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New Italian Special Tax Regime Lump sum tax for assets and income abroad

The Italian budget law for 2017 has introduced a special tax regime for foreign income earned by individuals who wish to transfer their tax residence in Italy.

The new art. 24-bis of the Law on Income Tax provides for an optional system of lump sum taxation replacing the normal taxation regime for individuals that transfer their residence in Italy, if they have not been a tax resident in Italy for at least nine fiscal years during the ten preceding the start of the option period.

The substitute tax applies only to foreign-source income that, in this way, will not be a component of the total income of the Italian taxpayer resident.

The substitute tax will be EUR 100,000.00 per tax period, whatever the amount of the assets held or the income realized abroad.

The new substitute tax regime will apply only after a positive answer from the Italian Inland Revenue and a respective ministerial decree implementing the scheme. The CoRe Team is available to assist you with any questions related to this matter


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