International taxation — Italy

Italian lump-sum tax regime:
the new residents scheme

The Italian lump-sum tax regime is a preferential scheme introduced by the 2017 Stability Law (article 24-bis of the Testo Unico delle Imposte sui Redditi) which allows individuals transferring their tax residence to Italy to subject all of their foreign-source income to an annual flat tax, initially set at €100,000, raised to €200,000 by Italian decree-law No. 113/2024 of 9 August 2024 (the "Omnibus decree", converted by law No. 143/2024, applicable to arrivals from 10 August 2024), and now to €300,000 for new elections made from 1 January 2026 (Italian Finance Act for 2026, article 1). The regime is reserved for taxpayers who have not been Italian tax residents for 9 of the last 10 years, applies for a maximum non-renewable period of 15 years, and may be extended to family members for an additional €50,000 per beneficiary (since 1 January 2026; previously €25,000).

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— In brief
What
Annual lump-sum tax on foreign-source income for new Italian residents
Founding text
Article 24 bis TUIR (Italian Stability Law 2017)
Amount 2026
€200,000 (existing residents) / €300,000 (new residents after 1 January 2026)
Family
€50,000 per attached family member since 1 January 2026 (previously €25,000)
Duration
15 years from Italian tax residence, non-renewable
— 01

A regime designed to attract internationally mobile wealth

The Italian lump-sum regime is part of a tax attractiveness strategy pursued by Italy since 2017 to attract executives, elite athletes, entrepreneurs and mobile family wealth. Its economic logic is simple: an annual flat tax discharging all foreign income, in exchange for a genuine Italian tax residence and transparent asset reporting.

The regime has progressively tightened: €100,000 in 2017, €200,000 since 9 August 2024 (Omnibus decree), and €300,000 for new residents arriving from 1 January 2026. This trajectory is deliberate: Italy continues to attract but raises the threshold to target significant wealth.

For a French taxpayer, the Italian lump-sum regime is often a rational trade-off against French taxation of capital gains, foreign dividends and complex estates, provided the exit from France (tax residence, exit tax under article 167 bis of the French Tax Code, bilateral treaties) and the entry into Italy (effective residence, consular filings, transparent asset reporting) are properly orchestrated.

— 02

How the Italian lump-sum regime works

01

Eligibility

The applicant must not have been an Italian tax resident for 9 of the last 10 years preceding the transfer. The residence qualification is not reduced to a single criterion: it is a body of evidence (home, centre of economic interests, main place of stay, registration in the residents register) assessed on a case-by-case basis.

  • Genuine Italian tax residence, based on a body of evidence: effective home, centre of economic interests, main place of stay (183 days per year or more as an indication), registration with the AIRE / residents register
  • Declared assets: all foreign bank accounts must be reported (quadro RW)
  • Open to Italian nationals returning after a long expatriation (9 years or more)
  • The election must be made in the tax return of the first year
02

Amount of the flat tax

An annual flat tax discharging all foreign-source income.

  • 2017-2024: €100,000 (initial regime)
  • Since 9 August 2024: €200,000 (Omnibus decree)
  • From 1 January 2026: €300,000 for new residents
  • Italian-source income remains taxed under ordinary rules
03

Duration of the regime

The regime applies for a maximum of 15 years from the start of Italian tax residence, and is non-renewable.

  • Immediate application from the first year of Italian residence
  • Maximum duration of 15 years (article 24-bis TUIR)
  • Waiver possible at any time, irrevocable
  • Automatic forfeiture in the event of non-payment of the flat tax
  • On exit: return to ordinary Italian rules (IRPEF) on worldwide income
04

Attached family members

The regime may be extended to family members for an additional flat tax per beneficiary.

  • Before 1 January 2026: €25,000 per member
  • Since 1 January 2026 (Italian Finance Act 2026, art. 1): €50,000 per member
  • Covers the spouse, children and dependent parents
  • Each member must also be eligible (non-resident of Italy for 9 years)
— 03

France · Italy trade-offs: 5 operational issues

For a French tax resident considering the Italian lump-sum regime, the strategy is not limited to applying for the regime on the Italian side. The exit from France must be orchestrated to avoid double taxation or an untimely triggering of the exit tax.

1. French exit tax (French Tax Code art. 167 bis)

Transferring one's tax domicile out of France may trigger the exit tax on latent capital gains attached to significant shareholdings (50% or more, or value of €800,000 or more). Automatic deferral of payment for transfers to the EU/EEA (Italy is a member). Relief after 2 or 5 years of holding the securities depending on the case. A strategy to be built 12 to 24 months before departure.

2. France-Italy treaty of 5 October 1989

Determines the taxpayer's tax residence in the event of dual attachment (permanent home, habitual abode, nationality, mutual agreement). Allocates income (real estate, dividends, capital gains, salaries) between the two States. Important: the qualification of tax domicile is not reduced to the permanent establishment test, nor to mere registration in the residents register; it rests on a body of evidence (home, centre of economic interests, main place of stay) assessed on a case-by-case basis, both on the French side (French Tax Code art. 4 B) and on the Italian side (art. 2 TUIR). Essential reading to structure the first transition year.

