Introduction

The expatriates regime is an Italian tax law that offers benefits to workers transferring their residency to Italy.

It was introduced with Article 16 of Legislative Decree No. 147 of 2015, also known as the "Internationalization Decree."

The primary goal of this regime was to encourage the return of taxpayers who, having previously resided abroad, developed professional qualifications outside the national borders.

The law provides for the exclusion from the taxable base of a portion of income produced in Italy for such taxpayers.

With the 2023 budget law, this regime has been further confirmed, ensuring the continuity of tax benefits for expatriate workers, as well as teachers and professors.

The measure aims to facilitate the return to Italy of both Italian citizens residing abroad and foreign nationals intending to move to Italy for work.

The regime offers a particularly advantageous tax relief, falling within the strategy of attracting skills and talents to Italy.

It should be noted that, over the years, the expatriate regime has undergone some evolutions.

For example, Article 5 of the Legislative Decree on International Tax Reform introduced changes that replaced some of the original provisions contained in Article 16 of Legislative Decree No. 147 of 2015. These changes aimed to make the regime even more suitable for the needs of the labor market and international taxation.

The expatriate regime in Italy offers significant benefits to workers deciding to transfer their residency to Italy.

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For a more in-depth understanding, let's see the main access requirements and benefits associated with this regime.

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Access Requirements

1. Previous Fiscal Residency: To be eligible, workers must not have been fiscal residents in Italy for the two tax periods preceding the repatriation. This criterion is fundamental in determining whether a worker is truly an "expatriate" under this law.

2. Residency Commitment: The worker must commit to being fiscally resident in Italy for at least two years. This requirement ensures a certain level of commitment and stability in staying in Italy.

3. Work Activity in Italy: The worker must carry out their work activity predominantly in Italian territory. This requirement aligns with the goal of encouraging professional contributions in the country.

 

Benefits of the Regime

1. Reduced Taxation: Expatriate workers can benefit from reduced taxation on incomes produced in Italy. This includes income from employment, self-employment, and business, with some specifications.

2. Recent Changes: With the tax reform, the tax exemption for expatriate workers has been modified. Previously, the exemption reached up to 70%, while now it has been set at 50% for a duration of 5 years. This change represents a return to pre-2019 conditions. Additionally, a 600,000 euro income limit for the application of benefits has been introduced.

3. Updated Requirements: The new requirements include an extended period of residence abroad of three years (instead of two), the need to stay in Italy for five years, the requirement of a high qualification or specialization, and the establishment of a new work relationship with a different entity than before.

 

 

New Developments for 2023 and 2024

2023: Transition to the New Regime

In 2023, a transitional period is observed, during which fiscal residency gives way to civil residency to access the benefits. This represents a phase of transition between the current regime and the changes foreseen by the tax reform.

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2024: Significant Changes

From 2024, the special regime for expatriate workers will be replaced by a new system. This will include a 50% tax relief on income up to a limit of 600,000 euros, with high qualification requirements for workers.

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International Comparison and Socio-Economic Impact

The Italian expatriate regime compares with similar policies in countries like Portugal and Spain, offering competitive conditions to attract talents and international investments. The goal is to stimulate economic growth and innovation in key sectors.

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Conclusions

The expatriate regime in Italy represents a significant opportunity to attract international talents and skills, contributing to the evolution of the Italian economy and labor market. With the changes foreseen for 2024, it is essential for sector professionals and potential beneficiaries to stay informed and prepared for the new provisions.

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For expert assistance regarding the Expatriates Regime, Studio Paci is fully at your service.

Our Firm, featuring a team of skilled Chartered Accountants, situated in the center of Milan, guarantees a personalized approach; please do not hesitate to contact us.