Who can benefit from this regime?

This tax regime is applicable to persons who have never been tax residents in Italy or have not been tax residents for many years prior to application.

Keep in mind that in order to legally reside in Italy, foreign nationals who do not already hold an Italian residence permit will need to apply for a visa that fits their personal and professional profile. For example, in the case of passive income from investments, a pension or capital stock, the foreign national will be granted a visa and a residence permit for Elective Residence.

What are the tax effects of the € 200K Lump-Sum Tax regime?

  • Taxpayers who qualify for the Lump-Sum Tax regime are subject to an annual flat tax on income earned abroad of €200,000 (with the possibility of extending the regime to each family member with an additional annual flat tax of €25,000 each). On the other hand, for those who became residents util August 10, 2024, the amount of the flat tax will be €100,000.
  • For the first 5 years of application of the €200,000 Lump-Sum Tax regime, capital gains from the transfer of qualifying participations are excluded from the Lump-Sum Tax regime and therefore capital gains are subject to ordinary taxation.
  • Foreign assets are not subject to monitoring obligations and are exempt from taxes on the value of investments held abroad and on the value of real estate;
  • There is also no estate or gift tax.

Main requirements to apply for the € 200K Lump-Sum Tax regime

  • The applicant must have been a non-Italian tax resident for at least 9 years out of the 10 years preceding the first year of application of the €200K Lump-Sum Tax regime.
  • The applicant must have qualified as a tax resident as of the first year of application or the second year with respect to the year of relocation to Italy.
  • The applicant must pay the lump sum tax by the ordinary payment deadline and opt for the application of the scheme through the tax return and by the ordinary deadline for filing tax returns (e.g., by September 30, 2025 for the tax year 2024).

In order to obtain confirmation of the necessary requirements for access to the lump sum scheme, the applicant may submit a request for a ruling to the Tax Authorities; within the 120-day period, the Authorities will rule on the matter and send a decision to the applicant.

Duration of the 200K Lump-Sum Tax regime

The 200K Lump-Sum Tax regime can be effective for a maximum period of 15 years. The option for this regime can be revoked by the taxpayer before its natural expiry. However, once revoked, the regime cannot be reactivated.

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Do not hesitate to contact us for further information on this special tax regime and for advice on your specific tax situation and on the type of visa you could apply for to become an Italian resident.

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