Italy’s Resident Non-Domiciled Program

To whom is it addressed this kind of benefit deriving from the Italian fiscal residence?

The inter-ministerial decree n. 1202/385 bis, stated by the External and by the Internal Affairs Ministry and the art. 1, par. 155 and 156 of the law n. 232/2016 rule about some forms of benefits for Visa and stay permit applications for people willing to move their fiscal residence to Italy, in order to attract foreign investors. This is also possible according to art. 24-bis D.P.R. 22 of December 1986, n. 917, in connection with: innovative start-up, investment initiatives of high formation , research or sponsorship to be realized also with enterprises, universities, research institutes or other private or public Italian subjects.

Which kind of Visa can I apply for by using this programme?

By moving your fiscal residence in Italy, you can benefit from a fast track procedure in order to apply for your Italian National Visa, basing on the purpose of your stay.

What is the flat-tax and to whom is it addressed?

A new fiscal programme has been launched in 2017, in order to attract new entrepreneurs and physical persons with high income capacity. In fact, they can benefit from a favourable fiscal regime, moving their fiscal residence to Italy. This new regulation allows them to pay a tax of 100.000,00 € instead of the physical persons income tax, for all their incomes produced abroad. This tax is not applicable for the capital gains deriving from the transfer of qualified shares of foreign subjects, which have been produced within five years from the transfer to Italy. Conversely, the IRPEF regime is still valid for all the incomes produced in Italy.

In which circumstances this new regulation is applied?

In order to benefit from this new regime stated in art. 24-bis of the Italian TUIR I need:

  • A fiscal residence in Italy;
  • Not to have an Italian residence for at least 9 of the 10 tax period before the beginning of the validity period of this new option;
  • To pay the Italian taxes;
  • To send a specific request to the Italian Fiscal Administration in order to ask for the eligibility of this regime.

How can I get the Italian fiscal residence?

You can get the Italian fiscal residence:

  • De facto: staying in the Italian territory for at least 183 days during the calendar year;
  • By law: subscribing your residence to the competent public office of your domicile city. If you are an European citizen your residence subscription can be done on the basis of your accommodation in Italy, according to the free move and establishment principle.
  • If you are a third-country national extra EU, you can obtain your residence after your Italian stay permit.

Are there also some facilities for the family of the applicant?

Yes, there are. In particular, the sum of fiscal contribution for income produced abroad and declared in Italy is reduced to 25.000 € for each income period for family members, as stated in par. 6. The tax must be paid in one solution, within the deadline for the balance of the income taxes.