Following the amendment, the measure only applies to incomes below 600,000 euros
Among other things, implementing the decree of the tax delegation law provides for changes to the facilitation regime for expatriates, which entailed tax advantage measures for individuals who transferred their residency to Italy after having been abroad.
New Favorable Regime in Favor of Impatriate Workers: What Changes?
Income from employment, income assimilated to employment, and income from self-employment produced in Italy by workers who transfer their residence to the territory of the State pursuant to Article 2 of the Consolidated Income Tax Act within the limit of 600,000 euros contributes to the formation of total income limited to 50 percent of their amount when the following conditions are met:
- Workers have not been tax residents in Italy in the three tax periods preceding the said transfer and commit to being tax residents in the territory of the State for at least five years.
- The work activity is carried out in the territory of the State by virtue of a new employment relationship with a subject different from the one the worker was employed by abroad before the transfer, as well as those belonging to the same group. Work activity is performed for the majority of the tax period in the territory of the State.
- Workers possess high qualification or specialization requirements.
If the tax residency in Italy is not maintained for at least five consecutive years after the transfer, the worker loses the benefits and the Financial Administration proceeds to recover those already enjoyed, applying the relevant sanctions and interests.
Italian citizens registered in the Registry of Italians Residing Abroad (AIRE) as well as those not registered in the same Registry, provided they have had residency in another state according to a double taxation agreement, can access the tax benefits provided by this article.
What are the differences compared to the previous regime?
As can be seen, if previously the incomes generated in Italy contributed to the overall income at 30% of their amount, now they will contribute to the overall income at 50%. Furthermore, the distinction that provided for an increase in the tax benefit for those who moved to one of the regions in the South of Italy has been eliminated. The new regime, in fact, does not make distinctions between regions.
Moreover, following the introduced changes, the measure will only apply to incomes below 600,000 euros. Finally, unlike previously provided, the individual who requests to benefit from the regime must have spent at least three years outside of Italy, no longer two, and must commit to residing in the territory of the State for at least five years.
