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Taxation and residency

Living in Italy: tax residency, IRPEF 2026, special regimes and inheritance

This page describes the issues a French citizen living in Italy encounters on the Italian side: tax residency, the 2026 IRPEF tax brackets, two special tax regimes for newcomers, inheritance tax, and social security. It is based on official Italian and French texts and websites, which reopened on October 18, 2026. We are neither lawyers nor local tax specialists: matters pertaining to Italian law should be verified with a professional based in Italy.

Italian tax resident since 2024: alternative criteria

The French Embassy in Italy (page dated 11/08/2026) considers presence in Italy for the majority of the tax year, i.e., at least 183 days per year (184 in leap years). Only one criterion is required: registration with the embassy, domicile, or residence as defined by the French Civil Code.

Circular 20/E of the Agenzia delle Entrate, presented in a press release dated November 4, 2024, has applied these criteria since 2024. The press release draws two conclusions from this:

  • Fractions of a day count towards the number of days; ;
  • registration in the civil status becomes «una presunzione relativa (e non più assoluta) di residenza fiscal in Italia»: proof to the contrary is admitted.

When France also considers you a resident, Article 4 §2 of the 1989 convention differentiates between: permanent home, then center of vital interests, habitual residence, nationality, and finally, agreement of the authorities. The French perspective is explained on our page regarding Article 4 B of the French General Tax Code (CGI).

IRPEF 2026: three tranches, 23 %, 33 % and 43 %

The 2026 Budget Law (Law 199/2025) replaces, in Article 11 of the TUIR (Unified Tax Regulations), "35 per cento" with "33 per cento", effective January 1, 2026. The Chamber of Deputies presents the applicable scale:

Taxable income bracketRate
Up to €28,00023%
From €28,000 to €50,00033%
Over €50,00043%

For 2024, Legislative Decree 216/2023 stipulated the same thresholds, with 35 % in the intermediate bracket. Only the Camera dei Deputati, a parliamentary institution and not the tax administration, provides us with the three brackets for 2026: the text of Article 11 of the TUIR could not be read.

Income of €80,000: a numerical example (fictitious profile)

Situation. A French consultant, fictitious profile, is an Italian tax resident and declares €80,000 of taxable income in 2026.

Issue. She wants to estimate the gross IRPEF and measure the effect of changing the second rate from 35 % to 33 %.

Strategy. Each rate is applied to the portion of income included in its bracket.

Result.

BracketBaseRateTax
1€28,00023%€6,440
2€22,00033%€7,260
3€30,00043%€12,900
Total€80,00033.25 % on average€26,600

At a rate of 35% of the % tax bracket, the second tranche would have cost €440 more (€22,000 × 2 % tax brackets). This calculation ignores deductions, abatements, and regional and municipal surcharges, none of which we have seen in the official source.

New arrivals: the Article 24-bis scheme and 7 % retirees

New residents. Law 199/2025 amends paragraph 2 of Article 24-bis of the TUIR (Uniform Act on Income Tax): "€200,000" becomes "€300,000" and "€25,000" becomes "€50,000". The text applies from the date of entry into force of the law, January 1, 2026. Our dedicated page provides further details on this system.

Retirees of foreign origin. Article 24-ter of the TUIR provides for a substitute tax, "calcolata forfettariamente con aliquota del 7%," for recipients of foreign-source pensions who transfer their residence to certain municipalities: Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise, Apulia, and municipalities affected by earthquakes (tax code 1899). The Agenzia delle Entrate website does not specify the duration of the option or the eligibility requirements.

Under the Franco-Italian tax treaty, private pensions are taxable in the country of residence (Article 18), with the exception of public pensions, which are generally taxable in the country that pays them (Article 19 §2 a). Our page on non-resident retirement pensions provides further details on the French perspective.

