How the €300,000 flat tax works
Italy's Art. 24-bis regime (the "regime dei nuovi residenti") lets someone who becomes an Italian tax resident — and who was not resident in Italy for at least 9 of the previous 10 years — pay a fixed annual substitute tax on all foreign-source income, no matter how large that income is.
- €300,000/year — art. 24-bis c. 2 sets the substitute tax “nella misura di euro 300.000 per ciascun periodo d’imposta”. That amount applies to those who transfer residence to Italy from 1 January 2026 (L. 199/2025 art. 1 c. 26), up from €200,000 (D.L. 113/2024).
- +€50,000/year per qualifying family member who joins — art. 24-bis c. 2, “ridotto a euro 50.000 … per ciascuno dei familiari di cui al comma 6”, the relatives of art. 433 of the civil code (c. 6). Up from €25,000, on the same 1 January 2026 dividing line.
- Lasts up to 15 years — art. 24-bis c. 4 ends the option fifteen years after the first tax period. The same paragraph makes it revocable, ends it on omitted or partial payment, and bars a new option after revocation or lapse.
- Also exempts foreign assets from Italian wealth taxes (IVIE/IVAFE) and foreign-asset reporting (Form RW) — L. 232/2016 art. 1 c. 153, in the note to art. 24-bis.
Italian-source income is excluded — it is always taxed under normal IRPEF. One carve-out: art. 24-bis c. 1 keeps gains on qualified shareholdings (art. 67 c. 1 lett. c) realised in the first five tax periods of the option outside the substitute tax — they stay under the ordinary regime of art. 68 c. 3. We state no rate for them: the article does not set one.
Break-even: when does it pay off?
The flat tax replaces what you'd otherwise pay in progressive IRPEF on that foreign income. Art. 11 c. 1 TUIR sets the brackets — we print the band edges in whole euro, so “over €28,000” appears below as €28,001:
- 23% up to €28,000
- 33% from €28,001 to €50,000
- 43% above €50,000
Because the marginal rate maxes out at 43%, ordinary tax only reaches €300,000 at roughly €716,000 of foreign income for a single filer — that break-even is our arithmetic on the art. 11 brackets (23%×€28,000 + 33%×€22,000 = €13,700, then (€300,000 − €13,700) ÷ 0.43 + €50,000 ≈ €715,800), not a figure the law prints. Below that, ordinary IRPEF on the income alone costs less — but the flat tax also removes wealth taxes and reporting, which can tip the balance for asset-heavy profiles. This calculator compares income tax only; factor in IVIE/IVAFE separately.
How to opt in: steps, ruling & the 30 June payment (2026)
Art. 24-bis is elected through your Italian tax return — there is no separate "application form". The advance ruling is optional but widely used, and the whole regime hinges on paying the lump sum on time each year.
Key steps & deadlines
| Step / Item | When |
|---|---|
| Advance ruling (interpello) | Before the option — art. 24-bis c. 3 |
| Option in tax return (Modello Redditi PF) | By the return deadline for the year of transfer |
| Lump-sum payment via F24 | By 30 June, every year |
| Substitute tax (2026 elections) | €300,000 + €50,000/member |
The "fee" is the substitute tax itself — there is no separate filing fee. Use the calculator above to see whether it beats ordinary IRPEF on your foreign income.
Order of the steps
Art. 24-bis c. 3 has the option exercised after a favourable interpello ruling under art. 11 c. 1 lett. f) of L. 212/2000, within the deadline for filing the return for the year of transfer, and it takes effect from that tax period — so the ruling comes first and the return carries the election. We state no reply time for the ruling: neither the article nor its notes sets one. The regime is revocable, and art. 24-bis c. 4 bars a new option after revocation or lapse.
Documents to prepare
- Codice fiscale and proof of Italian tax residence.
- Evidence of non-residence for 9 of the previous 10 years.
- Eligibility checklist for the interpello (if filed).
- Details of any family members joining and countries to exclude.
Frequently asked questions
Who qualifies?
Anyone becoming an Italian tax resident who was not resident in Italy for at least 9 of the prior 10 years. No nationality or retirement requirement — entrepreneurs, investors, executives, and high-earning remote workers all qualify.
Is this the same as the regime for foreign pensioners?
No. Art. 24-bis is the lump-sum regime for high foreign income. Italy has a separate regime for foreign pensioners who move to certain southern towns; we state neither its rate nor whether the two can be combined, because art. 24-bis and its notes do not say — the only incompatibilities they list are art. 44 of D.L. 78/2010 and art. 16 of D.Lgs. 147/2015 (L. 232/2016 art. 1 c. 154). Ask the Agenzia delle Entrate.
I'm a US citizen — does it still help?
The US taxes worldwide income regardless of residence. Whether the Italian substitute tax is creditable against US tax (Foreign Tax Credit) requires specialist US–Italy advice; treatment varies. Get professional guidance before electing.
How is it paid?
In a single instalment by 30 June each year. Missing the payment ends the regime — your foreign income then falls under ordinary IRPEF, with no reinstatement.
Common rejection & delay reasons
Common reasons the Italian flat-tax regime is denied or lost.
- Failing the 9-of-10-years test. You must have been non-resident for 9 of the last 10 years before moving.
- Missing the June 30 payment. The substitute tax must be paid via F24 by June 30; missing it can permanently end the regime.
- Using the wrong year's amount. The flat amount rose to €200,000 for residence transferred after 10 August 2024 (D.L. 113/2024) and to €300,000 for residence transferred from 1 January 2026.
- Not exercising the option correctly. It must be exercised in the Modello Redditi PF return, not just paid.
- Adding family members incorrectly. The per-member add-on (now €50,000) must be elected properly.
Flat-tax filing checklist (save your progress)
Tick each item as you prepare it. Progress is saved in this browser — nothing is uploaded. This is a preparation aid, not tax advice.
Sources and official references:
Art. 24-bis TUIR (Presidential Decree 917/1986, Normattiva); 2026 Budget Law (Law No. 199 of 30 December 2025, Normattiva) raising the substitute tax to €300,000 and the family add-on to €50,000 for elections from 1 January 2026 (existing electors are grandfathered at their original rate), and cutting the middle IRPEF rate to 33%; Decree Law 113/2024 (€200,000 tier); Agenzia delle Entrate guidance on the regime. DPR 435/2001 art. 17 (Normattiva) for the 30 June balance and the 0.40% increase within the following thirty days. normattiva.it still refuses our automated collector, so on 22 September 2026 the articles were read in a browser and the passages relied on are kept verbatim in monitors/srccache/italy_tuir_24bis_20260922.md — art. 24-bis c. 1–c. 6 with notes 181 and 242, art. 11 c. 1 and DPR 435/2001 art. 17. Removed in that pass, for want of any basis in those articles: the 26% rate for qualified shareholdings sold in the first five tax periods, the “cut from 35%” note on the middle bracket, the ~120-day interpello reply time and the 30-day supplement window, the 7% pensioner rate and the claim that the two regimes are mutually exclusive, the EUR 100,000 tier in the checklist and the 2017/10 August 2024 grandfathering dates. Corrected to the articles: the interpello is a precondition of the option, not optional, and the option belongs in the return for the year of transfer rather than “year 1 or year 2” (art. 24-bis c. 3). The substitute tax is paid in a single instalment via F24 by 30 June each year, for up to 15 years. Income-tax comparison only; excludes regional/municipal surcharges, IVIE/IVAFE, and the qualified-shareholding carve-out. Estimate, not tax advice — an advance ruling from the Agenzia delle Entrate and a qualified advisor are required.