Italy's new resident tax regime: a flat tax of €300,000 for new arrivals in 2026

The new resident regime under Article 24-bis of the Italian Income Tax Code (TUIR) establishes a flat annual tax, referred to as a substitute tax for income tax (IRPEF). The amount has changed: €100,000 according to the Italian tax authorities, €200,000 for transfers after August 11, 2024, and €300,000 for individuals transferring their residence to Italy from the date of entry into force of the 2026 Budget Law (January 1, 2026, according to the editorial note on the official Italian legislation portal). To qualify, you must have been a non-resident in Italy for at least nine of the ten previous tax periods, with a maximum duration of fifteen years. The exact amount depends on the date of your transfer.

Four amounts from four sources

Official sources don't say the same thing. That's the main difficulty with this regime.

The AdE fact sheet therefore still shows €100,000, an amount that more recent texts have exceeded: the figure of €100,000 applies to transfers prior to August 12, 2024. For a transfer of residence after August 11, 2024, the 2025 schedule indicates €200,000, in application of decree-law no. 113 of August 9, 2024.

An unresolved disagreement. The AdE's schedule for the June 30, 2026 deadline, from the same series (NRPP code), sets a limit of €300,000 for all transfers after August 11, 2024, and €50,000 per family member, without mentioning the January 1, 2026 date. The 2026 budget law, however, applies the increase to transfers from its entry into force. Therefore, for transfers between August 12, 2024, and December 31, 2025, these two sources do not align, and no source consulted explains the discrepancy. The amount applicable to this period should be verified with the Italian administration.

What the 2026 law says

Law No. 199 of December 30, 2025, amends Article 24-bis, paragraph 2, of the Italian Civil Code (TUIR). Paragraph 25 replaces "euro 200,000" with "euro 300,000" in the first sentence, and "euro 25,000" with "euro 50,000" in the second. Paragraph 26 governs the temporal application: these provisions apply to persons who transfer their residence within the territory of the State from the date of entry into force of the law, namely January 1, 2026, according to the editorial note of Normattiva, the official portal of Italian legislation.

The amount of €300,000 therefore applies to transfers of residence from 1 January 2026. The text quoted is the original text of the law, before any possible amendments.

The amount of €50,000 per family member appears in the AdE schedule for the deadline of June 30, 2026. The law does indeed replace "25,000" with "50,000" in the second sentence of comma 2; the attribution of this sentence to family members is not found in the text of the law itself, but in the schedule.

The conditions

Two pages of the AdE agree on two points:

• Nine out of ten periods. The scheme is reserved for those who have not been resident in Italy for at least nine of the ten previous tax periods.
• Fifteen years at most. The maximum duration is fifteen years.

The other eligibility requirements and the list of income covered by the flat-rate tax are not presented here. The payment title in the schedule is "Imposta sostitutiva dell'IRPEF – NUOVI RESIDENTI – art. 24-bis, comma 2, del TUIR," meaning a tax that replaces income tax. The exact scope of this substitution is not detailed here.

The payment

According to the AdE's payment schedule for the June 30, 2025 deadline, payment is made in a single installment, using form F24 and the tax code NRPP, no later than the tax balance due date, i.e., June 30. "Ravvedimento operoso" (voluntary regularization with reduced penalty) does not apply.

Foreign-source pensions: another scheme at 7 %

Article 24-ter of the TUIR (Tax on Foreign Income) provides for a substitute tax for the IRPEF (Income Tax on Foreign Pensions) for recipients of foreign pensions who transfer their residence to certain municipalities in Southern Italy. This tax is calculated at a flat rate of 7%. The AdE (Regional Tax Administration) schedule lists Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise, and Apulia, as well as municipalities covered by Decree-Law No. 189/2016 and those affected by the earthquake of April 6, 2009 (the limit of 30,000 inhabitants follows the mention of the earthquake in the schedule). The tax code is 1899.

The duration of the option and the eligibility conditions, for example the country of origin of the pension or previous residence, are not indicated in the AdE timetable and are not detailed here.

Inheritance

Inheritance between France and Italy is governed by the convention signed in Rome on December 20, 1990, which entered into force on April 1, 1995. Its allocation rules are not detailed here; our page on the France-Italy tax treaty presents them. Italian inheritance tax (rates and allowances) is not addressed here.

What this page does not cover

Italian tax residency as defined in Article 2 of the Italian Tax Code (TUIR), the 2026 income tax (IRPEF) scale, Italian inheritance tax, local taxes, and the Italian tax identification number (codice fiscale) are not covered here. The formalities for residency in Italy for EU citizens are also not detailed. The relationship with leaving France (exit tax, tax domicile) and with the tax treaty is addressed on other pages.

Numerical example (fictitious profile)

Situation. A Frenchman, a fictitious profile, is considering transferring his residency to Italy. He has not been a resident there for the previous ten periods. He is coming with two family members.

Issue. He reads different amounts depending on the source, and wants to know which one applies based on the date of his transfer.

Strategy. He applies to his household the amounts of the AdE schedule for a transfer after August 11, 2024, then those of the 2026 law for a transfer from January 1, 2026.

Result. According to the 2025 schedule, for a transfer after August 11, 2024, the lump sum would be €200,000 for him, plus €25,000 for each of the two family members, totaling €250,000 per year (€200,000 + 2 × €25,000). The 2026 law replaces €200,000 with €300,000, an increase of €100,000, and €25,000 with €50,000, an increase of €25,000. For a transfer starting from January 1, 2026, the same household would receive €400,000 (€300,000 + 2 × €50,000), an amount confirmed by the 2026 AdE schedule. For a transfer between August 12, 2024 and December 31, 2025, the law and the 2026 schedule do not give the same result (see above): the example of €250,000 follows the 2025 schedule.

What changes depending on your situation

• The date of your transfer of residence determines the applicable amount.
• Your residence history in Italy over the previous ten periods.
• The number of your family members affected.
• The nature and location of your income, and the exact scope of the substitution.
• Your situation in France: tax residence, assets, departure.

These elements are examined on a case-by-case basis. No tax result can be announced without this examination.