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EVEN SMART-WORKERS CAN ACCESS THE FACILITATED TAXATION REGIME FOR IMPATRIATES

Moving to Italy can be a very good deal: keep your job on motherland and enjoy Italian weather, food, landscape, at a bargain tax rate.

The confirmation comes directly from the Revenue Agency.

With ruling no. 186/2022, in fact, it is established that even employees of companies established abroad, who carry out their work mainly in the Italian territory, benefit from the facilitated tax regime for impatriates (basically a discount from 50% to 90% of income tax,  with a duration of 5 to 10 years).

This regime, which we have already dealt with in the past, is based on Article 16 of Legislative Decree no. 147 (so-called Internationalization Decree), and is intended for the worker who, jointly:

  • transfers residence to the territory of the State, pursuant to Article 2 of the Consolidated Income Tax Act referred to in the Decree of the President of the Republic of 22 December 1986, no. 917 (TUIR);
  • was not resident in Italy in the two tax periods prior to the transfer and undertakes to reside in Italy for at least 2 years;
  • carries out the work activity mainly in the Italian territory.

The regime of expatriate workers is usable for five tax periods and can be renewed for a further five years, if specific requirements are met.

With the ruling indicated at the beginning of this article, therefore, the doubt that had initially arisen regarding the application of the aforementioned regime is put to an end. In fact, the rationale of the law is to welcome human capital in the territory of the Italian state. As a prerequisite for the application, it is envisaged that anyone who transfers residence to Italy from abroad is a worker, employee or self-employed. Nothing is explicitly established, however, regarding the “nationality” of the Entity to which the worker established in Italy is employed, nor the possibility that, despite being a foreign company, it has a permanent establishment in Italy.

 

enquire freely: emanuele@studioferrari.com