Arriving in 2026 costs a new resident €100,000 a year more

Two founders move to Milan with the same money behind them. One arrives in November 2025, the other in February 2026. Both opt into the regime Italy keeps for people who have lived abroad, and both pay a fixed sum every year instead of Italian income tax on everything they earn outside Italy. The one who arrived in 2025 pays €200,000. The one who arrived in 2026 pays €300,000, for the same regime, and goes on paying it for as long as the option runs.12

The option runs for fifteen tax periods. Held for its full term, the difference between those two arrival dates is €1,500,000.18

Three prices, all of them current

Article 24-bis of the income tax act was written into law by the 2017 budget. It lets someone who moves their tax residence to Italy, and who was not resident here for nine of the ten years before, pay a flat annual sum on foreign income “a prescindere dall’importo dei redditi percepiti” — whatever that income comes to. The sum started at €100,000. A decree in August 2024 doubled it. The 2026 budget raised it again, to €300,000, and took the extension to a relative from €25,000 to €50,000.132

Neither increase reached anyone already in the regime. Both amending acts carry a clause saying who they apply to, and both name the same event: the transfer of residence. The 2024 decree reaches people who moved “successivamente alla data di entrata in vigore del presente decreto”, the 2026 budget those who move “a decorrere dalla data di entrata in vigore della presente legge”. So the price is set by the year of arrival and then stays there, and three prices are being paid at once by three groups of people under one article.32

Reading the article at fifteen dates between 2017 and today puts the switch-overs where the law does. Normattiva serves any article as it stood on a given day and stamps each version with the window it was in force for: €100,000 from 1 January 2017 to 9 August 2024, €200,000 from 10 August 2024, €300,000 from 1 January 2026.18

What the increases bought

A price that triples usually buys something. The obvious reading of a cohort gap is that the later arrival is paying more for a better regime, which would make the €100,000 a difference in what is on offer rather than a difference in what it costs. That is checkable: the operative text of the article can be compared across the versions, with Normattiva’s editorial marks and footnote pointers stripped out, and with the two euro figures blanked.1

Both repricings come back identical. In nine years the article has changed in exactly one way that is not an amount: a cross-reference in comma 3, which used to point at lettera b) of the taxpayers’ statute and now points at lettera f) of it, because that statute’s list was renumbered in December 2025. The conditions, the fifteen years, the nine-of-ten residence test, the exclusion of certain share disposals, the extension to relatives: all of them read in 2026 as they read in 2017. The later cohort is buying the same thing.18

That comparison was wrong the first time: it reported the 2025 and 2026 texts as different, and the difference was a footnote pointer the latest amendment had wrapped in its own insertion marks, so removing the marks first left a bare number that no longer looked like a footnote. The rule now strips pointers before marks.

What €300,000 has to displace

The fee is worth paying at the point where it undercuts what the ordinary rules would have taken. Below that point, opting in is a voluntary overpayment. When the fee was €100,000 that crossing sat at €250,698 of foreign income. It is now €715,814 — for income taxed on the ordinary scale, held as the person’s only income, with nothing already paid in the source country.49

That single number is the weakest thing here, because the crossing point moves with the kind of income the fee is standing in for. Foreign dividends and interest do not go on the progressive scale at all: article 18 taxes them by substitute tax at the same rate as the withholding they would have borne in Italy, which for dividends is twenty-six per cent. A flat rate crosses a flat fee much later. And tax already paid in the source country comes off the Italian bill as a credit, which lowers what the fee is being measured against and pushes the crossing further out again.567

So the honest answer to whether the regime is worth it is a band rather than a figure: somewhere between about €680,522 and €1,153,846 of foreign income a year, depending on what the income is and how much of it the source country has already taxed. Under the first fee the same band started around €238,337. The bar has moved by roughly the same multiple as the price.9

The flat tax this is not

This is not the regime most people who move to Italy to work will use, and the two are unrelated beyond both being flat. This one reaches foreign income only. Comma 1 defines what it covers by pointing at article 165, and that article defines foreign income as the mirror image of the rules that decide what is Italian — so income arising from work done in Italy stays outside it and is taxed normally, however large the fee already paid.17

A founder who moves to Milan and invoices clients from an Italian partita IVA is billing Italian income. Nothing in article 24-bis touches it. The regime that does is the forfettario, which taxes a fixed share of revenue up to a ceiling of €85,000 — a different regime, with its own cliff at that ceiling and its own way of deciding what share of revenue counts as profit. The two answer different questions and someone choosing between them on the strength of the phrase they share will choose wrong.

What this does not settle

The break-even is a comparison of tax on income, and the regime carries more than that. The act that introduced it also released anyone in it from declaring foreign assets and from the two levies on foreign property and foreign financial accounts, and those exemptions are worth real money to someone holding assets abroad rather than income. Counting them would pull every figure in the table down by an amount that depends on what the person owns, which is why they are named here and not netted off.1

Three other things the numbers do not carry. The computation treats the foreign income as the person’s only income and applies no deductions or credits, which at these amounts are small but not always nil. The surcharge figure is a national stand-in of 2.23 per cent rather than the pair actually charged where someone lives, and that pair varies by more than a thousand euros across Italy. And the exclusion in comma 1 — gains on certain shareholdings sold in the first five years stay under the ordinary rules — means a person selling a company soon after arriving is not covered by the fee for that gain at all.1

Nor does any of this predict the next budget. The grandfathering held twice, in the same form both times, and each act wrote it deliberately. Whether a third increase would be written the same way is not something the two precedents can settle — they are what parliament chose to do, not a constraint on what it may do.