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The Resident Non-Domiciled Tax Regime (also known as the \"Flat Tax Regime\") was introduced by the Italian Government in 2017 with the aim of attracting high net worth individuals who want to relocate to Italy. 

The new legislation introduced a key change to the general principle of worldwide taxation for Italian tax residents. According to these provisions an individual who meets certain conditions can be considered resident, but non-domiciled, in Italy. This allows them to pay ordinary tax on income generated in Italy and a single, lump sum payment of €100,000 per annum, to cover tax due on non-Italian income. This is irrespective of the type, or source, of international income. 

The Resident Non-Domiciled Tax Regime is available to individuals who:

  • Transfer their tax residence to Italy (the maximum time that this favourable tax regime can be enjoyed is 15 years and it can be revoked at any time by the taxpayer).
  • Have not been tax resident in Italy for 9 of the previous 10 years, preceding their application to this tax regime.
  • Obtain formal approval from the Italian Tax Authorities. 

At Hanover Bond Law we have advised several clients on how to apply to benefit from the Flat Tax Regime, often (but not necessarily) in combination with advice relating to the purchase of Italian property.