Non Dom Italy: Everything You Need To Know About Italy’s €200K Flat Tax Regime Going Into 2025…
In 2025, Italy is uniquely placed as a safe haven destination for the world’s wealth. The country’s (recently amended) €200,000 Flat Tax regime for HNWIs and UHNWIs historically played second fiddle to the likes of the UK’s Non-Dom Status regime…
Until March 6, 2024, that was, when the UK Chancellor announced the end of the Non-Dom regime, effective April 6, 2025, in favour of a residency based tax system.
Portugal, too, will be replacing their massively popular Non-Habitual Residency – now terminated – with a watered-down version of the program – the so-called NHR 2.o – in the near future.
Even Dubai, which used to be completely tax-free, has recently introduced corporate taxation.
And so, as the adage goes, now all roads lead to Rome for those seeking Non Dom tax benefits.
For high net worth migrants seeking a new tax home, Italy’s Flat Tax Regime offers excellent advantages. For eligible applicants, it replaces the country’s progressive tax system on worldwide income with a single flat tax levy for a period of 15 years (up from €100,000 to €200,000 in 2025).
Additional eligible family members can be added to this flat tax regime for an additional levy of €25,000 per fiscal year.
The regime covers foreign sourced income, but tax residents cannot deduct any taxes they already paid abroad from this amount.
And by obtaining an advanced tax ruling, applicants can ensure legal and fiscal certainty ahead of actually relocating to Italy.
This can also prevent unintended tax liabilities from being triggered upon relocation, however working with a knowledgeable tax expert in obtaining an advanced tax ruling from Agenzia delle Entrate is essential.
Let’s take a look at the Italian Non Dom regime’s benefits below…
LEGAL DISCLAIMER:
The below content does not constitute immigration or tax advice, and is presented purely as general information on the Italian HNWI Tax Regime. Due to the frequently changing nature of tax regulations, the below information, deemed accurate at the time of publication, is by no means guaranteed. Reading this article does not imply the creation of a client-attorney relationship, and neither the publishers nor any of our associates will be held liable for any losses suffered, either directly or indirectly, as a result of reliance on this information.
Be sure to seek tailored tax advice from a leading Italian tax lawyer specializing in the Italian Non Dom Tax Regime before making any decisions (you can contact one below).
The Italian Non Dom Tax Regime’s
Benefits At A Glance
As a travel and lifestyle destination, Italy is a product that sells itself, and has done so for decades. But the country’s extraordinarily high tax rates – and a top marginal rate of 43% for annual incomes above €50,000 – have historically served as a significant deterrent to affluent foreigners shopping around for new “home” jurisdictions.
In 2017, however, the country introduced the so-called €100,000 Italian Flat Tax Regime (also referred to as the “Special Tax Regime (STR) for High Net Worth Individuals”). And as an added benefit, you can extend the lump sum tax benefits to your family members, too – by paying an additional annual flat tax of just €25,000 per family member.
This program’s flat tax threshold was increased to €200,000 earlier in 2024.
Under this scheme, high net worth foreign individuals who are willing to relocate to Italy and establish their tax residency there can opt to pay a €200,000 flat tax per tax year on all of their foreign earned income. That means that your total tax bill on worldwide earnings would be capped at €200,000 – regardless of whether you earned a million or a billion euro – in lieu of standard Italian tax rates.
(Note: If you’re American, the IRS will follow you and demand their share regardless of where you live in the world; unless, of course, you expatriate. If you’re looking for professional advice on citizenship renunciation and US expat taxation, you can request contact from an expert here).
The great news is that these benefits are applicable for 15 full years from the point at which you register for the regime. That’s enough time to get fully settled and build a meaningful life in the country.
It must, however, be noted that these benefits do not apply to all types of foreign income: Any Italian sourced income earned as an Italian Non Dom taxpayer will be treated as ordinary Italian income, and taxed accordingly.
In addition, capital gains realized on foreign investments, and income derived from the sale of qualified foreign shareholdings, are subject to ordinary Italian taxation during the first five years of your qualifying for the Italian Non Dom tax status.
Ordinary Italian taxation is both onerous and high. Fortunately, qualifying under the Non Dom tax regime gives you the opportunity to avoid the following taxes and tax filing obligations for foreign income (i.e. income subject to the flat tax):
- The wealth tax on investments held abroad, saving you 0.2% per year on the value of financial investments, and 1,06% p.a. on the original cost of real estate properties held abroad.
- The Italian Inheritance and Gift Tax (varying from 4% to 8%, depending on the degree of kinship you share with the deceased/giver).
- The filing of annual declarations pertaining to your investments held abroad – provided that you pay the relevant flat tax in full, and in a timely manner.
To be frank, in a time when calls to “eat the rich” are mounting globally, the Italian Non Dom tax regime is an excellent deal – and one of the only remaining options of its kind available.
(Uruguay offers an interesting Non Dom tax regime as well, however, its location and bucolic atmosphere will certainly not be for everyone.)
How Can I Become A Tax Resident Of Italy In 2025?
