Italy's flat tax at €300,000: who still moves for it, and why the official counts cannot answer yet

Three prices for one regime: €100,000, €200,000 and €300,000

The regime began with the 2017 Budget Law at €100,000 a year for the main taxpayer and €25,000 for each family member. The Agenzia delle Entrate's own information page still shows those amounts. It was last updated on 24 November 2023.

The first increase came in August 2024. Article 2 of Decree-Law 113/2024, known as the omnibus decree, raised the main amount to €200,000 for people who moved their residence after 10 August 2024, the date the decree took effect. The family amount stayed at €25,000 (ecnews, 25 October 2024; CMS, 9 August 2024).

The second increase is in the 2026 Budget Law. The bill's article 11 became article 1, commi 25-26, of the enacted law, according to the Chamber of Deputies' research dossier on the bill (24 December 2025). The law appeared in the Gazzetta Ufficiale on 30 December 2025 (Serie Generale n. 301, ordinary supplement n. 42) and took effect on 1 January 2026. The government's technical report on the bill describes comma 1 of article 11 as raising the main payment "da 200.000 euro a 300.000 euro" and the family payment from €25,000 to €50,000. We read the report through a third-party copy. The legal sites leggeinchiaro and e-glossa reproduce commi 25-26; in e-glossa's copy, comma 26 applies the new amounts to people who transfer residence under article 43 of the civil code from the law's entry into force. We did not open the official text on Normattiva or in the Gazzetta Ufficiale.

The result is three cohorts paying three prices for the same regime, each for up to 15 years. The main amount has tripled since 2017 and the family amount has doubled. Table 1 sets out the rules as they stand.

The regime's mechanics did not change in 2026. The payment covers foreign-source income only. Italian income is taxed in the normal way. A taxpayer can leave named countries out of the regime and pay ordinary Italian tax on income from them, with a credit for foreign tax. Gains on qualified shareholdings sold in the first five years are excluded. The payment is due in one sum by the income tax balance deadline, 30 June, or 30 July with a 0.40% surcharge. Those details come from a law-firm briefing by Watson Farley & Williams (22 January 2026), which we did not check against the statute. A ruling request to the tax agency before opting in is optional, and the payment code is NRPP (Agenzia delle Entrate).

Who pays €300,000, and who does not

The 2026 increase applies to new arrivals only. The technical report says the higher amounts apply to people who "hanno trasferito nel territorio dello Stato la residenza ai fini dell'articolo 43 del codice civile" from the date the law came into force. Article 43 of the civil code defines residence as the place of habitual abode. The Senate budget committee's rapporteur, Claudio Borghi, described the same scope on 11 November 2025: people who transfer their tax residence to Italy after the law takes effect.

Some commentary has said otherwise. The legal site leggeinchiaro wrote, in its own comment on comma 25 (published 4 May 2026, updated 27 October 2026), that the new amount applies also to people who had already opted in. The technical report contradicts that reading, and we found no source in the law or the agency's guidance that supports it.

The tax agency has not published updated guidance. We found no circular or published ruling on the 2026 transitional rule, and the agency's page still gives the 2017 amounts. Anyone relying on the transition date should check with the agency or an adviser. The day a person becomes resident under article 43 decides which of three prices applies.

A fourth change is already law. Decree-Law 38/2026 of 27 March 2026, article 2, bans combining the flat tax with the separate regime for workers who move to Italy (the impatriati regime, article 5 of Legislative Decree 209/2023). The ban applies "a decorrere dal periodo d'imposta 2027" to people who transfer their tax residence to Italy, according to the Chamber of Deputies' summary of the decree. The summary does not say whether people who transfer during 2026 are covered. A tax agency ruling of 28 January 2025 (Risposta 16/E) had allowed the combination, according to the tax site fiscomania (3 April 2026). We did not verify the decree's conversion law.

Nothing in article 24-bis deals with immigration status. It is a tax election. Citizens of countries outside the EU need a residence permit under separate rules. Our planned guides to the elective residence visa and to moving to Italy cover that side.

