Italy
A high-tax jurisdiction with a competing new-resident flat-tax regime under Article 24-bis TUIR. The substitute tax, €100,000 a year from 2017, rose to €200,000 for those moving after 10 August 2024 and to €300,000 for those becoming resident from 1 January 2026. Italy combines significant Mediterranean luxury infrastructure with one of Europe's older inheritance-tax regimes.
Why this jurisdiction matters
Italy's Article 24-bis TUIR regime, introduced by the 2017 Budget Law (Law 232/2016), replaces Italian tax on foreign-source income with a flat annual substitute tax for qualifying new Italian residents who were not Italian-resident in at least nine of the ten preceding tax years. Certain capital gains on substantial shareholdings realised in the first five years are excluded. The amount was €100,000 a year for those who opted in on moving before 10 August 2024. Decree-Law 113/2024 raised it to €200,000 for those transferring residence after 10 August 2024, and the 2026 Budget Law (Law 199/2025) raised it again to €300,000 for those becoming resident from 1 January 2026. Each earlier cohort keeps the amount in force when it moved. For the “Italian luxury tax” on high-powered cars (the superbollo), see below.
The relevant tax regime
- Income tax (IRPEF). Progressive to 43% top marginal; regional and municipal surcharges add up to approximately 4%.
- Article 24-bis flat tax. €300,000 a year for those becoming resident from 1 January 2026; €200,000 for those who moved between 11 August 2024 and 31 December 2025; €100,000 for earlier electors. It replaces tax on foreign income and gains, lasts up to 15 years, and also exempts the elector from IVAFE/IVIE, Quadro RW reporting and Italian gift and inheritance tax on foreign assets.
- IVAFE / IVIE. IVAFE at 0.2% a year on foreign financial assets (0.4% for assets in listed low-tax jurisdictions from 2024); IVIE at 1.06% a year on foreign real estate (raised from 0.76% by the 2024 Budget Law, Law 213/2023).
- Succession and gift tax. Among Europe's lowest: 4% to spouses and lineal relatives (above €1 million per beneficiary); 6% to siblings (above €100,000); 6% to other relatives to the fourth degree and certain in-laws; 8% to others.
- IMU. Municipal property tax on second homes.
- VAT. 22% standard. Since Decree-Law 95/2025 (in force 1 July 2025), a 5% rate applies to imports of works of art, collectors’ items and antiques and to most supplies of them (the margin scheme stays at 22%). Before that the reduced rate was 10%.
- Superbollo. Italy’s luxury-car surcharge: €20 a year per kW above 185 kW, on top of ordinary vehicle tax, reduced as the car ages and ending after 20 years.
Registration or residency mechanics
Italian tax residency is set by TUIR Article 2 (as amended from 2024). A person is resident if, for more than 183 days of the year, they are in the resident population register, have their domicile (the main place of personal and family relationships) or their habitual residence in Italy, or are physically present there. The Article 24-bis option is made in the tax return for the first year of residence, optionally after an advance ruling, and renews automatically. It can be extended to family members at €50,000 each for those resident from 2026, or €25,000 each for earlier cohorts.
Reporting and disclosure
CRS participant. FATCA Model 1 IGA. Foreign-asset reporting on Quadro RW; IVAFE/IVIE assessed on RW data (24-bis electors exempt). The beneficial-ownership register kept by the Chambers of Commerce has been subject to litigation over access since 2024, so check its current status.
The substance question
Article 24-bis residency requires substantive Italian residency — physical presence and registration. The regime is for residents, not for paper-only structures. Tax-treaty residence and CRS reporting follow standard rules.
Recent changes
Decree-Law 113/2024 raised the 24-bis substitute tax to €200,000 for those moving after 10 August 2024. The 2026 Budget Law (Law 199/2025) raised it to €300,000, with family members at €50,000, for those becoming resident from 1 January 2026. Decree-Law 95/2025 cut VAT on art imports and sales to 5% from July 2025. Italian cultural-property export rules continue to restrict cross-border movement of cultural property. Figures as of October 2026.
Common asset classes parked here
- Italian real estate — particularly Tuscany, Lake Como, Capri.
- Exotic cars — Italian manufacturers; superbollo applies.
- Yachts — Mediterranean yacht charter market; Italian VAT mechanics on charter.
- Italian art — cultural-property export restrictions.
- 24-bis-elector residency for international HNW migration.
Primary Sources
- Testo Unico delle Imposte sui Redditi (TUIR), DPR 22 dicembre 1986, n. 917, Articolo 24-bis.
- Legge 11 dicembre 2016, n. 232 (introduction of Art. 24-bis); Decreto-Legge 9 agosto 2024, n. 113, art. 2 (€200,000); Legge 30 dicembre 2025, n. 199 (Legge di Bilancio 2026; €300,000/€50,000).
- Legge 30 dicembre 2023, n. 213 (IVIE rate 1.06%).
- Decreto-Legge 30 giugno 2025, n. 95, art. 9 (5% VAT on works of art).
- DPR 633/1972 (VAT).
- D.Lgs. 31 ottobre 1990, n. 346 (Testo unico dell’imposta sulle successioni e donazioni); Decreto-Legge 3 ottobre 2006, n. 262 (current rates and thresholds).
- Decreto-Legge 6 dicembre 2011, n. 201, art. 19 (IVAFE and IVIE).
- Codice dei Beni Culturali, D.Lgs. 42/2004 (cultural property export).
- Agenzia delle Entrate — agenziaentrate.gov.it.
Reviewed October 2026