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Studio Paci

📜 New Italian Tax Regime for Expatriates in 2024

🔍 Introduction

In 2024, the tax regime for expatriate workers in Italy underwent significant changes with the introduction of Legislative Decree No. 209/2023, published in the Official Gazette No. 301 on December 28, 2023.

This decree, which came into effect on December 29, 2023, has significantly reformed international taxation, including a new favorable regime for workers who transfer their tax residence to Italy starting from the tax year 2024.

This is a measure aimed at encouraging the arrival of highly qualified workers, which entails a reduced taxation rate of 50% on incomes up to a maximum of 600,000 euros annually.


📝 Details of the New Regime for Expatriates in 2024:

The new tax regime for expatriates in 2024 offers significant benefits for those who transfer their tax residence to Italy.

This regime, introduced by Legislative Decree no. 209/2023, provides for taxation limited to 50% of income, both for dependent and self-employed work, up to a maximum of 600,000 euros per year.

However, to access these benefits, workers must meet certain conditions:

1. Commitment to reside in Italy in the year of transferring tax residence and in the following 4 tax periods.

2. No tax residence in Italy in the three tax periods preceding the transfer.

3. Predominant performance of work activity in Italy.

4. Possession of high qualifications or specializations, as defined by Legislative Decrees no. 108/2012 and no. 206/2007.


Furthermore, the regime provides for tax exemption that applies from the moment of transferring tax residence to Italy and for the following 4 tax periods.

If the worker does not maintain tax residence in Italy for the required period, they will lose the benefits and will have to pay taxes on income calculated in full, in addition to interest.

There are also specific conditions for those who work for the same employer or group both before and after transferring to Italy. In these cases, the minimum period of stay abroad before the transfer is:

- 6 tax periods if the worker was not previously employed in Italy.

- 7 tax periods if the worker was employed in Italy before the transfer abroad.


An additional benefit is provided for those who transfer to Italy with minor children or become parents during the period of enjoying the regime, with a reduction of taxation to 40%.

Furthermore, those who transfer tax residence in the year 2024 and acquire a residential property in Italy by December 31, 2023, or in the 12 months preceding the transfer, can extend the 50% income tax exemption for an additional three tax periods.


🌐 Impact on Businesses:

The new tax regime for expatriate workers in 2024, an integral part of the 2024 Budget Law, represents a significant opportunity for Italian companies.

This measure is a key element of the government's efforts to attract and retain high-level talents, with a direct impact on the country's economic development and competitiveness.

For businesses, this regime means having access to highly skilled workers and specializations in key sectors, which can bring innovation and contribute to business growth.

Furthermore, this measure helps position Italy more competitively on the international stage, aligning it with other countries that have adopted similar strategies to attract global talents.


📊 Analysis of the Change:

2024 marks a year of significant changes in the Italian tax landscape, with the introduction of a tax reform aimed at redefining the rules for taxpayers and influencing various economic sectors.

This transformation aims to stimulate economic growth and ensure a more equitable distribution of the tax burden among citizens and businesses.

With new tax rates and incentives for investments, these changes are expected to have a substantial impact on the country's financial landscape in the coming years.

The reform, therefore, not only offers benefits to expatriate workers but also fits into a broader context of tax reform that affects all taxpayers, both individuals and companies, with long-term implications for the Italian economy.

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