes are no longer merely expanding. They are entering a more selective, more politically visible, and more strategically delicate phase.
The numbers remain strong. In 2024, the impatriate regime, which allows qualifying individuals to exempt a portion of their employment income from taxation, applied to 44,881 employees, up from 41,020 in 2023.
The professors and researchers regime, which offers a similar income exemption to academics and scientists relocating to Italy, applied to 4,774 employees, up from 4,102, with average gross employment income of €56,411.
The flat tax regime for new residents, which substitutes a fixed annual levy for ordinary taxation on all foreign-source income, also continued to grow.
In 2024, 1,631 individuals filed the NR section for new residents, compared with 1,242 in 2023. Of these, 48.4% also declared Italian-source income, for a total of €102.5 million, mostly employment income.
The 7% regime for foreign pensioners, which applies a flat 7% substitute tax on foreign-source income for retirees relocating to qualifying municipalities in Southern Italy, reached 933 taxpayers, up from 672 in 2023.
In short, all four regimes continued to expand.
The 2024 Data in Context
The first point worth stressing is that these are not marginal income profiles.
Italy’s average declared income in 2024 was €25,820. Against that benchmark, impatriate employees declared an average gross employment income of €120,922, roughly 4.7 times the national average.
Researchers and professors declared €56,411, more than twice the national average. New residents who also declared Italian income generated approximately €102.5 million of domestic taxable income, while foreign pensioners under the 7% regime declared total foreign-source income of about €61,500 per person.
These figures matter because the political debate around preferential regimes often focuses on the tax discount, while ignoring the counterfactual: many of these individuals would likely not be Italian tax residents at all without a targeted regime.
A preferential tax regime is not simply a revenue concession. It is also a fiscal import mechanism. It brings into the country income, spending, property investment, professional activity, school fees, consumption, advisory fees, and in many cases social security contributions and employment relationships that would otherwise remain outside Italy.
That does not mean every regime is beyond criticism. It does mean that the discussion should be based on data, not instinct.
The Impatriate Regime: Still Growing, But the Real Test Is Ahead
The impatriate regime remains by far the largest of the inbound tax incentives. In 2024, it covered 44,881 employees, with an average gross employment income of €120,922. That is a significant increase both in number and in average income compared with 2023.
However, the 2024 figure needs to be interpreted carefully.
The impatriate regime was substantially amended by Legislative Decree No. 209/2023, with the new version applying from 2024. The new rules are more restrictive than the previous framework: the benefit is generally limited to 50% taxable income, or 40% taxable income in the presence of qualifying minor children, and applies within a €600,000 income cap.
The Ministry’s chart shows that only a relatively small part of the 2024 employee population falls under the new 2024 codes: 1,617 employees under the 50% taxable income rule and 455 under the 40% rule. The majority of the 2024 beneficiaries still appear under the legacy versions of the regime.
This is not a weakness in the data. It is precisely the point.
The 2024 numbers confirm the accumulated strength of the old regime, but they do not yet fully measure the attractiveness of the new one. The real test for the reformed impatriate regime will come in the 2025 and 2026 tax data, when the number of individuals entering under the stricter framework becomes more visible.
For now, the message is mixed but still positive: the regime continues to attract or retain high-income workers, but policymakers have clearly moved from a highly generous attraction model to a more controlled, more selective framework.
There is also a second technical point that should not be missed. The headline figure of 44,881 refers to employees. The Ministry notes that the impatriate regime also concerned 5,720 taxpayers with self-employment or business income, of whom 1,012 also had employment income.
Because of this overlap, the total number of unique impatriate beneficiaries cannot be obtained by simply adding the two figures. But the broader conclusion is clear: the regime remains relevant not only for employees, but also for professionals and business operators.
Researchers and Professors: A Smaller But High-Value Regime
The professors and researchers regime is smaller, but strategically important.
In 2024, it applied to 4,774 employees, with an average gross employment income of €56,411. It also applied to a small number of self-employed taxpayers, although the employee figure remains the meaningful reference point.
Compared with the impatriate regime, the researchers and professors regime has a narrower policy purpose: attracting academic and scientific human capital. Its scale is therefore naturally smaller. But its value should not be assessed only through income tax figures.
Researchers and professors bring institutional links, international networks, research output, teaching capacity, and reputational benefits for universities and research centers. For a country that has historically struggled with brain drain, this regime remains one of the clearest examples of tax policy being used as a human capital instrument.
The 2024 data show continued growth, but not explosive growth. That is not necessarily a problem. For this category, quality matters more than volume.
