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How does the new Italian non-domicile tax program work?

I heard about Italy’s new non-domicile tax program. Does it apply to all foreign income or income from one certain foreign country? Do all kinds of income apply? I also heard that once a foreign investor opts to use the program, it is valid for 15 years. Will it still apply to me if I become an Italian citizen during that time?

  • LCA Studio Legale
    November 15, 2018

    The "res non-dom" tax regime option is applicable to all foreign income, notwithstanding the country of origin (as long as the applicant has indicated such country wihtin the option's geographic perimeter) nor the kind of income produced (only exclusion is for capital gains from the transfer of qualified shareholdings realized in the first five taxable periods from the option's exercise). The main condition is that the person applying for this tax regime shall not have resided in Italy during at least nine of the 10 years preceding the residency transfer. This regime is automatically renewed each year up to 15 years, unless in case of free revocation, and the acquisition of the Italian citizenship during the validity period of the regime does not affect its application.

  • Rossi & Rossi Law Firm
    November 18, 2018

    Yes, the program is applicable to all foreign incomes with no exclusion and it is valid for 15 years. No problem if one becomes an Italian citizen in the meantime.