What is Italy’s high net worth individual tax regime?
On 9th March, 2017, Italy introduced a high net worth individual tax system.
Pursuant to article 24 bis of Italy’s Budget Bill, a codicil introduced an annual fixed €100 thousand forfeiture substitutive tax rate for foreigners. The tax regime also applies to EU citizens, who decide to move their residence to Italy.
There is no fixed level of income attached to this tax regime. Individuals must be resident in Italy and tax is payable on worldwide income. However, tax will not be due on the value of real estate and financial investments located outside of Italy.
Individuals need to apply for the high net worth individual tax regime
According to the bill, uptake of the high net worth individual tax regime is neither an automatic right nor an obligation – it is a choice.
Individuals electing to take advantage of this fixed tax rate option, will have to file an advance application with the Italian tax authorities. The Agenzia delle Entrate then decides whether or not to grant the forfeiture substitutive tax rate to individuals. The Italian tax authorities will base their decisions on investigations with tax authorities in the individual’s country of origin. They will also check that an individual has not previously been tax resident in Italy.
The option extends to the individual’s family members provided they also meet the conditions of no previous tax residency in Italy. Each family member included in the option is also subject to an annual forfeiture substitutive tax on non-Italian sourced income. This is a lower fixed amount of 25,000 Euros.
If the Agenzia delle Entrate accepts an individual’s application, the option expires after 15 years. It is revocable at any time but in revoking the option, an individual loses the right to restore it.
After the 15 year residence period, the fixed tax rate will no longer be applicable. The individual will thereafter need to decide whether to continue to be resident in Italy. Should an individual continue to reside in Italy, standard tax rates apply.
Italian visa for investors
The Budget Bill also introduces a “visa for investors”. This means that any foreign national bringing a capital of at least €1 billion into Italy, and investing it within three months of arrival, automatically gains entitlement to a two-year residence permit.
Should you need help to understand your personal tax situation, please get in touch or seek advice from a qualified accountant registered with the ODCEC, the Italian professional accounting association of certified public accountants, auditors and advisors.