New residents, the substitute tax on foreign income arrives. Revenue rules are ready for those who decide to transfer their residence to Italy.

The registrations of the Revenue Agency arrive for foreigners who intend to transfer their tax residence to Italy by benefiting from a substitute tax on income produced abroad. The option, introduced with the 2017 Budget Law, provides for the payment of a lump sum tax of 100 thousand euros for each tax period for which it is exercised, in order to attract and encourage the transfer of residence in our country of the High net worth individual, i.e. people with high wealth. With today's provision of the director of the Revenue Agency, the check list model was also approved to be attached to the request for ruling which allows a preventive assessment by the Financial Administration on admissibility to the preferential regime.

How to exercise the option - Taxpayers in possession of the requirements can join the new regime at the time of submitting the tax return, referring to the tax period in which the tax residence was transferred to Italy or in the immediately following one. it is also possible to submit a specific preventive request for a ruling to the Central Assessment Department of the Revenue Agency. The request can be delivered by hand, by registered letter with acknowledgment of receipt or electronically, using certified e-mail.


personal data and, if already assigned, the tax code, in addition to the relative address of residence in Italy, if already resident;
the status of non-resident in Italy for at least nine tax periods during the ten preceding the start of validity of the option;
the jurisdiction or jurisdictions in which he had his last tax residence prior to the exercise of the validity of the option;
the foreign states or territories for which it intends to exercise the right not to avail itself of the application of the substitute tax.
The taxpayer must also indicate the existence of the elements necessary for access to the scheme, filling out a check list attached to today's provision and presenting, if necessary, the related supporting documentation.
Option also extended to family members - The flat-rate scheme can also be extended to one or more family members who transfer their tax residence to Italy or to the next one. In this case, the substitute tax is equal to 25 thousand euros for each of the family members to whom the effects of the same option are extended.

When to submit the request - The option must be exercised within the terms for submitting tax returns, even if the response from the Revenue Agency has not yet received the request for ruling. The application can be submitted even if the terms for establishing the tax residence in Italy have not yet passed. The option is considered tacitly renewed from year to year, while the effects cease, in any case, after fifteen years from the first tax period of validity.

The only solution to pay the tax - the payment of the substitute tax, in the amount of 100 thousand euros, must be made in a single solution, for each tax period of effectiveness of the scheme, by the date scheduled for the payment of the balance of the income tax.


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