Here’s what it means, who is affected, and why speaking with a commercialista before you move—or renew—matters. Italy’s flagship incentive for high-net-worth movers—the flat, fixed levy on foreign-source income for new residents—may soon become more expensive. The latest draft of the Budget Law raises the main charge to €300,000 per year, with the supplemental amount for eligible family members rising to €50,000. The regime under art. 24-bis TUIR would remain optional and time-limited, but at a higher annual price point. While Parliament will still debate the measure, expats who are planning a relocation (or who already opted in at €200,000) should run the numbers now and plan their next steps with a professional adviser.
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Quick recap: how the regime works today
The “new residents” regime lets qualifying individuals who transfer tax residence to Italy pay a single, fixed levy on their foreign-source income instead of ordinary progressive tax. Domestic income remains taxed under standard rules, and the option lasts up to fifteen years as long as payments are made. Historically, the annual amount was €100,000, then €200,000; the draft law would lift it to €300,000 and increase the family add-on accordingly. The policy’s purpose is to attract internationally mobile individuals who hold significant assets or income streams abroad—entrepreneurs, executives, investors, and talent with global careers—by swapping complexity for certainty. If the price changes, the core concept does not; what changes is the cost-benefit line for who should use it.
Who should reassess their plan
1) Movers still abroad who were budgeting at €200,000. If you built a five-year plan using the current levy, update your model with €300,000 and check whether the regime still beats ordinary taxation on your foreign income. If your foreign-source income is very large, the higher levy may still be attractive; if it is “borderline,” a professional projection may point you to alternatives (see below).
2) Families relying on the add-on. The extra charge for eligible family members would double to €50,000 per person. For large families, the delta becomes material. Confirm who qualifies in your case and how many years you intend to stay; small duration changes can swing the decision.
3) Those already in the regime. If you opted in at the previous level, check transitional rules once the law is final: many budget measures include “from tax year X” language, but practical application (grandfathering, renewals, deadlines) is where a commercialista earns their keep. Keep payment receipts and option letters handy; you will need them to validate your status with the tax office or your bank.
Alternatives many expats overlook
Ordinary taxation + treaty planning. For people with modest or irregular foreign income, the fixed levy can over-insure. Depending on your portfolio and treaty positions, ordinary rules might produce a lower effective rate, especially if sizable income is Italian-source (which the flat levy does not cover anyway). This route requires careful reporting and documentation—an accountant can map your country-by-country flows and foreign tax credits.
Impatriates regime (for employment). If you are moving for a job, the “impatriati” regime provides partial relief on Italian employment income (subject to eligibility rules updated recently). It does not shelter worldwide investment income like the flat levy, but for salaried transferees with limited foreign passive income it can be the smarter fit.
Entrepreneurs/freelancers with Italian clients. If most revenue will be Italian-source, the new residents’ levy does not help with that portion. You may be better off on ordinary rules or, if eligible, in the simplified forfettario regime for small businesses. The right answer depends on your turnover, cost structure, and INPS position—areas where an early consultation avoids expensive mistakes.
Decision framework you can apply today
Step 1: Inventory your income mix. Separate Italian-source from foreign-source items, then split foreign by category: dividends, interest, gains, real estate, trusts, partnership flows. Estimate a “steady state” for the next three to five years rather than a single year spike.
Step 2: Model three scenarios. (A) New residents’ levy at €300,000 (+ €50,000 per family member); (B) ordinary rules with treaties and foreign tax credits; (C) employment-based impatriati or business regimes if applicable. Compare like-for-like (net of social contributions, municipal/regional add-ons, and wealth/monitoring duties like RW/IVIE/IVAFE that may not apply under the levy).
Step 3: Stress test the plan. Change residence city (municipal add-ons differ), add a sale of a large asset in year two, or reduce passive income by 30%. If small changes flip your decision, you need a more robust plan.
Step 4: Lock timelines. If you intend to move, align visa, residence, housing, bank onboarding, and tax elections so the chosen regime is available when you file. Missing a cut-off by a month can cost more than a year of fees.
Banking, compliance, and wealth structuring
Private banks and compliance teams often ask for clarity on the tax regime you use, especially when onboarding cross-border clients. Keep your option letter (if any), proof of timely payments, and a one-page memo that describes how the regime interacts with your foreign assets (for example, whether you still file foreign disclosures). If you are not using the flat levy, maintain a clean archive of statements and cost bases; you will need them for annual returns and any future disposition. Where trusts, family holding companies, or carried interest are involved, bring structure diagrams to your adviser—Italy has specific rules on look-through and financial income that can surprise newcomers.
Where a commercialista adds concrete value
Optimising the choice, not just filing forms. A commercialista in Italy can map your actual cash cost under each regime and flag hidden interactions (municipal add-ons, social contributions, monitoring obligations, treaty relief). They can also coordinate with your foreign adviser when assets or entities sit outside Italy. If you are unsure whether you need one, read our short explainer on whether you need a commercialista in Italy. For selection criteria and fee models, see our guide on how to choose an accountant in Italy so you walk into the first meeting prepared.
Practical next steps
1) Confirm the latest text. Policy can shift during the budget process. Track the final language before year-end and note the first tax year it applies to.
2) Build a three-year projection. Model levy vs ordinary rules vs employment/business regimes, including add-ons and contributions. Sensible assumptions beat wishful thinking.
3) Align immigration and tax timing. Digital nomad or elective residence permits do not by themselves “pick” your tax regime; residence days and your centre of vital interests do. Plan the calendar with both immigration counsel and your accountant.
4) Prepare documents for a first consult. Bring asset lists, income estimates by source, prior-year returns (if any), family details, and intended city of residence. A one-hour session goes much further with tidy inputs.
5) Decide on a review cadence. Re-check the plan after big life events (sale, bonus, relocation, family changes) or when a law changes mid-stay.
Bottom line: the proposed €300,000 levy does not kill Italy’s appeal for globally mobile professionals, but it does narrow the group for whom the “pay-and-forget” option is the right tool. With clear numbers and early planning, you can still optimise for certainty and cost—just make sure you are comparing the right scenarios with a professional by your side.
