Italy Flat Tax 2026: EUR 300,000 — What Competitors Get Wrong and What You Actually Pay

What Is Italy's Art 24-bis Flat Tax Regime?

Italy's Art 24-bis flat tax — formally the imposta sostitutiva under Article 24-bis of the Italian Tax Consolidation Act (TUIR) — is a lump-sum tax regime that allows individuals who transfer their tax residence to Italy to pay a single annual substitute tax on all their foreign-sourced income. Instead of calculating actual foreign income and applying Italy's standard progressive rates (23%–43%), the regime charges a fixed EUR 300,000 per year regardless of how much is earned abroad. For an individual earning EUR 5 million in foreign dividends, the effective rate is 6%. For someone earning EUR 30 million, it is 1%. The arithmetic is unambiguous.

Introduced by Law 232/2016 (the 2017 Italian Budget Law), Art 24-bis was designed to attract globally mobile, high-income individuals to establish genuine Italian tax residence. The Italian Revenue Agency (Agenzia delle Entrate) administers the Art 24-bis regime through a structured enrolment process, including an optional advance ruling to confirm eligibility before the individual commits to relocating.

The scheme serves three broad profiles:

• HNWI investors with significant foreign dividend, capital gain, and interest income who want tax certainty on their international portfolio
• Entrepreneurs retaining ownership of foreign businesses who want to relocate their personal residence while maintaining operations abroad
• Family offices managing complex cross-border structures who benefit from replacing an unpredictable foreign-income calculation with a single fixed payment

Italian-sourced income remains taxable at standard Italian progressive rates. Art 24-bis replaces the tax on foreign income only — a distinction that is critical to proper financial modelling.

How Much Is the Italy Flat Tax in 2026 — and Why Do Competitors Cite the Wrong Number?

From 1 January 2026, Italy's Art 24-bis flat tax is EUR 300,000 per year for all new elections. This figure supersedes the EUR 100,000 original rate and the EUR 200,000 interim rate applied during 2025. Individuals who enrolled before 31 December 2025 may be grandfathered under their existing rate for the remainder of their 15-year election period.

The evolution of the Art 24-bis annual rate reflects successive Italian budget law changes:

The confusion in the market is understandable but no longer excusable. Many sources — including major advisory blogs, tax publications, and competing investment migration firms — continue to cite EUR 100,000. Some acknowledge the 2025 change to EUR 200,000 but have not been updated to reflect the further increase effective 1 January 2026. Anyone planning their Italian residency on a EUR 100,000 annual tax cost is working with a figure that is now three times too low.

Grandfathering provision: Individuals who already made the Art 24-bis election before 31 December 2025 continue under the rate applicable at the time of their enrolment. Those who enrolled before the end of 2024 remain at EUR 100,000 or EUR 200,000 (depending on when they enrolled). The EUR 300,000 applies exclusively to elections made from 1 January 2026 onwards.

This grandfathering creates a material advantage for early movers — those already inside the regime at EUR 100,000 or EUR 200,000 enjoy those rates for the remainder of their 15-year period, which at the current EUR 300,000 entry point represents a saving of EUR 100,000–EUR 200,000 per year.

Who Qualifies for Italy's Art 24-bis Flat Tax?

To qualify for Italy's Art 24-bis flat tax, an individual must not have been an Italian tax resident for at least nine of the ten tax years immediately preceding the election. There is no nationality restriction, no minimum age, and no minimum investment required under Art 24-bis itself. The regime is open to citizens of any country who meet the non-residency test and genuinely transfer their tax residence to Italy.

Core eligibility criteria:

• Non-residency test: must not have been Italian tax resident for at least 9 of the preceding 10 tax years. This is Italy's own strict tax residency definition — not passport or habitual-residence status elsewhere
• No nationality restriction: citizens of any country are eligible
• No age restriction: available to individuals of any age
• No profession restriction: available to employed individuals, entrepreneurs, retirees, and investors alike
• Genuine transfer of tax residence: the individual must genuinely transfer their centre of vital interests to Italy — a formal registration with the local anagrafe (municipality) and establishment of a primary domicile in Italy

Important note on Italian tax residency: Italy defines tax residence broadly under Art 2 TUIR. An individual is considered Italian tax resident if they are enrolled in Italian public registries (anagrafe), or if they maintain their domicile or habitual abode in Italy for the majority (183+ days) of the tax year. Individuals who have previously lived in Italy must carefully document a genuine gap of at least 9 years in their tax residency before electing Art 24-bis. Errors here can trigger backdated IRPEF assessments with interest and penalties.

