Regime Res Non Dom in Italy: Lump-Sum Flat Tax for New Residents and 2025 Benefits

The preferential tax regime for non-domiciled residents in Italy, known as the “Regime Res Non Dom”, is one of the most innovative and advantageous solutions for individuals wishing to transfer their tax residence to Italy and make it the strategic centre for their investments.

As of 2024, the new residents’ regime has been updated: the new lump-sum flat tax of € 200.000 per year allows individuals with significant assets (HNWIs, High Net Worth Individuals) to benefit from a fixed tax on their foreign-source income, regardless of the amount.        
In addition to the main taxpayer, eligible family members may also benefit from the regime, subject to a reduced substitute tax.

​

The new residents’ regime is available to:           

• Individuals who have spent at least 9 of the last 10 years abroad and who transfer their tax residence to Italy;

• Both returning Italian nationals and foreign nationals, provided that they have not been fiscally domiciled in Italy;             

• Individuals who submit the relevant option within their first Italian income tax return following the transfer of tax residence.

• ​

The main advantages of the flat tax regime for new residents are:

• Application of a € 200.000 annual flat tax on foreign-source income, irrespective of the total amount; 

• Exemption from foreign asset reporting obligations (RW form) and from wealth taxes on foreign financial and real estate assets (IVAFE, Tax on the Value of Financial Assets held Abroad and IVIE, Tax on the Value of Real Estate Properties located Abroad);           

• No inheritance or gift tax on assets held abroad;

• A maximum duration of 15 years, non-renewable;   

• Access to an advance ruling (interpello) procedure before the Italian Revenue Agency (Agenzia delle Entrate) to confirm and strengthen one’s tax position.

 

What’s New from 2026

From 1 January 2026, for new transfers of tax residence to Italy, the Italian neo-resident regime (res non dom) provides for an increase in the flat tax to € 300.000 per year on foreign-source income.

The same 2026 reform also updates the extension to family members: for each family member, the substitute tax is set at € 50.000 per year (upon joining the principal taxpayer’s regime).

​

The Italian regime is currently among the most competitive in Europe for international wealth and estate planning, thanks to recent legislative changes and the abolition of res non dom regimes in other countries. This makes Milan and the Lombardy region a major hub of attraction for entrepreneurs, executives and investors choosing to transfer their tax residence to Italy.

 

Studio Paci, a Firm of Chartered Accountants and Tax Advisors based in Milan, Italy works alongside specialised partners with specific expertise in the Res Non Dom Regime, ensuring the highest level of advisory services for both Italian and foreign clients: from verifying eligibility requirements to accessing available tax benefits, from designing the overall tax strategy to managing the related documentation, supported by extensive experience in the most complex and sophisticated cases.