
High-net-worth individuals eyeing a relocation to Italy will soon face a steeper price tag. A technical note published on 5 February by consultancy Interconsulting confirms that the 2026 Budget Law raises the annual substitute tax under the "Regime dei Nuovi Residenti" from €200,000 to €300,000 for the principal applicant and from €25,000 to €50,000 per dependent. The increase applies to anyone who registers as an Italian tax resident on or after 1 January 2026.
Italy introduced the lump-sum tax in 2017 at €100,000 to lure foreign billionaires and footloose entrepreneurs. A 2024 decree doubled the amount, but take-up remained strong, with advisory firm Fidal reporting 1,150 active beneficiaries last year. Government sources say the latest hike aims to maintain competitiveness while "aligning contributions with increased public-service demands." Crucially, existing participants remain grandfathered at their original rates, a continuity clause that preserves Italy’s credibility with mobile wealth holders.
Private-banking advisers believe the €300,000 levy still compares favourably with Switzerland’s expenditure-based deals and the UK’s remittance basis, especially after Britain’s decision to abolish non-dom status from April 2026. However, they expect a short-term surge in applications during the remainder of 2025 as clients rush to lock in the €200,000 rate.
Corporate mobility specialists note indirect effects: the flat-tax regime often underpins C-suite transfers and remote-work arrangements by neutralising Italy’s top marginal rate of 43%. Companies planning to relocate executives in 2026 or later should revisit cost-projections and consider alternative incentives such as the "impatriate" 50 per cent income exemption.
Immigration lawyers also flag possible processing bottlenecks at understaffed “Sportello Unico” offices if a late-2025 application spike translates into an end-of-year scramble for codice fiscale numbers and residence permits.
Italy introduced the lump-sum tax in 2017 at €100,000 to lure foreign billionaires and footloose entrepreneurs. A 2024 decree doubled the amount, but take-up remained strong, with advisory firm Fidal reporting 1,150 active beneficiaries last year. Government sources say the latest hike aims to maintain competitiveness while "aligning contributions with increased public-service demands." Crucially, existing participants remain grandfathered at their original rates, a continuity clause that preserves Italy’s credibility with mobile wealth holders.
Private-banking advisers believe the €300,000 levy still compares favourably with Switzerland’s expenditure-based deals and the UK’s remittance basis, especially after Britain’s decision to abolish non-dom status from April 2026. However, they expect a short-term surge in applications during the remainder of 2025 as clients rush to lock in the €200,000 rate.
Corporate mobility specialists note indirect effects: the flat-tax regime often underpins C-suite transfers and remote-work arrangements by neutralising Italy’s top marginal rate of 43%. Companies planning to relocate executives in 2026 or later should revisit cost-projections and consider alternative incentives such as the "impatriate" 50 per cent income exemption.
Immigration lawyers also flag possible processing bottlenecks at understaffed “Sportello Unico” offices if a late-2025 application spike translates into an end-of-year scramble for codice fiscale numbers and residence permits.
Source: Pragma International