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  • Studio Paci

🌍 Italian Expatriate Regime in 2024: An In-depth Overview


The year 2024 marks a new era in the Italian tax landscape, thanks to the introduction of Legislative Decree No. 209/2023.

This legislative document has been crafted to revitalize the expatriate regime, a strategic move aimed at encouraging the return of brains and attracting international talents to Italy.

The law emphasizes the importance of precisely distinguishing between registry residence and tax residence, two fundamental concepts that directly influence access to tax benefits.

In an era of global mobility, Italy positions itself as an attractive hub for highly qualified professionals, offering favorable conditions both in terms of quality of life and professional opportunities.

🔍 Registry Residence Versus Tax Residence: A Crucial Distinction

Registry residence refers to the place where an individual has established their family and social life, a concept rooted in Italian legislation and reaffirmed by Article 43 of the Italian Civil Code.

Conversely, tax residence determines a person's tax obligations towards the Italian State, based on actual presence in the country for more than 183 days a year, domicile, or enrollment in a registry.

This distinction is vital, as it directly impacts eligibility for the expatriate regime, emphasizing Italy's intention to attract individuals deeply integrated into the national social and economic fabric.

💼 Eligibility Criteria and Requirements for the Expatriate Regime

To access the favorable tax regime, it is imperative not to have had tax residence in Italy in the three fiscal years prior to the transfer.

Prospective beneficiaries must also demonstrate that they perform or intend to perform work activities in Italy, meeting criteria of high qualification or specialization.

These parameters, detailed in Legislative Decree No. 108/2012 and Legislative Decree No. 206/2007, are designed to attract individuals with critical skills for innovation and the economic development of the country.

Opening the regime to those previously employed abroad by the same employer or corporate group underscores an inclusive and flexible vision, aimed at facilitating the transnational mobility of talents.

📈 Advantages and Implications of the New Regime

Subjects within the regime will enjoy a reduced taxation at 50%, a percentage that can increase to 60% in the presence of minor children or in the case of birth or adoption of a child during the application period of the regime, provided that the minor resides in Italy.

This incentive tax structure is further enriched by the possibility of extending the benefit for an additional three years through the purchase of a residential property in Italy within specific timeframes.

This option reflects the legislator's intention to encourage long-term investment in the country, while also promoting the development of the Italian real estate market.

The income threshold set at 600,000 euros per year underscores the regime's orientation towards high-income profiles, with the goal of stimulating an economy based on knowledge and skill quality.


🔍 What is the essence of the new expatriate regime introduced by Legislative Decree No. 209/2023 in Italy?

The 2024 expatriate regime, introduced through Legislative Decree No. 209/2023, represents an innovative Italian fiscal policy aimed at stimulating the return of brains and attracting international talents.

The main focus is to offer significant tax benefits to qualified professionals who decide to transfer their tax residence to Italy, highlighting an interesting distinction between tax and registry residence.

This approach is part of a broader effort to make Italy an attractive hub in the context of global mobility, encouraging investment and economic development through the inclusion of global skills.

💼 Who can benefit from the expatriate regime and what are the necessary requirements?

To access the expatriate tax regime, candidates must meet specific eligibility criteria: not having had tax residence in Italy in the three fiscal years prior to the transfer and demonstrating the intention to perform work activities in the country, favoring individuals with high qualifications or specializations.

This regime also opens up to those who, while having worked abroad, were employed by the same employer or within the same corporate group, showing a clear openness towards the international mobility of talents and their integration into the Italian productive fabric.

📈 What advantages does the expatriate regime offer and how can it influence investment in the Italian real estate market?

The regime envisages a reduced taxation at 50% of income, which can rise to 60% in the presence of minor children, with the further incentive of being able to extend this benefit for an additional three years through the purchase of a residential property in Italy.

This opportunity not only underscores the intent to encourage long-term investment in the country but also acts as a catalyst for the revitalization of the Italian real estate market, making it even more attractive for international professionals and investors looking to combine tax advantages with a high standard of living.


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