The inpatriate regime is a temporary tax scheme that provides preferential treatment to workers who move their residence to Italy (introduced by Article 16, paragraph 1, Legislative Decree No. 147/2015).
From 2024 the new provisions of the Legislative Decree no. 209/2023 will take effect. To be eligible for the scheme, the worker must not have been a resident in Italy during the three tax periods prior to the transfer and must commit to residing in Italy for at least four years. Additionally, the work activity must be primarily carried out within Italian territory and the taxpayer must be highly qualified.
For taxpayers who meet these conditions, the Legislative Decree confirms the 50% tax exemption within the annual income limit of 600.000 euros, with a commitment to reside in Italy for at least 4 years.
An increase of the tax exemption to 60% has been introduced if the worker moves to Italy with a minor child or in the case of birth/adoption during the period in Italy, from the tax period in progress at the time of the birth or adoption and for the remaining time the benefit is available.
In addition, the inpatriate scheme (50 percent) will be extended for further 3 tax years for those who are going to register their residence with the Anagrafe in 2024 but have purchased a property in Italy used as their main abode by December 31, 2023 (and in any case within the 12 months preceding the transfer).
To take advantage of the facility, employees must submit a written request to their employer. Italian citizens who are not registered in the Register of Italians Resident Abroad (AIRE) are also eligible for the regime, provided that they have resided in another state under a convention against double taxation on income in the three tax periods prior to the transfer.
Workers who move to Italy to work for the same employer (including returns from a secondment position) or for an entity belonging to the same group, will then be eligible for the tax benefit; however, for them there is an increase in the minimum period of residence abroad requirement: six or seven tax years, depending if the worker has (or not) previously been employed in Italy in favor of the same entity or an entity belonging to
A transitional regime remains for those who have registered their residence in Italy with the Anagrafe by Dec. 31, 2023, who will be eligible for the old regime conditions.