As a reminder, legal residency and tax residency are two separate issues. In addition, as a rule of thumb, legal residency status tends to lead to tax residency. And unless you’re getting a job in Italy, or marrying an Italian, you’ll likely have to apply for one of the following two legal residency programs:
| Residency Program | Italian Elective Residence AKA Italy’s Retirement Visa | Italian Investor Visa AKA The Italian Golden Visa |
|---|---|---|
| Investment Required | No | Yes. See this Italian Golden Visa page for more information. |
| Passive Income Required | Yes | No |
| Minimum Annual Stay Requirement | Yes (183+ days per year, or 184+ days, in a leap year) | No (0 Days per year) |
You will generally become an Italian tax resident if you spend more than 183 days per calendar year in the country (and more than 184 during a leap year). However, it is worth noting that the Legislative Decree on International Taxation, No. 209 of 27 December 2023 (Italian PDF), introduced some important modifications to Italy’s tax residency rules for individuals; in particular to the Statutory Test of Tax Residence (STTR).
Article 2 of the Tax Code, effective as of 2024, means that you will most likely be considered an Italian tax resident if, for more than 183 days per year (or 184 days in a leap year), you just meet one of the following criteria:
- You are physically present within the territory of Italy.
- Your “center of vital interests” is in Italy (i.e. your spouse and children live there permanent, OR;
- Your “habitual abode” is in Italy, OR;
- You are registered as a resident in the list of resident population ( the so-called anagrafe) maintained by your local authority (i.e. a Comune).
Note: The latter stipulation is only a presumption of tax residence, not an absolute test, and can be overcome, e.g. by the terms of an applicable tax treaty.
So if you’re looking to avail of Italy’s €200,000 Italian Flat Tax regime benefits, the above criteria would be applicable. Italy is also home to tax incentives for retirees, as well as for employees and self-employed workers, however these incentives cannot be combined with the Italian HNWI Flat Tax regime…
Tax residency is typically not triggered unless you spend more than 183 days per year in the country. However, consulting a tax advisor is highly recommended. Italy offers favorable tax schemes for new residents, including a flat €200,000 annual tax on foreign income for high-net-worth individuals.
How Can I Qualify For Italy’s €200K Non Dom Flat Tax Regime?
In order to be eligible for the flat tax benefit under the regime, you have to be able to prove that you were not registered as an Italian tax payer for 9 (or more) consecutive years before applying for the Italian Special Non Dom Tax Residency.
The advantageous tax regime is available for “newly resident” individuals moving to Italy, who have not been tax resident in Italy for at least 9 years out of the 10 years preceding their relocation to the country. Family members of qualifying individuals can also benefit, subject to the payment of an additional 25,000 flat tax on their foreign sourced income per year.
All nationalities are eligible to benefit under the regime; even Italian citizens, as long as they’d not been tax residents in the country for 9 out of the 10 preceding years. You can access the regime either by submitting an advance tax ruling to the Italian Internal Revenue Service, or by exercising the option for substitute taxation in your annual tax returns.
You can also revoke this option at any time. Importantly, your access to the regime will be terminated should you either not pay the requisite flat tax, or if you fail to meet the requirements for the Statutory Test of Tax Residence during any applicable tax year.
Start Your €200,000 Italian Flat Tax Application Today, Working With An Acclaimed Italian Flat Tax Lawyer In Milan
For affluent, UK based Non Doms seeking a new home country in particular, Italy, and its Flat Tax Regime, can make a lot of sense.
Having said that, applying for the Italian Non Dom Regime is by no means a DIY exercise: Especially for those utilizing offshore trust and complex company structures, working with an experienced Italian tax lawyer is highly advisable.
If you’d like to discuss this attractive tax regime with a leading Italian tax lawyer based in Milan, simply complete the below form now to request expert contact and more information on how you can apply for an advanced tax ruling ahead of relocation.
To request contact from a leading Italian tax lawyer to discuss Italy’s Flat Tax and how you can benefit, get in touch below.
Simply complete the below form to request contact from an Italian tax specialist.
Quoted on tax matters by Forbes, Marco and his firm assists high-net-worth individuals and families with their transition to Italy from a tax and legal perspective.
He has successfully helped numerous of our clients to take advantage of the Italian Flat Tax Program, and is an expert on the process of submitting advanced tax filings in Italy.
Italian Flat Tax Program Overview (2025) Compiled By…
Born in Cape Town, South Africa, Andre Bothma is a seasoned digital entrepreneur specializing in European Residency By Investment programs (and the Italian Investor Visa, in particular).
After graduating from Rhodes University in 2002, he spent two decades building a career in online marketing.
He also previously served as national marketing director for the official political opposition in South Africa.
Given the challenges faced by the Portuguese Golden Program in recent years, many North American Plan B seekers have started looking at alternative European Golden Visa options.
And, going into 2025, the Italian Investor Visa is arguably the most underrated program of its kind.
With these factors in mind, Andre launched GoldenVisas.it with a view to give foreign Plan B investors access to the information and opportunities they need to secure their Italian back-up plan – discretely, securely, and hassle-free.
Andre is a prolific writer on investment migration, and has been advising an international client base on their European Residency and Citizenship By Investment options since 2017.
He splits his time between Porto, Cape Town, and increasingly, Milan.