New Residents: The Flat Tax Regime Continues to Expand
The flat tax regime for new residents is the most politically sensitive of Italy’s inbound tax regimes, but also one of the most internationally visible.
In 2024, 1,631 individuals filed the NR section. This represents a 31% increase from 2023.
Almost half of them, 48.4%, also declared Italian-source income, for a total of €102.5 million. The Ministry specifies that this Italian income was predominantly employment income, representing 73.3% of the total.
This is an important point. The flat tax regime is often described as a passive wealth regime for people who merely relocate their tax residence while keeping their economic life abroad. The data suggest a more nuanced picture: a significant share of new residents also declare income in Italy, and that income remains taxed under ordinary Italian rules.
The 2024 data also come during a period of reform. For individuals transferring tax residence to Italy after 10 August 2024, the annual substitute tax increased from €100,000 to €200,000. From 2026, the regime has become even more expensive for new entrants, with the annual flat tax rising to €300,000 for the main applicant and €50,000 for each qualifying family member, according to current professional guidance on the 2026 changes.
This makes the 2024 numbers especially relevant. They show that the regime was still expanding before the full impact of the higher entry cost became visible. The next question is whether Italy can maintain the same momentum after moving from €100,000 to €200,000 and then to €300,000.
The likely answer is that the composition of applicants will change. The regime may become less attractive to merely affluent individuals, but remain compelling for ultra-high-net-worth individuals with substantial foreign income, complex international assets, and a preference for stability, lifestyle, and EU residence.
In other words, the flat tax regime may become smaller at the margin, but more selective.
The 7% Pensioner Regime: Quietly Becoming More Relevant
The 7% regime for foreign pensioners is less discussed internationally than the flat tax for new residents, but the 2024 data show significant growth.
The number of taxpayers using the regime rose from 672 in 2023 to 933 in 2024, an increase of almost 39%. These taxpayers declared €37.6 million of foreign pension income, equal to an average of €40,262, and €57.4 million of total foreign-source income. The substitute tax declared amounted to €4 million.
This regime has a different policy logic from the flat tax for new residents. It is not designed to attract billionaires to Milan or Rome. It is designed to bring foreign pension income and consumption into smaller municipalities in Southern Italy and certain qualifying regions.
The amounts involved are much smaller on a per-person basis than in the HNWI regime, but the territorial objective is also different. If properly connected with local housing, healthcare, and municipal development strategies, the 7% regime can serve as a modest but useful tool for repopulation and local spending.
The challenge is execution. A tax regime alone cannot make a small town attractive. It can create attention and financial incentive, but infrastructure, services, healthcare access, language support, and housing quality determine whether retirees actually move and stay.
What the Data Really Show
The 2024 data do not prove that preferential tax regimes are perfect. They do not answer housing concerns in Milan, distributional criticism, or the question of how generous the regimes should be.
But they do show something important: these regimes are not symbolic. They are being used, they are growing, and they are attracting taxpayers with income profiles well above the national average.
This matters for Italy.
Italy is a high-tax country with demographic pressure, a history of skilled emigration, and a constant need to attract capital and human talent. In that context, preferential tax regimes are not just fiscal exceptions. They are competitive tools.
The better policy question is not whether Italy should have them at all. The better question is how to design them so that they attract the right taxpayers, preserve legal certainty, avoid abuse, and generate benefits beyond the individuals who use them.
The 2024 data point in that direction. Italy has tightened the impatriate regime. It has increased the price of the new residents flat tax. It has kept the researchers regime in place. It has allowed the 7% pensioner regime to continue growing. This is not a policy of indiscriminate tax discounting. It is a move toward segmentation.
Different regimes for different categories. Workers, academics, HNWIs, and pensioners are not the same population. They should not be treated as such.
A Maturing System
The new statistics confirm that Italy’s inbound tax regimes remain attractive. But the more interesting message is that the system is maturing.
The impatriate regime is moving from broad generosity to a stricter and more selective model. The researchers and professors regime continues to support academic attraction.
The flat tax for new residents is becoming more expensive, likely pushing it further toward the ultra-high-net-worth segment. The 7% pensioner regime is growing as a smaller but potentially useful territorial policy tool.
The result is not a mass relocation machine. It is a portfolio of targeted regimes, each with a different purpose.
For Italy, the lesson is clear: preferential tax regimes can work, but only if they are stable, credible, and designed around real economic objectives. The 2024 data suggest that, despite reforms and political debate, international taxpayers are still responding.
That is not a reason to stop refining the system. It is a reason not to dismantle it.