3. French real-estate assets

Real estate located in France remains taxable in France (French Tax Code art. 4 A); the Italian lump-sum regime applies only to foreign-source income. Strategies: sell before departure to clear the French capital gain, hold through an SCI with specific trade-offs, or contribute to a dedicated structure. To be analysed on a case-by-case basis.

4. Cross-border inheritance

The France-Italy treaty of 20 December 1990 allocates inheritance taxation. The Italian lump-sum regime applies to income but not to inheritance tax: assets located in France remain subject to French gratuitous transfer duties. Estate planning is critical before departure.

5. Historical example: Cristiano Ronaldo at Juventus (2018-2022)

Cristiano Ronaldo's arrival at Juventus in 2018 was emblematic of the €100,000 regime. CR7 left Juventus for Al-Nassr in January 2023, but the transaction had popularised the Italian lump-sum regime as an attractiveness tool for high-income athletes and executives. Now at €200K (€300K in 2026), the flat tax remains highly competitive for foreign income typically above €800K per year.

— 04

The firm's approach

Bensaid Avocats advises executives, athletes, entrepreneurs and wealthy families considering a transfer of tax residence to Italy. Our work covers the pre-transfer analysis (eligibility, exit tax, wealth structuring), coordination with Italian advisers (Italian tax lawyers, commercialisti), preparation of the first-year returns and multi-year follow-up.

We structure each matter from the taxpayer's economic reality: nature and geography of income, latent capital gains, real-estate assets, family structure. Our structures favour legal certainty over aggressive schemes: a poorly prepared transfer can trigger a substantial exit tax or double taxation.

Our dual admission to the French and Swiss bars is an asset for multi-jurisdictional matters, which are frequent in this client base: we coordinate directly with Swiss advisers on Stiftung structures, foundations and international trusts that interact with the Italian lump-sum regime.

— Frequently asked questions

Everything you need to know before applying for the Italian lump-sum regime

Who can apply for the Italian lump-sum tax regime?

Individuals transferring their tax residence to Italy who have not been Italian tax residents for 9 of the last 10 years preceding the transfer. The regime is open to foreigners, but also to Italian nationals returning after a long expatriation (9 years or more). The election is made in the first Italian tax return.

How much does the flat tax cost from 2026?

€200,000 per year for taxpayers who transferred their residence before 1 January 2026. €300,000 per year for new residents from 1 January 2026 (Italian Finance Act for 2026). An additional flat tax of €50,000 per attached family member. Italian-source income remains taxed under ordinary rules.

What is the difference between the €100K regime (2017-2024) and €200K/€300K (2024+/2026+)?

The mechanics of the regime are identical; only the amount changes. Taxpayers who elected before the successive increases benefit from a grandfathering rule: their flat tax remains fixed at €100K as long as they stay in the regime, whatever subsequent legislative changes occur. This is why many decisions were made in 2024 and 2025 before the latest increase.

Does the Italian lump-sum regime cover foreign capital gains?

Yes. The flat tax applies to all foreign-source income, including securities and real-estate capital gains realised outside Italy, foreign dividends, interest, foreign rental income and foreign pensions. One exception: capital gains on qualified shareholdings in non-Italian-resident companies remain taxable under ordinary rules during the first 5 years of the regime.

How to avoid the French exit tax when leaving for Italy?

The exit tax (French Tax Code art. 167 bis) benefits from an automatic deferral of payment for transfers to the European Union (Italy is a member), provided the taxpayer retains a significant shareholding and declares the deferral in their last French tax return. Relief is granted after 2 years (EU/EEA transfers) or 5 years (other conditions) if the securities are retained. A strategy to be built with a tax lawyer 12-24 months before departure.

Is the Italian lump-sum regime compatible with keeping real estate in France?

Yes, but French real estate remains taxable in France under ordinary rules (rental income, real-estate wealth tax, real-estate capital gains). The Italian flat tax applies only to foreign-source income within the Italian meaning. Common strategies: sell the French real estate before departure to clear the capital gains, hold through a family SCI, or structure a dismemberment of ownership coordinated with the heirs.

What happens to my French-source income during the Italian lump-sum regime?

Retained French-source income (rents, French dividends, French securities capital gains) remains taxable in France under the rules applicable to non-residents (French Tax Code art. 4 A et seq.; bilateral treaty). The Italian flat tax does not cover this income. French non-resident taxation applies: minimum rates of 20-30%, social levies as the case may be, etc. See our page Non-resident income tax returns.

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Considering a transfer of residence to Italy?

A confidential initial discussion to assess your eligibility for the lump-sum regime, anticipate the French exit tax and structure the transition.

Request an appointment See the Non-residents practice
Jonathan Bensaid, avocat fondateur

Written by

Me Jonathan Bensaid, avocat fiscaliste, fondateur du cabinet Bensaid Avocats, inscrit aux Barreaux de Paris & Genève.

© BENSAID Avocats — The information on this site does not constitute legal advice and cannot replace a personalised tax analysis.