Recent Competitive Tax and Immigration Measures are Turning Italy into an ‘El Dorado’ for Foreign Investors, Workers and HNWIs

Abstract

The end of globalization, following the Brexit and Trump’s election, is having immediate repercussions also on the approach of States on tax policies. Although the international community is still engaged in various multilateral projects (e.g. Base Erosion and Profit Shifting (BEPS), etc.), in the recent years various States, especially in the European area, have unilaterally introduced optional tax regimes specifically designed to attract foreign individuals, reopening a new phase of (lawful) tax competition. Italy has recently aligned with this trend by introducing significant amendments to its immigration and tax rules aimed at permitting a ‘fast-track’ visa procedure for relevant foreign investors and a fifteen-year long exception to the worldwide income tax principle, which allows for the payment of an annual flat tax of EUR 100,000 (plus EUR 25,000 for each family member transferring to Italy with the main applicant) for foreign-sourced income in lieu of the standard progressive tax rates. This measure, which is very interesting also because it allows ‘new Italian residents’ to start accumulating the years necessary for applying for citizenship, appears compatible both with EU law and Italian constitutional principles, and guarantees a coordination with the double tax treaties in force.