Part II · Jurisdictions · No. 15

Italy

A high-tax jurisdiction with a competing new-resident flat-tax regime under Article 24-bis TUIR. The substitute tax was doubled to €200,000 per year for new electors in 2024, repositioning the regime mid-market. Italy combines significant Mediterranean luxury infrastructure with one of Europe's older inheritance-tax regimes.

Why this jurisdiction matters

Italy's 2017-introduced Article 24-bis TUIR regime provides a substitute tax on all foreign income (and gains) at a flat annual amount for qualifying new Italian residents who have not been Italian-resident in nine of the prior ten years. The regime — designed to compete with the UK non-dom system — operated at €100,000 per year for new electors through 2024. The Italian Budget Law 2024 doubled the substitute tax to €200,000 for new electors from August 2024, with existing electors grandfathered at €100,000.

The relevant tax regime

• Income tax (IRPEF). Progressive to 43% top marginal; regional and municipal surcharges add up to approximately 4%.
• Article 24-bis flat tax. €200,000 (new electors from 2024) / €100,000 (legacy electors) annual substitute for tax on foreign income and gains, available for up to 15 years.
• IVAFE. 0.2% on foreign financial assets; 0.76% on foreign real estate.
• Succession tax. Among Europe's lowest: 4% on transfers to spouses and direct descendants (above €1 million per beneficiary); 6% to siblings (above €100,000); 8% to others.
• IMU. Municipal property tax on second homes.
• VAT. 22% standard; 10% reduced for certain art imports.
• Superbollo. Luxury-vehicle surcharge on engine power above 185 kW.

Registration or residency mechanics

Italian tax residency under TUIR Article 2 — registration in resident population register, principal residence, or center of vital interests for at least 183 days. Article 24-bis election filed annually with the tax return; family members may extend at €25,000 each.

Reporting and disclosure

CRS participant. FATCA Model 1 IGA. Foreign-asset reporting on RW form (Quadro RW); IVAFE assessed on RW data. Beneficial-ownership register through Camera di Commercio.

The substance question

Article 24-bis residency requires substantive Italian residency — physical presence and registration. The regime is for residents, not for paper-only structures. Tax-treaty residence and CRS reporting follow standard rules.

Recent changes

2024 budget law doubled the 24-bis substitute tax to €200,000 for new electors. The change repositioned the Italian regime above the prior €100,000 (which had matched the post-2017 UK non-dom anticipated cost). Italian art-and-cultural-property export rules continue to restrict cross-border movement of cultural property.

Common asset classes parked here

• Italian real estate — particularly Tuscany, Lake Como, Capri.
• Exotic cars — Italian manufacturers; superbollo applies.
• Yachts — Mediterranean yacht charter market; Italian VAT mechanics on charter.
• Italian art — cultural-property export restrictions.
• 24-bis-elector residency for international HNW migration.

Reviewed May 2026