Flat tax for High-Net-Worth Individuals

Income tax benefits

High-net-worth individuals (HNWIs) moving their residence to Italy are enabled to apply a flat tax to their foreign income, amounting to € 100,000 for each fiscal year, in lieu of the Italian Income Tax.
For example, under this tax regime, the flat tax could substitute the ordinary income tax on foreign investments (foreign interests, dividends, capital gains) with the exception of capital gains on qualified participation earned in the first five years of application of the tax regime.
Consequently, individuals opting for the flat tax will be taxed in Italy only:

• on their Italian income (if any);
• on qualified capital gains if realised within 5 years.

Individuals who opt for the flat tax regime are considered to be resident in Italy also for double tax treaty purposes, unless the relevant treaty provides otherwise and the CFC rules do not apply to payers of the flat tax.

Further benefits

No inheritance and gift tax are due on foreign assets, therefore individuals opting for the flat tax could pass on foreign assets free of tax.
In addition, HNWIs moving their tax residence to Italy:

• have not to pay Italian wealth tax (IVIE and IVAFE) on their real estate and financial investments owned out of Italy;
• are not required to declare their foreign investments in the Italian tax return (with the exception of qualified participations in the first five tax periods of application of the tax regime).

The election for the regime may be extended to family members of the HNWIs through the payment on their foreign income of a flat tax amounting to € 25,000 per member.

Conditions

The HNWIs regime is available for individuals who:

• actually move their tax residence in Italy;
• have been non-tax resident in Italy for at least 9 out of 10 years preceding their transfer to Italy.

Family members of HNWIs who want to apply for the tax regime must meet the same conditions.
Taxpayers may access to the regime submitting an advance tax ruling to the Italian Revenue Agency.

Duration

The option for this tax regime is valid for a period of 15 years.