Draft — open questions below

The headline figures and eligibility test are read from the statute itself, in full, including its own amendment history. A few real questions — chiefly whether an existing beneficiary’s rate is locked at what they signed up for, or tracks the current figure — aren’t settled by anything found so far. Treat this as a starting point to confirm with a commercialista, not as advice.

Flat tax for new residents — a fixed annual sum instead of tax on foreign income

A person who moves their tax residence to Italy, having lived outside Italy for at least nine of the previous ten years, can pay one fixed annual sum — currently €300,000 — instead of ordinary Italian tax on their foreign-source income, for up to fifteen years. Extending it to a family member costs €50,000 more per person per year. It replaced tax on foreign income specifically: Italian-source income is still taxed normally, and capital gains on qualifying shareholdings stay outside the flat sum for the option's first five years. The figure has changed twice since the regime's 2017 introduction — €100,000 originally, €200,000 from August 2024, €300,000 now — and each change applied only to people transferring residence after it took effect, not to everyone already in the regime.

€300,000

flat sum a year, foreign income

€50,000

more, per extended family member

years, maximum

9 of 10

prior years must be non-resident

This isn’t the “€200,000 flat tax.” That figure was correct from August 2024, when it replaced the original €100,000 rate the regime launched with in 2017 — but a further increase, in the 2026 Budget Law, replaced it again before most coverage caught up. The current rate is €300,000, confirmed against the statute’s own currently-in-force text, not against a secondary source repeating the last number it saw. Each change applied only to people transferring residence after it took effect — someone already in the regime under an earlier rate isn’t automatically moved to the new one.

Who qualifies

Transfers tax residence to Italy, having not been tax-resident in Italy for at least nine of the ten tax periods before the move — a much longer look-back than the regime impatriati's three-year test.
Elects to pay a fixed substitute tax on foreign-source income — currently €300,000 a year — instead of ordinary Italian income tax on that income, regardless of how much foreign income is actually received in a given year.
The option can be extended to family members named in art. 433 of the Codice Civile, at €50,000 a year each, provided they independently meet the same non-residence test.
Capital gains on qualifying shareholdings (art. 67, comma 1, lett. c) are excluded from the flat sum for the option's first five years and taxed under ordinary rules instead.
The option must be exercised through a favourable response to a specific interpello (advance ruling request) to Agenzia delle Entrate, by the filing deadline for the tax return covering the year residence transferred, and lasts up to fifteen years unless revoked or forfeited for missed or partial payment.
A person can exclude one or more specific foreign countries from the flat-sum treatment, paying ordinary tax with a foreign tax credit on income from just those countries instead — decided when the option is exercised, or on a later amendment to it.

What this page does not cover

Whether an existing beneficiary's flat sum is locked at the rate in force when they first opted in, for the full fifteen years, or tracks the current rate, is inferred from the transitional clauses' own wording rather than stated as a standalone rule anywhere read for this file.
Comma 6's family-member eligibility test (art. 433 codice civile) is named but not itself read in full — this page states that the extension exists, not the precise list of who it can cover.
What counts as a 'qualifying shareholding' for the first-five-years capital-gains carve-out (art. 67/68) was not independently verified.
Says nothing about the interpello application process itself, typical processing time, or how the per-country income carve-out (comma 5) interacts with a specific double-taxation treaty — a professional question, not one this page answers.

The legislation

TUIR (D.P.R. 22 dicembre 1986, n. 917), art. 24-bis — VERIFIED — read in full, all 6 commi, from Normattiva's vigente (currently in force) text, plus its official aggiornamenti (amendment) annotations giving the exact effective-date window of each change. Introduced by L. 232/2016 art. 1 co. 152; the flat-sum figures in comma 2 have been amended twice since — see verificationNotes for the full chronology, each change's precise effective date, and why this file's headline figure is not the one most existing coverage of this regime still quotes.
D.L. 9 agosto 2024, n. 113, art. 2, comma 2 — VERIFIED — the amendment that raised the flat sum from €100,000 to €200,000. Read via Normattiva's own aggiornamento (233) annotation, verbatim: applies only to those who transferred residence to Italy AFTER this decree's entry into force (9/10 August 2024) — a grandfather clause, not a rate change for everyone already in the regime.
Legge 30 dicembre 2025, n. 199 (Legge di Bilancio 2026), art. 1, comma 26 — VERIFIED — the amendment currently in force, raising the flat sum from €200,000 to €300,000 and the per-family-member sum from €25,000 to €50,000. Read via Normattiva's own aggiornamento (242) annotation, verbatim: applies only to those who transfer residence FROM this law's entry into force — the same grandfather structure as the 2024 change, one cycle later.

