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Commentary

6.3.3 Impatriate regime

Italy

There is a concessional taxation scheme, recognised for workers who transfer their residence to Italy (Legislative Decree No 147/2015, Art 16, para 1). However, this legislation was abrogated and changes were introduced from 1 January 2024, which are noted below (Legislative Decree No 209/2023, Art 5).

However, transitional arrangements in 2024 are in place for those who already have access to the old regime and have the benefit period in place as of 31 December 2023 or can also access it during the 2024 tax period.

The new rules apply to those individuals, having the required access conditions, who transfer their tax residence to Italy as of the tax year 2024. This means that the transfer by registration in the resident population registry takes place in the year 2024.

Impatriate regime – rules after 1 January 2024

The residence rules, from 1 January 2024 (see 1.1), are applied to the definition of residence for the purpose of the impatriate regime.

Legislative Decree 209/2023, Art 1, effective from 1 January 2024, changed the rules for qualifying residence for tax purposes and

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Web page updated on 17 Mar 2025 16:25