Many HNWI clients combine the Art 24-bis election with the Italy Investor Visa (Visto Investitore), which provides a structured legal entry route to Italian residence for non-EU nationals. Investment thresholds for the Investor Visa range from EUR 250,000 for qualifying start-ups to EUR 2,000,000 for Italian government bonds. For a full breakdown of Italy's entry routes, see our Italy Golden Visa and Investor Visa guide.

What Does the EUR 300,000 Cover — and What Income Is Excluded?

Italy's Art 24-bis flat tax of EUR 300,000 per year covers all foreign-sourced income. The lump sum replaces standard Italian income tax (IRPEF) on dividends, capital gains, rental income, business profits, and interest earned outside Italy — regardless of the actual amount. Italian-sourced income, income from controlled foreign companies in certain low-tax jurisdictions, and specific capital gains from qualifying foreign participations remain separately taxable under Italian law.

Income covered by the EUR 300,000 lump sum (Art 24-bis):

• Foreign dividend income from non-Italian companies
• Foreign interest income from non-Italian financial instruments
• Foreign rental income from properties outside Italy
• Foreign capital gains (subject to specific exclusions — see below)
• Foreign business income (for entrepreneurs retaining ownership of non-Italian companies)
• Foreign employment income (where applicable)

Income NOT covered (remains taxable at standard Italian rates):

• Italian-sourced income of any kind — taxed at IRPEF progressive rates of 23%–43%
• Controlled Foreign Company (CFC) income from subsidiaries in low-tax jurisdictions — subject to Italy's separate CFC rules
• Capital gains from qualifying participations in foreign companies (broadly, stakes above 20%) — these may fall outside the substitute tax scope in certain circumstances and require specific legal analysis

Practical implication: The regime is most advantageous for individuals whose income is predominantly foreign-sourced. An HNWI deriving most of their income from Italian real estate, an Italian business, or Italian employment will find Art 24-bis of limited or no benefit. The programme is specifically designed for individuals who have transferred their Italian residence while retaining substantial international income streams.

Mirabello Consultancy performs a detailed income-source analysis for each client before recommending the Art 24-bis election. Schedule a free programme assessment to understand your specific income exposure and whether the EUR 300,000 lump sum is economic for your situation.

For a detailed breakdown of the full Italian tax stack — including Art 24-bis, the Art 24-ter 7% pensioner regime, and the inbound worker incentives — see our complementary guide: Italy Tax Stack 2026: Art 24-bis, Art 24-ter, and Inbound Worker Incentives Explained.

How Long Does Italy's Art 24-bis Flat Tax Regime Last?

Italy's Art 24-bis flat tax regime lasts for a maximum of 15 consecutive tax years from the year of first election. An individual may withdraw voluntarily at any point, but re-election is permanently prohibited once withdrawn. The regime ends automatically at the expiry of the 15-year period, after which the individual becomes a standard Italian tax resident subject to progressive IRPEF rates on worldwide income.

Key tenure considerations:

• Start date: the regime begins in the first Italian tax year in which the individual transfers their residence to Italy and makes the election (typically by filing the annual Modello REDDITI PF tax return)
• Voluntary withdrawal: permitted at any time; the withdrawal takes effect from the following tax year. Once withdrawn, re-election under Art 24-bis is permanently prohibited
• Automatic revocation: the Italian Revenue Agency may revoke the regime — with retroactive effect for the relevant year — if the EUR 300,000 payment is not made in full and on time, or if the individual ceases genuine Italian tax residence
• CFC revocation risk: income from certain CFCs in low-tax jurisdictions can also trigger a revocation review

Post-15-year planning: HNWIs need an exit strategy well before the 15-year window closes. Options include:

• Transitioning to standard Italian residence (with full IRPEF exposure on worldwide income)
• Relocating to another jurisdiction before or at the end of the 15-year period
• Applying for Italian citizenship (after 10 years of legal residence) — at which point the individual becomes an EU citizen and can live across the Schengen area

The Italy flat tax residency programme page covers the broader residency and citizenship context for individuals planning a long-term Italian base.

