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Newly domiciled Regime
Newly domiciled Regime
Italy has introduced an attractive tax regime for high net worth individuals that moves to, and becomes tax resident in, Italy. This regime enables eligible taxpayers, to opt to be taxed in Italy on their selected foreign-sourced income by paying a flat annual charge of 100,000 Euros.
To have access to this favorable regulation it is necessary to respect some conditions of admission that are:
The nature of the taxpayer, this can only be a individual.
The taxpayer has to move and transfer his residency in Italy;
The taxpayer cannot have resided in Italy for more than one year out of the ten years preceding the year of the transfer.
The election has a validity for a period of 15 years from the year and can be revoked at any time, it is not possible to renovate the regime at the expiration date.
The eligible taxpayer may further choose to extend the application of the regime to one or more relatives, as defined by the Italian Civil Code, that also derive foreign source income and that they relocate their tax residence to Italy. In such a case, the yearly substitute tax will be increased by 25,000 Euros for each relative joining the regime. Thus, the increase does not apply if the relative is a minor without income.
Italian-source income and non-selected foreign-source income are subject to ordinary Italian taxation. In fact, the taxpayer may elect not to apply the regime to income sourced in certain foreign countries. Such foreign-sourced income will, therefore, be subject to Italian statutory taxation, although it will benefit from the provisions of the treaties for the avoidance of double taxation where applicable.
Italian Business Group (IBG) - Newsletter
JPA International -The International Tax Newsletter Autumn 2017
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