I heard about Italy’s new non-domicile tax program. Does it apply to all foreign income or income from one certain foreign country? Do all kinds of income apply? I also heard that once a foreign investor opts to use the program, it is valid for 15 years. Will it still apply to me if I become an Italian citizen during that time?
Answers
A new fiscal program 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 favorable fiscal regime, moving their fiscal residence to Italy. This new regulation allows them to pay a tax of 100,000 euros 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 income produced in Italy. This program applies to all the income 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. Once a foreign investor opts to use the program, it is valid for 15 years. This is a very unusual situation, however. The law is pretty clear by including in this provision persons willing to move their fiscal residence to Italy in order to attract foreign investments. Since this is a fiscal law, it does not mention the citizenship but only the fiscal residency.
A new fiscal program 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 favorable fiscal regime, moving their fiscal residence to Italy. This new regulation allows them to pay a tax of 100,000 euros 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 income produced in Italy. This program applies to all the income 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. Once a foreign investor opts to use the program, it is valid for 15 years. This is a very unusual situation, however. The law is pretty clear by including in this provision persons willing to move their fiscal residence to Italy in order to attract foreign investments. Since this is a fiscal law, it does not mention the citizenship but only the fiscal residency.
The "res non-dom" tax regime option is applicable to all foreign income, notwithstanding the country of origin (as long as the applicant has indicated such country wihtin the option's geographic perimeter) nor the kind of income produced (only exclusion is for capital gains from the transfer of qualified shareholdings realized in the first five taxable periods from the option's exercise). The main condition is that the person applying for this tax regime shall not have resided in Italy during at least nine of the 10 years preceding the residency transfer. This regime is automatically renewed each year up to 15 years, unless in case of free revocation, and the acquisition of the Italian citizenship during the validity period of the regime does not affect its application.
The "res non-dom" tax regime option is applicable to all foreign income, notwithstanding the country of origin (as long as the applicant has indicated such country wihtin the option's geographic perimeter) nor the kind of income produced (only exclusion is for capital gains from the transfer of qualified shareholdings realized in the first five taxable periods from the option's exercise). The main condition is that the person applying for this tax regime shall not have resided in Italy during at least nine of the 10 years preceding the residency transfer. This regime is automatically renewed each year up to 15 years, unless in case of free revocation, and the acquisition of the Italian citizenship during the validity period of the regime does not affect its application.