Can Family Members Join Italy's Flat Tax Scheme?

Yes. Family members who transfer their tax residence to Italy alongside the primary applicant can join Italy's Art 24-bis scheme at an additional EUR 25,000 per family member per year. Each qualifying family member must make their own election and meet the same 9-of-10-year Italian non-residency test independently.

Qualifying family members under Art 24-bis include:

• Spouses or civil partners
• Children (including adult children who meet the eligibility criteria)
• Other family members who can establish the required non-residency history

Family cost modelling: The EUR 25,000 per-family-member charge was not increased by the 2026 budget law and remains at EUR 25,000. A family of four qualifying members would pay:

Family member participation is not mandatory. Where a family member's foreign income is modest, the EUR 25,000 flat charge may not be economic, and they may be better served by an alternative Italian residency status. Mirabello Consultancy models the optimal structure for each family unit.

What Is the 7% Art 24-ter Flat Tax for Foreign Pensioners?

Italy's Art 24-ter provides a 7% flat tax on all foreign-sourced income for individuals receiving a qualifying foreign pension who relocate to a qualifying Italian municipality. The regime lasts for up to 10 years and was significantly expanded by Law 34/2026 to include Italian towns with populations of up to 30,000 — adding 74 new eligible municipalities and extending this route to a much wider pool of locations across Italy's regions.

The comparison between Art 24-bis and Art 24-ter is instructive:

Law 34/2026 expansion in detail: The prior Art 24-ter threshold was a municipality population of up to 20,000 residents. Law 34/2026 raised this to 30,000, immediately adding 74 municipalities across Italy — including attractive towns in the Abruzzo, Marche, Basilicata, Sicilian interior, and Sardinian regions that had been excluded under the prior threshold. The expansion reflects Italy's strategic use of its tax incentive framework to revitalise smaller towns that have historically struggled to attract international residents.

Which regime is right? For a retiree receiving EUR 150,000 per year in foreign pension income, Art 24-ter costs EUR 10,500 (7% of EUR 150,000) — dramatically less than EUR 300,000 under Art 24-bis. For an HNWI with EUR 5,000,000 in annual foreign investment income, Art 24-ter would cost EUR 350,000, making Art 24-bis (at EUR 300,000) more efficient. The crossover point is approximately EUR 4.3M in annual foreign income.

How Does Italy's Flat Tax Compare with Greece, Malta, and the UAE for HNWI Relocation in 2026?

Italy's EUR 300,000 flat tax provides maximum certainty for very high-income HNWIs — the effective rate per euro earned falls progressively as foreign income rises. For EU access and citizenship speed, Greece's Golden Visa leads with a 7-year EU citizenship path. Malta's MPRP delivers the most favourable non-dom tax rates with EU passporting. The UAE offers zero income tax with no residency minimum stay, but without an EU or Schengen benefit.

The right choice depends entirely on the HNWI's income profile, existing residency, citizenship objectives, and lifestyle preferences. Italy is the strongest choice for individuals with foreign income above EUR 4.3M who want Italian/EU citizenship and a high-quality Mediterranean lifestyle. Greece leads on investment efficiency and citizenship speed. Malta wins on percentage-based non-dom tax economics for moderate foreign income levels. The UAE wins on absolute tax cost and lifestyle for those without EU access requirements.

Mirabello Consultancy's model is to advise neutrally across all programmes rather than push a single solution. Our Swiss-based advisors construct multi-jurisdiction residency strategies tailored to each client's specific financial profile and long-term objectives. Explore the full landscape of Europe's best Golden Visa and residency programmes or speak to an advisor directly.

What Are the Practical Steps to Enrol in Italy's Art 24-bis Flat Tax?

To enrol in Italy's Art 24-bis flat tax, an individual must first establish genuine Italian tax residence — typically by obtaining an Italian long-stay visa and residence permit, registering with the local municipality, and then making the formal election in their first Italian annual tax return. From January 2026, biometric data collection is mandatory at the residence permit stage for non-EU nationals.

Step-by-step process:

Step 1 — Obtain an Italian long-stay visa:
Non-EU nationals must obtain a Type D (long-stay) Italian visa. HNWIs typically use the Italy Investor Visa (Visto Investitore) at the relevant investment threshold. EU nationals have right of entry but must still register their residence.

