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TAX REGIME OF IMPATRIATES: what changes from 2024

Starting in 2024 tax relief for impatriates, meaning workers who transfer their residence to Italy, will change.

Indeed, the Council of Ministers approved, in preliminary consideration, a legislative decree implementing the tax reform on international taxation. The text replaces Article 16 of Legislative Decree n. 147 of 14 September 2015.

Workers eligible for the benefit are those who obtain the transfer of tax residence in Italy on or after 01/01/2024 and who receive:

  • Income from employment;
  • Income assimilated to employment;
  • Income from self-employment.

THE TAX RELIEF

The new regulations provide for the reduction of taxable income by 50%, for a maximum reduction of 600.000 euro.

REQUIREMENTS

To be eligible for the benefit, workers must meet the following requirements:

  • workers have not been resident in Italy in the 3 tax periods prior to obtaining residency;
  • the employment must be with an entity other than the foreign employer (with whom you had the employment relationship before the transfer) and that is not part of the same group as it;
  • the employment must be carried out for most of the tax period in Italy;
  • workers must have tax residence in Italy for 5 years after the transfer in order to maintain tax relief, otherwise, they will be forced to return the facilities, paying interest;
  • workers must have the requirements of high qualification or specialization.

The requirements of high qualification or specialization (Legislative Decree n. 108, of 28 June 2012) occur in the cases of:

  • Attainment of a higher education qualification, issued by competent authorities in the country where it was obtained, certifying completion of a higher education course of at least three years in duration and the relevant higher vocational qualification, that falling into the following levels:
  • Level 1: legislators, entrepreneurs and senior management;
  • Level 2: intellectual, scientific and highly specialized professions;
  • Level 3: technical professions of the ISTAT classification of occupations CP 2011, attested by the country of origin and recognized in Italy.
  • Possession of the requirements of Legislative Decree n. 206/2007, limited to the practice of the professions regulated in that decree.

EXCEPTIONS

The provisions for researchers, university professors and sports workers already provided remain unchanged.

Author: Diana Cacciotti

info@studioferrari.com