Greater appeal to the tax regimes for impatriate workers (article 16 of the legislative decree 147/2015) with the norms foreseen by the recent Decree n. 34 (Decreto Crescita). In order to favor the return of these subjects to Italy, the Government has strengthened the existing relief measures, relying on the further reduction of the tax base and the extension of their duration.
For those who are resident and transfer their residence in Italy from the tax period following the date of entry into force of the decree, a further reduction in the tax base is foreseen, which goes from 50 to 70%; the income produced will compete for 30 percent.
Work activities – no longer in a managerial position or highly qualified or specialized – must be carried out in the Italian territory, but no longer necessarily in favor of a resident company or one of its subsidiaries. The tax periods of residence abroad prior to the transfer were then reduced from five to two. Confirmed the commitment to reside in Italy for at least two years post-repatriation. The favorable regime can be applied not only to employees, income assimilated and self-employed workers, but even to natural persons who start a business company from the tax period following 31 December 2019.
Italian citizens not registered in the Aire who have returned to Italy from the tax period following 31 December 2019 will also be able to access tax benefits as long as they have resided in another State with which there is an agreement against double taxation in the two periods tax prior to the transfer.
The facility is also extended for another five tax periods in the presence of at least one child who is a minor or dependent, even in pre-adoptive foster care, and the purchase of a residential property in Italy, even by the spouse, cohabitant or children, also in joint ownership.
The tax base is further reduced for the additional five tax periods in favor of workers who have at least three children who are minors or are dependent, even in pre-adoptive foster care, or who have transferred their residence to regions of Southern Italy (Abruzzo, Molise, Campania, Puglia, Basilicata , Calabria, Sardinia, Sicily).
For the facilitation of the return of the brains (reduction by 90% of the income perceived by teachers and researchers) the decree foresees the extension from four to six years of the duration for the subjects that transfer residency in Italy starting from the tax period following 31 December 2019. The duration of the favorable tax regime is further extended to eight years in the presence of at least one minor child or dependent child, including those in pre-adoptive custody, and the purchase of residential property in Italy, also by the spouse, cohabitant or children, also in joint ownership. The duration of the facility is elevated to 11 and 13 years in the presence of two or at least three children respectively. Italian professors and researchers not enrolled in the Aire who have returned to Italy from the tax period subsequent to 31 December 2019 will also be able to access the facilitation provided they have resided in another State with which there is an agreement against double taxation.
Our firm can assist international clients, as we do, not only to relocate their residence to Italy, but also to opt for the new resident not domiciled tax package. Contact us with confidence, we have experience about this matter.