Step 2 — Apply for the permesso di soggiorno:
Apply for the Italian electronic residence permit (permesso di soggiorno elettronico) at the local Questura (immigration authority). From January 2026, biometric data — fingerprints and photographs — is mandatory for all non-EU applicants at this stage. Processing typically takes 2–4 months.

Step 3 — Register with the anagrafe:
Register as a resident at the local municipalità (municipality office). This formally establishes Italian domicile and triggers Italian tax residence from the registration date.

Step 4 — File the annual tax return with the Art 24-bis election:
In the first Italian tax year of residence, file the Modello REDDITI PF annual income tax return. The Art 24-bis election is made in Box RN54. The EUR 300,000 substitute tax is due by the standard Italian payment deadline (typically 30 November of the relevant year, with a first instalment option by June).

Step 5 — Maintain annual compliance:
Pay the EUR 300,000 (plus EUR 25,000 per qualifying family member) in full and on time, annually. Late or partial payment results in forfeiture of the regime for that year, potentially triggering full IRPEF exposure on worldwide income for the affected period.

Optional — Advance ruling (interpello):
Applicants may seek an advance ruling from the Italian Revenue Agency (Agenzia delle Entrate, interpello art. 11 Statuto del Contribuente) confirming eligibility before relocating. This provides legal certainty but is not mandatory. Mirabello Consultancy coordinates the advance ruling process and Italian tax filing for clients who require confirmed eligibility before committing to the move.

Frequently Asked Questions About Italy's Flat Tax 2026?

Is Italy's flat tax EUR 100,000, EUR 200,000, or EUR 300,000 in 2026?

The correct figure for all new Art 24-bis elections from 1 January 2026 is EUR 300,000 per year. The original EUR 100,000 rate applied from 2017 to 2024. The EUR 200,000 rate applied during 2025 (following the Italian Budget Law 2024). Individuals who enrolled before 31 December 2025 may remain on their prior rate for the remainder of their 15-year period — the increase applies to new elections only.

Can I combine Italy's Art 24-bis flat tax with the Italy Investor Visa?

Yes. Many HNWI clients enter Italy via the Italy Investor Visa (starting at EUR 250,000 for qualifying start-up investments) as their legal route to Italian residence, then make the Art 24-bis election in their first Italian tax year. The Investor Visa and the flat tax election are complementary but entirely separate processes with separate applications and legal bases. The Investor Visa provides the residency right; Art 24-bis provides the tax regime.

Is the Italy flat tax available to UK nationals after Brexit?

Yes. Art 24-bis imposes no nationality restriction whatsoever. UK nationals who transfer their tax residence to Italy and meet the non-residency test — not having been Italian tax resident for at least 9 of the previous 10 years — are fully eligible. Post-Brexit, UK nationals require a standard non-EU Type D long-stay visa (e.g., the Investor Visa) rather than the former EU freedom-of-movement right to establish Italian residence.

What happens to my tax position when the 15-year regime expires?

At the expiry of the 15-year Art 24-bis period, the individual transitions automatically to standard Italian tax residence, subject to IRPEF progressive rates (23%–43%) on worldwide income. Forward planning is therefore essential. Options include relocating to another jurisdiction, transitioning to Italian citizenship (possible after 10 years of residence, prior to the 15-year Art 24-bis expiry), or restructuring income streams to reduce Italian IRPEF exposure. Mirabello Consultancy advises clients on exit strategies at the 10-year mark.

How do I know whether the EUR 300,000 flat tax is economical for my income level?

The break-even point is roughly EUR 750,000 in annual foreign income (at which the 40% effective IRPEF rate would roughly equal EUR 300,000). Above that level, Art 24-bis becomes increasingly cost-efficient as income grows. Below that level, Art 24-ter (7% for pensioners, if eligible), Malta's non-dom SDC, or the UAE may offer better economics. Mirabello Consultancy performs this modelling as part of a free initial consultation.

How Do I Start with Mirabello Consultancy?

Mirabello Consultancy is an IMC-member, ACAMS-certified Swiss investment migration advisory with a 99% approval rate across 250+ CBI and 350+ Golden Visa cases. To explore whether Italy's Art 24-bis flat tax is right for your profile, book a free consultation through our online form. Our advisors will assess your income structure, existing residency, and long-term objectives — and compare Italy with Greece, Malta, UAE, and Caribbean CBI to identify the optimal programme for your specific situation.