Italy's flat tax changed 14 times. The 15% never did.

Ask what the forfettario’s revenue ceiling is and the answer depends on when the page you are reading was written. In 2015 a consultant had to stay under €15,000 to use it. From 2016, €30,000. From 2019, €65,000. From 2023, €85,000. Someone billing €60,000 was above the line for the regime’s first four years and inside it for the eight since — same work, same billing, a moving ceiling.3

That is one rule. The regime is thirty-six of them, and they sit in one place: article 1, commi 54 to 89 of the 2015 stability law.1 Normattiva, the state’s consolidated record of the statute book, serves any part of an act as it stood on a given date and stamps each version with the window it was in force for. Follow those windows from the first day of the regime to the last and you get every text it has ever had: fifteen of them, fourteen changes in twelve tax years.

Fifteen rulebooks, ninety versions

The two numbers in that heading are different measurements and it matters which one is quoted. Normattiva served the block holding commi 1 to 100 in ninety versions over the same period — but that block is part of a budget law of 735 commi covering pensions, school building and everything else the 2015 budget touched, and most of those ninety versions leave the flat tax untouched. Cutting commi 54 to 89 out of each and comparing them with the version before leaves fifteen distinct texts.2

Getting from ninety to fifteen took two passes. The first reported twenty-four, and three of the extra “changes” were a footnote number that appeared next to a full stop and a semicolon that gained a space in front of it. Normattiva marks recent amendments with double brackets and numbers its footnotes afresh whenever a note is added anywhere in the act, so a comma can be re-typeset without a word of it changing. Strip the brackets, the footnote pointers and the space before a comma or semicolon and the count settles at fifteen. Keep them and it reads twenty-six, which would be a fact about a website rather than about the law.

Fifteen versions across 4,383 days is a median shelf life of 185 days. The shortest text lasted 23 days, from 1 to 23 January 2016. The longest ran 759 days, through 2017 and 2018, which is the only stretch in the regime’s history when a person could have read the rules twice a year apart and found the same words.

What moved, and when

Not every change is worth a reader’s attention. Seven of the thirty-six commi decide whether a person may use the regime and what they pay: 54 to 56 are the way in, 57 is the list of people shut out, 64 and 65 set the tax, and 71 says when it stops applying. The rest are VAT, invoicing, withholding and reporting duties — real obligations, but they do not move the answer to “can I use this, and what will it cost me”. That split is declared before the comparison runs rather than chosen afterwards, and the full list of commi touched by each change ships in the data, so anyone who would draw the line elsewhere can recount.

Eight of the fourteen changes land on one of those seven. Three of the eight are the January rewrites — 2016, 2019, 2020 — and each of those moved four or more of them at once.

Commi in bold include at least one of the seven that decide eligibility, the rate or the exit.

The door kept moving

Comma 57 — the list of people who may not use the regime — changed seven times, more than any other. Comma 54, the way in, changed five. Between them they have been rearranged in a way no summary of “the 2019 reform” quite conveys.

In 2015 comma 54 asked four separate things of a person: revenue under the ceiling for their activity group, no more than €5,000 of spending on employees and collaborators, no more than €20,000 of capital goods, and business income exceeding any employment income they also had. The 2019 text asks one: revenue under €65,000. Everything else was deleted, and the last of the four reappeared the same day in a different place — as an exclusion in comma 57 for people working mainly for an employer they have or recently had. In 2020 two of the deleted conditions came back, the labour-cost cap now at €20,000 rather than €5,000.

The ceiling is the part a person feels. Until 2019 there was no single ceiling at all: the annex set nine of them, one per activity group, and a professional’s was the lowest bracket in the table while a retailer’s was nearly three times higher.

A professional-services activity billing €60,000 was therefore outside the regime on the revenue test in 2015, 2016, 2017 and 2018, and inside it from 2019. At €80,000 the wait was eight years. That is the revenue test alone: in those same years the labour-cost cap, the capital-goods cap and the prevalence test could each have shut the same person out independently, so clearing the ceiling was necessary and not sufficient.

The half that never changed

Nineteen of the thirty-six commi read the same on the last day as on the first, and comma 64 is one of them. That is the comma the whole regime is known by: it applies the profitability coefficient from the annex and taxes the result at un’imposta sostitutiva […] pari al 15 per cento.1 Fourteen rewrites have gone on around that sentence in twelve years without altering a word of it.

The rate for a new business is a different story, and the distinction is worth keeping. In 2015 comma 65 cut taxable income by a third for the first three years. From 2016 it sets the rate at 5% for the first five. Both are called “the startup relief” and they are not the same thing: the older one scaled with the coefficient, the newer one does not.

So the stable part of the regime is the part everyone quotes, and the unstable part is the part that decides whether the quote applies to you. That is a reasonable answer to why two confident explanations of the forfettario can disagree and both have been correct: a guide written in 2018 was describing a real regime with a €30,000 ceiling and four entry conditions, and every word of it was out of date within a year.

The line about people who live abroad

Comma 57, letter b) shuts out people who are not resident in Italy, with an exception for residents of an EU or EEA state who earn at least 75% of their total income here. That exception has been there since the beginning. What changed on 15 December 2024 is a sentence added to the end of it: for VAT purposes, persons established in another member state apply the franchise regime under title V-ter of the VAT decree.1 The income-tax test and the VAT treatment of a cross-border small business are now handled in the same letter and answer to different rules.

It is the only one of the fourteen changes aimed squarely at people who do not live in Italy, and it arrived in the middle of December for a tax year starting sixteen days later.

What this does not show

This counts changes to the statutory text of the regime and nothing else. It does not count the acts that made them — one act can move two commi and two acts can land on the same day, so the changes are dated by when the new text took effect rather than attributed to a law. It does not count the coefficient annex, which is versioned separately and has three versions of its own. And it says nothing about the guidance, the forms and the circolari built on top of the statute, which change more often than the statute does and are what most people actually read.

A comma also counts as changed here whether a single word moved or the whole thing was rewritten, so fourteen is a count of occasions and not a measure of how much moved on each one. The list of commi in the data is the correction for that: the 2019 and 2020 rewrites touch eleven and ten commi, four of the others touch a single one.

One more thing this count does not include, because it has not happened yet: on 1 January 2027 commi 54 to 89 are repealed and the regime becomes twelve articles of a new income-tax code, with all eighteen of its operative numbers carried across unchanged.4 That is a sixteenth rulebook by any reasonable reading, and the first one whose arrival does not change what anybody pays.