Italy’s Flat Tax for New Residents: What It Means for a Move to Tuscany

Picture a long lunch on a terrace in the Tuscan hills. The house has been found, and the talk drifts from the house to the move itself, and from the move to the question of tax. The question has a precise answer.

How much is the flat tax now?

The figure is €300,000 for each tax year, whatever the income. For every family member to whom the option is extended, a further €50,000 is due for each tax year.^[2] The tax is paid in one instalment by the date set for the payment of the balance of income tax, and it cannot be deducted from any other tax.^[2]

The amount has changed twice. A decree-law raised the tax from €100,000 to €200,000 for those who transferred residence after its entry into force, in August 2024.^[4] A law then raised it to €300,000 for those who transfer from its entry into force, on 1 January 2026, according to the Agenzia delle Entrate (AdE), the Italian revenue agency.^[5]

Which figure applies to a given person follows the date on which he or she transferred residence.^[6] An older passage of the Agenzia’s guidance page still shows the earlier figures; the figures here are those of the statute and of the page’s opening notice.^[7][8][9] The two versions are set side by side in the Notes at the foot of the article.

Which rule is it, and from when?

The option was written into the 1986 consolidated income tax code, the TUIR, as article 24-bis.^[10] A new consolidated code, approved by a legislative decree published on 3 July 2026, moves it to article 246.^[11] For the amounts, conditions and paragraphs described here, the content is substantially the same.^[12] The decree entered into force on 4 July 2026.^[13] The new code, however, applies only from 1 January 2027,^[14] and from the same date the first 191 articles of the 1986 code are repealed.^[15][16]

This article follows the text of article 246. The rules and their dates are changing, and the regime depends on each person’s circumstances. How the new code’s application date works in practice is a matter for a tax adviser.

Who can opt?

The first test is residence. The option is open to a natural person who transfers his or her tax residence to Italy under the ordinary criteria, and who was not tax-resident in Italy for at least nine of the ten tax years before the option starts.^[3] Tax residence means residence for income-tax purposes, which follows Italian statutory criteria. It is not the same as immigration status or ownership of a home.^[17]

The option covers income produced abroad.^[18] Italian-source income is taxed under the ordinary rules. There is one exception inside the foreign income: capital gains on the sale of qualifying shareholdings,^[19] if realised in the first five tax years of the option, are not covered by the substitute tax. The taxpayer may also opt out of the regime for income produced in named foreign States.^[20] For those States the ordinary rules apply and the foreign tax credit is available.

On request the option can be extended to family members within the category set by the Civil Code (the article is given in the Notes) who meet the same conditions.^[21] Revocation or forfeiture of the head of the family ends the extension, while forfeiture of a family member does not end the head’s option.^[21] The option cannot be combined with the regimes of two other articles of the new code, understood to be the regime for workers who move to Italy.^[22]

How is the option made?

Here the statute and the Agenzia’s guidance page are worded differently, and both versions are given as the texts have them.

The statute says that the option must be exercised after obtaining a favourable reply to a specific interpello request, a request to the Agenzia for a ruling on how a tax rule applies to a particular situation. The request is filed with the Agenzia within the deadline for the return relating to the year in which residence is transferred, and the option takes effect from that year.^[23] The taxpayer indicates the jurisdiction or jurisdictions of last tax residence, which the Agenzia communicates to the authorities of those States.

The guidance page uses other words. Before exercising the option the taxpayer “may also” ask for an interpello, and the option is made in the return for the year of the transfer or for the following year.^[24] The statute and the guidance page therefore differ on whether the interpello is mandatory and on the deadline. The statute is the binding text.^[25]

How long does it last, and how does it end?

The option is revocable, and in any case it ceases after fifteen years from the first tax year for which it is valid.^[1] According to the AdE it is tacitly renewed each year unless it ends.^[26]

It also ends if the tax is not paid. Failure to pay the substitute tax in whole or in part ends the effects of the option, although effects already produced in previous years are preserved. Revocation or forfeiture bars a new option.^[1] According to the AdE there is no ravvedimento operoso for a late payment, the procedure by which a late payment can be regularised with a reduced penalty, and payment is made by form F24.^[27][28]

What else does the option change?

Holders of the option, and the family members to whom it is extended, are exempt from the annual reporting of foreign assets, the form known as RW, and from the taxes on foreign real estate (IVIE) and on foreign financial assets (IVAFE).^[29]

The relief has a boundary. According to the AdE’s guidance on inheritance and gift tax, the effect of the regime concerns assets held abroad, and it gives no relief for assets in Italy.^[30] The subject is taken up in “Who Inherits the House”. Treatment in the country of origin, including tax credit and treaty rules, is a separate matter and depends on that country’s law.

Does a house have anything to do with it?

The regime concerns tax residence, and it is independent of the purchase of a house. It depends on the transfer of tax residence and on the non-residence condition.^[3] Owning or buying a house does not qualify a person.

An elective residence visa is an immigration matter and a separate step, described in “The Elective Residency Visa”. Whether the regime suits a given person, and the sequence of the move, the option and any purchase, are matters for a tax adviser.