Headline benefit
€300k/yr substitute tax on foreign income (2026+)
Italy’s HNWI new-resident regime replaces progressive IRPEF on foreign-source income with a fixed annual substitute tax. Budget Law 2026 raised the principal fee to €300,000 for transfers from 1 January 2026 (€50,000 per extended family member). Italian-source income stays on ordinary rules. Maximum term: 15 years.
By Sammy S. · Founder · AuthorUpdated for 2026
Italy
Country
Up to 15 years
Duration
30%
Effective rate on foreign income
IT
Calculator
Key finding
Italy’s 2026 new-resident flat tax (Art. 24-bis) charges a fixed €300,000 annual substitute tax on foreign-source income for transfers from 1 January 2026 (prior transfers often keep €200,000; family extensions €50,000 each for 2026+). On €1,000,000 of foreign income that is a 30% effective rate; on €3,000,000 it is 10%. Italian-source employment remains on ordinary IRPEF.
Updated 2026-08-06 · Tax year framing 2026
Italy’s HNWI new-resident regime replaces progressive IRPEF on foreign-source income with a fixed annual substitute tax. Budget Law 2026 raised the principal fee to €300,000 for transfers from 1 January 2026 (€50,000 per extended family member). Italian-source income stays on ordinary rules. Maximum term: 15 years.
Official name: Imposta sostitutiva per nuovi residenti (Art. 24-bis TUIR)
Legal basis: Art. 24-bis TUIR · Legge di Bilancio 2026 · Agenzia delle Entrate scheda neo-residenti
Headline benefit
€300k/yr substitute tax on foreign income (2026+)
Duration
Up to 15 years
Country
Italy
Art. 24-bis lets new Italian tax residents pay a fixed substitute tax instead of progressive IRPEF on foreign-source income. The fee is due each year the option applies, regardless of how large (or small) foreign income is.
Italian-source wages, Italian business profits, and Italian real estate remain on ordinary IRPEF / local surtaxes. The regime is aimed at people whose foreign income would otherwise dominate a worldwide IRPEF bill.
High-net-worth individuals with large foreign passive or business income who can comfortably pay the fixed fee. At €300,000/year, the break-even foreign income is high — below that, ordinary taxation (or another country’s regime) may be cheaper. Run the maths before relocating.
Beckham Law and IFICI reshape tax on local employment income. The Dutch 30% ruling shrinks the Dutch wage-tax base. Italy’s Art. 24-bis is a fixed euro fee on foreign income — it does not flatten Italian salary tax.
At €300,000/year, the effective rate on foreign income equals fee ÷ foreign income. Examples: €500,000 foreign → 60%; €1,000,000 → 30%; €2,000,000 → 15%; €3,000,000 → 10%. If your expected foreign income is modest, ordinary IRPEF (or another country’s regime) can be cheaper.
Remember: Italian-source salary is still taxed normally on top of the fee.
Myth: “Italy has a 24% salary flat tax like Beckham.” Fact: Art. 24-bis is a fixed euro substitute tax on foreign income only.
Myth: “Family members are still €25,000 each after 2026.” Fact: Agenzia delle Entrate states €50,000 each for transfers from 1 January 2026.
High-net-worth individual who becomes an Italian tax resident on or after 1 January 2026 and elects Art. 24-bis TUIR substitute tax on foreign-source income. Italian-source employment and Italian situs assets stay on ordinary IRPEF / local rules.
Foreign-source income
€1,000,000
Ordinary worldwide IRPEF
Progressive (often punitive on large foreign income)
Substitute flat tax (2026+)
€300,000
Effective rate on foreign income
30%
Budget Law 2026 raised the principal fee to €300,000 for transfers from 1 Jan 2026 (earlier transfers generally keep €200,000). Family-member extensions are €50,000 each for 2026+ transfers (€25,000 under prior rules). Not the forfettario freelancer scheme.
Effective rate at the 2026+ €300,000 fee
| Foreign income | Fee | Effective rate |
|---|---|---|
| €500,000 | €300,000 | 60% |
| €1,000,000 | €300,000 | 30% |
| €2,000,000 | €300,000 | 15% |
| €3,000,000 | €300,000 | 10% |
24% flat on Spanish-source work (to €600k)
20% flat IRS on qualifying Portuguese income
Up to 30% of salary tax-free (2026)
Confirm current rules with the official tax authority before you move.