Italy · Tax regime
Impatriate Workers Regime (Lavoratori Impatriati)
Cut back sharply by Legislative Decree No. 209/2023 for transfers from 2024 onward: the old 70–90% exemption with a possible 10-year run was replaced by a 50% exemption on income up to EUR 600,000, for 5 years. Unchanged through 2025 and 2026.
Mostly irrelevant to a UHNW principal — it relieves Italian earned income, not foreign investment income, so it does nothing for a portfolio. Its real use in a family plan is for the next generation: an adult child taking an Italian executive role can stack the impatriate relief on their salary while the principal sits under Article 24-bis. Note the two regimes are mutually exclusive for the same person.
Qualifying routes
50% of qualifying Italian-source employment or self-employment income up to EUR 600,000 excluded from the tax base
exemption rises to 60% where the worker relocates with a minor child, or has/adopts a child during the benefit period
The facts
- Qualifying figure
- €600k
- Total landed cost
- No cost — a relief, not a charge. Worth up to roughly EUR 140k per year in tax saved at the top rate on EUR 600k of income.
- Physical presence
- Italian tax residence required, and the work must be performed mainly in Italy
- Family
- applies to the individual worker; the enhanced 60% rate depends on the worker's own minor child
- Permanent residency
- n/a — a tax relief
- Citizenship
- n/a
- Language test
- n/a
- Dual citizenship
- Permitted
- Requirements
- transfer of tax residence to Italynot tax resident in Italy for the 3 preceding tax periods (6 if previously employed in Italy by the same employer or group)commitment to remain Italian tax resident for at least 4 yearswork performed mainly within Italyhigh qualification or specialisation requirements apply
- Only Italian-source employment and self-employment income qualifies. Foreign investment income, dividends and gains get nothing.
- The EUR 600,000 cap means income above it is fully taxed at ~47.2%.
- A binding four-year Italian tax residence commitment attaches: leave early and the relief is clawed back with interest.
- Three years of prior non-residence is the baseline, but six years if you previously worked in Italy for the same employer or group — a rule that catches returning secondees.
- 5 years only, with no extension mechanism — the old 5+5 with property purchase or children is gone for post-2024 arrivals.
- Cannot be combined with Article 24-bis for the same individual.