New special tax regime for individuals moving to Italy: the substitute tax on foreign-source income and gains

Abstract

Italy has introduced a special new tax regime for individuals, whether Italian or foreign nationals, who transfer their residence to Italy. This special regime, which is optional and aimed at attracting HNWIs, provides for a fixed 100,000 Euro annual tax on foreign income and gains, irrespective of their amount, and additional benefits, including the exemption of foreign assets from wealth taxes and inheritance and gift tax. This special regime is effective for up to 15 years and may be voluntarily extended to one or more family members by paying an additional 25,000 Euro per family member benefitting from the regime.