Impatriates: current provisions

The purpose is nevertheless the same: to enhance Italy's attractiveness in the eyes of foreigners living abroad.

However, contrary to the legal provision in force until the 31st December 2023, the current version provides for a greater selection of beneficiaries, which is limited to individuals:

• with distinctive professional qualifications or titles;
• proven to be resident abroad for at least three tax periods (demonstrable by AIRE registration or by application of the provisions of the relevant double taxation convention).

Below are the key points of the scheme under discussion.

Requirements

The starting condition is always the transfer of residence to Italy.

More specifically, paragraph 1 of the aforementioned article specifies that the facilitated regime is applied to ‘...employment income, income assimilated to employment income, and self-employment income deriving from the exercise of arts and professions produced in Italy by workers who transfer their residence to the territory of the State pursuant to Article 2 of the Consolidated Income Tax Code, pursuant to Presidential Decree No. 917 of 22 December 1986.

Therefore, among the aforementioned kinds of income, the measure p...