THE TAX REGIME FOR “IMPATRIATES”


Are you thinking of returning or moving to Italy and want to know if you can legitimately pay less tax? The Impatriate tax regime could be the right solution for you.


The 2025 Impatriate Regime is a tax measure designed to encourage the return of qualified workers, offering a tangible benefit: a minimum 50% reduction on the taxable income earned in Italy from employment or self-employment for five years.


1. Eligibility requirements


The regime applies when the following conditions are met:


a) Transfer of tax residence to Italy, according to Article 2 of the TUIR (Italian Tax Code).


b) Not having been a tax resident in Italy in the three tax years prior to the transfer. However, if the worker is employed in Italy by the same entity they worked for abroad before the transfer, or by a company in the same group, the minimum period of stay abroad is:

  • six tax years if the worker had not previously been employed in Italy by the same entity or a company in the same group;
  • seven tax years if the worker had previously been employed in Italy by the same entity or a company in the same group.

In this regard, companies are considered part of the same group if there is a direct or indirect control relationship or if they are under common direct or indirect control by another entity.

c) The work activity must be carried out in Italy for the majority of the tax year.

d) The individual must meet the criteria of high qualification or specialization as defined by Legislative Decrees no. 108/2012 and no. 206/2007. This includes professionals such as managers, researchers, executives, or technicians with advanced training.

A particular case concerns workers who wish to move to Italy but do not hold a university degree.

On this matter, the Italian Revenue Agency recently clarified through two rulings (no. 71/2025 and no. 74/2025), confirming the eligibility of a project manager and an IT specialist, both without university degrees for the tax benefit.

These rulings suggest that the applicable criteria are (more comprehensively and alternatively) those stated in Article 27-quater of the Consolidated Immigration Act:
  • A university degree of at least three years;
  • Practicing a regulated profession (e.g., nurse);
  • A higher professional qualification demonstrated by at least 5 years of experience, comparable to a university degree and relevant to the job;
  • A higher professional qualification demonstrated by at least 3 years of experience in the last 7 years, for executives and specialists in the IT sector.

These access conditions must be maintained throughout the five years of tax benefit. Otherwise, the beneficiary will lose the benefits and the tax authority will have the right to recover the unpaid taxes.

2. How to Apply?


To apply for the Impatriate bonus:


Employees can:

  i) submit a written request to their employer, who will apply the benefit starting from the next pay period, or

  ii) opt for the regime directly in their income tax return, declaring the reduced income.


Self-employed individuals can:

  i) submit a written request to their client, requesting reduced withholding tax on their income, or
  ii) opt for the regime directly in their income tax return, declaring the reduced income.

3. Eligible Income and Duration of the Benefit


The 2025 Impatriate Regime provides a tax exemption ranging between 50% and 60% (the latter applies if the worker relocates with a minor child, or in the case of childbirth or adoption during the benefit period) on employment or self-employment income earned in Italy, up to a maximum of €600,000.


Income from business activities and company shareholding is not eligible.


In practice, the regime excludes 50% or 60% (in the presence of minor children) of the income from the taxable base. For example, with an income of €100,000, taxes will not be paid on €50,000 or €60,000. IRPEF rates will apply only to the remaining €40,000 or €50,000.


This is particularly advantageous, especially for avoiding the top IRPEF rate, and is more beneficial for those with higher incomes.


The revocation of the tax relief regime may occur for:

  • failure to meet the minimum period of tax residency;
    • work activity not primarily carried out in Italy;
    • errors or omissions in the tax return.

    Following the revocation of the regime, Italian authorities have the right to reclaim the taxes not paid for all the years during which the taxpayer benefited from the regime, plus late payment interest starting from the date the taxes should have originally been paid.