TAX ADVANTAGES TO ATTRACT “HUMAN CAPITAL” FROM ABROAD

The Italian tax system, in order to support the economic, scientific and cultural development of the country, offers numerous benefits to people who move their residence to Italy for work.

Tax regime for so-called “impatriate” workers, art. 16 of Legislative Decree 147/2015: the benefit provides for a taxable income of 50% (2019) and 30% (from 2020) of the income from employed or self-employed work received, for a maximum of 5 years, which can be extended for another 5 years under certain conditions.
Article 24/bis Tuir of the so-called “neo-residents” tax regime: it provides for the possibility for individuals residing abroad for at least nine of the last ten tax periods to move to Italy by paying as follows:
1) an annual substitute tax of € 100,000 (plus € 25,000 for each “accompanying” family member) for all income from foreign sources, with the possibility of excluding some countries;

2) Taxes calculated on the basis of ordinary progressive rates per bracket for all Italian source income.

The newly-resident (and all his family members) may benefit from this preferential arrangement for a maximum period of fifteen years. Facilitations are also provided for in relation to inheritances and donations on assets located outside Italy.

Fiscal incentives for researchers and teachers, art. 44 D.L. 78/2010: the benefit provides for a taxable income of 10% of the income from employment or self-employment received, duration 6 years, which can be extended under certain conditions.
In addition, with the changes introduced by the Budget Law 2019, a “flat tax” of 7% is provided for pensioners living abroad who move to the South, in municipalities with less than 20,000 inhabitants. The 7% applies to all foreign source incomes of the pensioner.

Studio Tributario Societario Internazionale is available to evaluate with the client the most favorable opportunities in each specific case.