Inheritance in Italy: 4 %, 6 % or 8 %, with high deductibles

Legislative Decree 139/2024 replaced Article 7 of the Consolidated Law on Successions. By beneficiary:

Connection with the deceasedRateFranchise
Spouse, direct line parents4%€1,000,000
Siblings6%€100,000
Other relatives up to the fourth degree, direct line relatives by marriage, collateral line relatives by marriage up to the third degree6%none indicated
Other people8%none indicated

For a person with a recognized disability (Law 104/1992, Article 3 §3), the tax only applies to the portion exceeding €1,500,000.

Territoriality. Article 2 of the consolidated text subjects to taxation all assets and rights transferred, "ancorché esistenti all'estero" (anchored and existing abroad). If the deceased was not a resident of Italy, only assets located in Italy are subject to taxation. A child who receives €1,800,000 net from their parent would pay, in this respect, 4 % on €800,000, or €32,000 (calculation based on a hypothetical case).

The version displayed by Normattiva is indicated as valid until 31/12/2026: the applicable version is determined on the date of death. The 1989 convention referred to here concerns income tax and wealth tax; its interaction with French inheritance law is not addressed on this page.

Social security: National Health Service, INPS and INAIL

According to the Cleiss (2024 edition), the National Health Service "offers basic healthcare to all residents"; registration takes place with the ASL (Local Health Association) of the place of residence and provides the health card (tessera sanitaria). The INPS (National Social Security Institute) manages sickness and maternity benefits, pensions, unemployment benefits, and family allowances; the INAIL (National Institute for Insurance against Accidents at Work) covers work-related accidents and occupational diseases. Retirement requires at least 20 years of contributions and age 67.

Contributions 2026 according to Cleiss, for the IVS part: 9.19 % for employees, 23.81 % for employers, 24 % to 26 % for self-employed workers, with a minimum base of €18,808 and a maximum base of €122,295.

On-site formalities

After three months, the Italian Ministry of the Interior describes the registration process with the local municipality of habitual residence, either in person or online; the municipality issues a certificate of registration. There is no deadline for registration and no fine. Income tax returns are filed using form 730 before September 30th or form Redditi PF before November 30th. In case of doubt regarding interpretation, the embassy website refers to the "istanza di interpello" (request for information) with the Agenzia delle Entrate (tax authorities).

What this page does not cover

We were unable to find information from official sources regarding: the tax on financial assets held abroad (IVAFE), the tax on real estate held abroad (IVIE), the taxation of financial income, local surcharges, and obtaining the codice fiscale (tax code). An investor holding a portfolio or assurance-vie policy must have these matters validated in Italy.

What changes depending on your situation

  • Your status – employee, self-employed, retired or investor – is not subject to the same rules.
  • Your region and your municipality, for the pension scheme and local surcharges.
  • Your links with France: maintaining a home or business activity can make you a resident of both states.
  • The composition of your family determines inheritance tax exemptions and rates.

No results can be announced without reviewing your file.

Frequently asked questions

When does a French citizen become an Italian tax resident?

As soon as one of the following criteria is met: presence for the majority of the tax period, i.e., at least 183 days per year (184 in leap years), registration with the tax authorities, domicile, or residence. Since 2024, registration is a presumption that can be rebutted by evidence to the contrary.

What is the IRPEF tax scale in 2026?

According to the Camera dei deputati: 23 % up to €28,000, 33 % from €28,000 to €50,000, 43 % above €50,000.

How much inheritance tax is there for a child in Italy?

The rate is 4 % on the net value which exceeds €1,000,000 per beneficiary, for parents in the direct line.

Can a retiree benefit from the 7 % rate?

The 7 % rate applies to foreign pensioners who transfer their residence to certain municipalities, according to the list of regions and municipalities on the Agenzia delle Entrate website. The duration of the option and eligibility requirements are not specified on the website.

Take stock of your installation

Balmont Conseil, a firm based in Lyon for nearly 14 years, advises executives and families whose assets span France and Italy. To discuss your situation, please schedule an appointment.

Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)

Official sources