Italy Flat Tax for Foreign HNWIs: 2026 Guide

Anyone who moves tax residence to Italy on or after January 1, 2026 can elect to pay a flat tax of EUR 300,000 per year on foreign-source income, plus EUR 50,000 per included family member. Those who moved before 2026 are not affected by the increase, and the election lasts up to 15 years.

How much does the Italian flat tax for foreigners cost in 2026?

The amount depends on the date the person transfers residence. Legge 30 dicembre 2025, n. 199 (the 2026 budget law) amended art. 24-bis, comma 2, of the TUIR and replaced "euro 200.000" with "euro 300.000" and "euro 25.000" with "euro 50.000" (art. 1, comma 25). Comma 26 applies the change to those who transfer residence from the date the law enters into force.

The Agenzia delle Entrate itself warns, in a note dated January 16, 2026, that the budget law raised the tax to EUR 300,000 and the family member's tax to EUR 50,000. It recalls that, until August 10, 2024, the amount was EUR 100,000. The body of the same page still shows EUR 200,000 and EUR 25,000, which are the previous amounts. When in doubt, the text of the law prevails.

What does the flat tax cover and what is left out?

It replaces personal income tax (IRPEF) on income produced abroad. The amount is fixed, "a prescindere dall'importo dei redditi percepiti," that is, it does not change whether the foreign income is higher or lower.

Three points of the legal text deserve attention:

• •Country exclusion: the taxpayer may indicate States or territories whose income is left outside the regime. In those cases, the ordinary regime applies, with a credit for tax paid abroad.
• •Exception in the first five years: the substitute tax does not apply to the income of art. 76, comma 1, lettera d), of the new consolidated text, when realized in the first five periods of validity of the election. Ask the Italian adviser to confirm whether any of your assets falls under this rule.
• •No stacking: the election does not add to the effects of the impatriates regime (arts. 225 and 226).

The text deals with income produced abroad. For Italian-source income, consult an accountant in Italy.

Who can elect the regime?

An individual who transfers residence to Italy and was not a tax resident in the country in at least 9 of the 10 tax periods before the start of the election. Tax residence follows art. 2 of the consolidated text: the person has civil residence, domicile or presence in Italy for most of the tax period.

This concerns tax. The regime does not replace the residence permit or visa required by Italian immigration, which is a separate matter, with a different authority.

How do you include family and what does it cost?

The election can be extended to family members under art. 433 of the Italian Civil Code who also meet the rule of 9 of the 10 periods. Each family member pays EUR 50,000 per period, under art. 246, comma 2, of the new consolidated text.

Revocation or loss of the regime by the main taxpayer extends to family members. Loss of the regime by a family member, for failure to pay their amount, does not bring down the main taxpayer (art. 246, comma 6).

How do you request the election and how do you pay?

The election is indicated in the income tax return for the period in which residence was transferred or in the one for the following period, according to the Agenzia. The taxpayer reports the jurisdictions where they last had tax residence. The Agenzia passes that information to those countries' authorities through administrative cooperation (art. 246, comma 3).

On the interpello, the sources describe it differently. The Agenzia page treats the interpello request as a consultation the taxpayer "may" make before electing. The text of art. 246, comma 3, published in the Gazzetta Ufficiale, provides for the election after a favorable answer to an interpello. Confirm the current procedure with a professional in Italy.

Payment follows these rules, according to the Agenzia:

• •single installment, by the payment date for the balance of the income tax;
• •form F24 "Versamenti con elementi identificativi," tax code NRPP, paid by the main taxpayer and by each family member;
• •no possibility of using ravvedimento operoso.

How long does the election last and when does it end?

It lasts up to 15 years, counted from the first period of validity of the election. Before then, the taxpayer can revoke it. The effects also cease if the tax is not paid, in whole or in part, and revocation or loss of the regime prevents a new election (art. 246, comma 4).

Did the legal basis change with the new consolidated income tax text?

Yes, the numbering changes from 2027. Legislative Decree of June 19, 2026, No. 117, approved the new Testo unico delle imposte sui redditi (Gazzetta Ufficiale No. 152, of July 3, 2026, Ordinary Supplement No. 26/L). The regime of art. 24-bis of the TUIR becomes art. 246 of the new text, which repeats the amounts of EUR 300,000 and EUR 50,000.

Art. 377 says the consolidated text applies from January 1, 2027. Until then, the basis is art. 24-bis of the TUIR, as worded by Law 199/2025. When researching, you will find both article numbers.

What does a Brazilian need to check before moving?

The flat tax settles taxation in Italy. Leaving Brazil is a separate step, and a Brazilian's situation depends on the ties they keep here, such as real estate, companies and pensions. See what changes for INSS contributions when leaving Brazil and how preserving wealth across generations fits into the planning.

Before deciding, ask for a tax planning analysis that compares Italy with other jurisdictions, such as Portugal, and check the compliance obligations that remain in Brazil. To move funds between countries, also see the offshore banking service.