Open questions — what a checker needs to settle

RESOLVED 2026-09-14 — the headline figure is €300,000/year, not €200,000. This regime is widely known online (and in this site's own earlier planning notes) as "the €200k flat tax," which was accurate from 10 August 2024 but was itself superseded by the 2026 Budget Law before this file was ever written. Read live against Normattiva's currently-in-force text: the figure is €300,000 for the principal applicant and €50,000 per extended family member, confirmed by the article's own official amendment annotations rather than by any secondary source.
RESOLVED 2026-09-14 — full chronology of the flat-sum figure, each stage confirmed against Normattiva's own text at that date rather than assumed from a chain of secondary citations: €100,000 (principal) / €25,000 (family) from the regime's introduction, 1 January 2017 (L. 232/2016) — not independently re-verified against the original 2017 text for this file, since it is superseded and not the headline; €200,000 / €25,000 from 10 August 2024 (D.L. 113/2024) — CONFIRMED by fetching Normattiva's text as it stood on 2025-06-01, which shows exactly these two figures and states its own validity window as "10-8-2024 al 19-12-2025"; €300,000 / €50,000 currently in force, from the 2026 Budget Law (L. 199/2025) — CONFIRMED as the vigente text as of 2026-09-14.
RESOLVED 2026-09-14 — each rate change is prospective only, by the statute's own express terms (comma 2's amendment annotations, not an inference): it applies to someone who TRANSFERS RESIDENCE after the amending law's effective date, not to everyone already inside the regime. Someone who transferred residence and exercised the option while €100,000 or €200,000 was in force is not read from this text as being retroactively moved to €300,000 — though this file has not found or read a source stating explicitly that an existing beneficiary's rate is locked for their full 15 years rather than tracking the current rate; that inference follows from the transitional clauses' own wording ("si applica ai soggetti che hanno trasferito... successivamente alla data di entrata in vigore") but is not spelled out as a standalone rule anywhere read for this file.
UNRESOLVED — the exact date the 20 December 2025 boundary reflects. Normattiva's text as fetched on 2025-06-01 states its own validity window ends "19-12-2025," while the currently-in-force text states its own window begins "1-1-2026" — a roughly two-week gap this file has not investigated (a transitional third version, a database artifact, or Normattiva pre-populating a scheduled future change against an approximate boundary). Immaterial to anything this page states, since both figures either side of the gap are correctly captured, but worth knowing before quoting an exact day-of-change date.
UNRESOLVED — comma 6's family-member extension covers the persons named in art. 433 of the Codice Civile, which this file has not read in full. Secondary understanding is that it is broader than a spouse and minor children (potentially parents, other ascendants/descendants, and in some circumstances siblings, per the Civil Code's mutual-maintenance-obligation list) but this page states only that the extension exists and defers the precise list to that article rather than asserting a scope not directly verified.
UNRESOLVED — comma 1's carve-out for capital gains on qualifying shareholdings (art. 67, comma 1, lett. c) in the first five tax periods was read directly and is stated accurately, but this file has not separately verified what counts as a "qualified" shareholding under art. 67/68, which sits in a different article this pass did not read.
"Needs a commercialista pass" applies here for the same reason it applies to every hand-curated regime on this site: the interpello procedure (comma 3), the per-country carve-out mechanism (comma 5), and the interaction with double-taxation treaties are all read accurately from the statute's own words but not independently corroborated against Agenzia delle Entrate's own operative guidance (circolari, risposte ad interpello) the way the regime impatriati page's citations were.