The new impatriate regime: who qualifies, for how long and what you stand to lose

Giulia, a software engineer, has spent five years in Munich and now holds an offer from a Turin company paying €90,000 a year. Colleagues told her that, once back in Italy, half of that salary would escape income tax. They are only half right. The relief is real, but it hinges on four conditions, on how many years she spent abroad and even on who her new employer is.

Where the regime comes from and who it covers

The impatriate workers regime is a temporary relief. For a set number of years, part of the income a newcomer earns in Italy is simply left out of the base on which IRPEF, the Italian personal income tax, is worked out.

The version in force today sits in article 5 of Legislative Decree no. 209 of 27 December 2023. The Revenue Agency's information page calls it the new regime and applies it from the 2024 tax year onwards.

Paragraph 8 draws the line in time: the new rules apply to people who move their tax residence to Italy from the 2024 tax year.

Anyone who arrived earlier is not shut out of every relief; they stay under the previous scheme, covered further on. So the very first thing to pin down is the year you actually came back.

Paragraph 1 lists the eligible income precisely: employment income, income treated as employment income, and self-employed income from the exercise of arts and professions, provided it is produced in Italy.

The list is closed. Business income is missing from it, whereas the old scheme, as the Agency's archived page recalls, had been widened to people starting a business from 2020.

In practice the split is sharp. An employee hired by an Italian company, a director paid a fee treated as employment income, an architect or a consultant holding a professional VAT number can all qualify.

A shopkeeper opening a store or a craftsman with a workshop cannot, because they earn business income. If you are still deciding how to work after the move, weigh this before choosing the legal form of your activity.

The four entry conditions

Paragraph 1 grants the relief only when four conditions are met at the same time, and the Agency's page repeats them almost word for word. Missing a single one means ordinary taxation, with the whole income in the taxable base.

• Commitment to stay: the worker undertakes to keep Italian tax residence for at least four years
• Prior absence: no Italian tax residence in the three tax years before the move, with a longer requirement when working for the same employer or group
• Work mainly in Italy: the job is carried out on Italian territory for most of the tax year
• Qualified profile: the worker meets the high-qualification or specialisation requirements of Legislative Decrees 108/2012 and 206/2007, or has done research, including applied research, in artificial intelligence technologies

The fourth condition points to two other decrees, one on highly qualified workers and one on the recognition of professional qualifications. This course does not summarise them, because those texts were not read in writing it.

The sensible move is to have your employer or an adviser confirm that your degree and your role fit the definition before you build a budget around the relief.

Remote workers tend to overlook the third condition. Being resident in Italy is not enough: the work itself must be performed here for most of the year.

A consultant who settles in Bologna but spends eight months out of twelve at client sites abroad may fail it, even when everything else is in order.

Tax residence: the starting point

The regime speaks of moving residence within the meaning of article 2 of the income tax code, known as the TUIR, and Decree 209 itself rewrote that article with effect from 2024.

In the wording that governs 2026, a person is resident when, for most of the tax year, counting fractions of a day, they have in Italy their civil-law residence, or their domicile, or are simply physically present there.

Domicile is defined in down-to-earth terms: the place where the person's personal and family relationships mainly unfold.

Being on the resident population register for most of the year, on the other hand, creates a presumption of residence that can be rebutted. Three alternative tests plus one presumption: meeting any one of them makes you resident for that year.

For Italian citizens, paragraph 6 adds a rule about the years before the decree came into force. They count as resident abroad if they were enrolled in AIRE, the register of Italians living abroad, or were resident in another country under a double tax treaty.

Someone who left without enrolling in AIRE can therefore still prove the absence, but must be able to rely on the treaty.

Years abroad: three, six or seven

The basic rule asks for three tax years without Italian tax residence before the move. Letter b) of paragraph 1 lengthens it when, back in Italy, the worker serves the same employer they had abroad, or a company of the same group.

The point is to stop a short posting inside a multinational from turning into a tax springboard.

Paragraph 2 explains when two entities belong to the same group: when one controls the other directly or indirectly under article 2359, first paragraph, point 1, of the Civil Code, or when both are controlled by the same third party.

An Italian subsidiary and the German parent that controls it are one group; two competing companies are not.

How long it lasts and how you lose it

Paragraph 3 sets the length: the regime runs from the tax year in which tax residence moved to Italy plus the four following years, five tax years in all. Someone resident from 2026 benefits from 2026 to 2030, as long as the conditions keep holding each year.

The same paragraph prices a change of heart. If Italian tax residence is not kept for at least four years, the worker forfeits the relief and the relief already enjoyed is recovered, with interest. The loss is not only for the future: every euro saved in earlier years becomes payable again.

Anyone on a fixed-term contract, or likely to be sent abroad again, should run the numbers first. A cautious approach is to set aside the tax saved in the early years until the four years are up, so that an early departure can be paid for.

Paragraph 7 adds a less visible limit: the regime applies within the conditions of the EU de minimis state aid regulations. It is a technical clause referring to ceilings set at EU level, which this course does not quantify; just know it exists, especially if you receive other public aid.

Moves made before 2024 and the home-purchase case

Paragraph 9 repealed the previous scheme, article 16 of Legislative Decree 147/2015, but keeps it alive for people who moved their registered residence to Italy by 31 December 2023.

The two sets of rules will therefore coexist for years. The old one asked for two years of absence and, according to the Agency's archived page, brought only 30 % of the eligible income into the tax base, or 10 % in the southern regions named by the law.

Those percentages belong to the old scheme and do not apply to people arriving from 2024. Reading an older article and expecting 30 % is a classic mistake: under the current rules the taxable share is higher, the requirements are stricter and the special treatment for the South is gone.

Paragraph 10, by contrast, holds a transitional rule inside the new regime.

People who moved their registered residence in 2024 get three extra tax years, still at 50 %, if they became owners of a home in Italy used as their main residence by 31 December 2023 and in any case within the twelve months before the move. The Agency's page confirms the same dates.

A regime that can sit alongside others

The Agency's page states that the new regime is compatible with the other incentives for people moving their residence to Italy, provided each is applied to its own income and under its own conditions.

The example it gives, taken from ruling no. 16 of 2025, is a returnee who does both research and freelance work: article 44 of Decree-Law 78/2010 can cover the research income and article 5 of Decree 209 the professional income.

Compatible does not mean stackable on the same euro: each relief covers its own slice. If you will have several activities after the move, keep them clearly apart, contracts included, because that separation is what will justify in your return which regime applies to which income.