How many people use it: three counts, three units

Every count of the regime in circulation measures something different. Table 2 puts them side by side with their units.

The Finance Department's yearly IRPEF analyses count tax returns that include the "NR – Nuovi residenti" section. The count was 957 for tax year 2022, 1,242 for 2023 and 1,631 for 2024. The 2024 figure includes 27 people who used the return to revoke the option (footnote 42). Growth was 29.8% and then 31.3% (derived, ours). Family members who join the regime can file the section too, according to the technical report, so this is a count of returns, not of households.

The Corte dei conti counts beneficiaries and splits them into main taxpayers and family members. Its summary report on the 2024 State accounts (26 June 2025) gives 1,495 beneficiaries in 2023: 1,070 main taxpayers and 425 family members. ItaliaOggi (19 February 2025), citing Agenzia delle Entrate data, reported 1,136 for 2022 (818 and 318), as did Pagella Politica without the split. It also reported 196 main taxpayers and 67 family members for 2018, a total of 263 (derived, ours), without naming a source. For the following year, QuiFinanza (26 June 2026) reported 1,923 beneficiaries (1,374 and 549) from the court's June 2026 report, without a year. It is most likely 2024. We did not open that report.

The two official series do not match, and they should not. For 2023 the Finance Department counts 1,242 returns and the Corte 1,495 beneficiaries. The first is a count of filed sections. The second is a count of people covered, including relatives who may not file. Neither is a count of people who arrived that year.

The newest number comes from Assonime, an association of Italian joint-stock companies. MF Milano Finanza (4 July 2026) reported a study titled "Towards Italy. L'Italia e l'attrazione di Hnwi, manager e talenti" that counts 2,468 beneficiaries in 2025, up from 94 in 2017. We could not find the study, and the article does not say whether family members are included. If the unit matched the Corte's 1,923, the 2025 figure would be 28% higher (derived, ours). We cannot confirm the units match.

What the 270 and the 130 measure

The most quoted figures about the 2026 increase come from the government's own technical report. Fiscalità Patrimoniale (Edoardo Catinari, 12 November 2025) summarized them as "un calo delle adesioni di circa il 50%, con un flusso medio di soli 130 nuovi residenti annui". Our own content plan wrote of adherents falling from 270 to 130. The report says something narrower.

It says that in the three most recent years available, 2021 to 2023, "il numero di soggetti interessati dal regime speciale per i neo-residenti ha registrato un incremento annuo di circa 270 unità in media". That is the average yearly increase in the number of people in the regime. It is a historic figure.

It then assumes, "prudenzialmente", that after the rise to €300,000 the number of new residents opting in grows by "circa 130 soggetti" a year, "about half" the 2021-2023 flow. The report itself calls the 270 the "flusso di neo-residenti" and says 130 is "circa la metà rispetto al flusso di neo-residenti rilevato nel triennio 2021-2023". So the comparison is the report's own. The 130 is still a costing assumption used to score revenue. The report does not present it as a forecast of behavior, and it gives no evidence for the halving.

We could not check the 270. The published series we found have no 2021 figure. From 2022 to 2023, Corte beneficiaries rose by 359, Finance Department returns by 285 and main taxpayers by 252 (derived, ours). The report does not say which series it used.

The revenue estimate follows from the assumption. The report multiplies 130 people by a €100,000 difference per person and gets about €13m a year from 2027. In what it calls "un'ottica di estrema prudenza", it does not count the build-up of cohorts over time. It estimates about 59 affected family members, based on 2023 returns and payment records, at €25,000 each, for about €1.5m. The total is €14.5m a year from 2027. The report does not say whether the 59 is a yearly flow. It is far below the 425 family members the Corte counted in 2023, which would fit a flow (our inference). The report contains no estimate of investment, spending or people deterred from moving.

Who files: nearly half also earn in Italy

The Finance Department returns show more than the headcount. In each year, a little under half of filers also declared income produced in Italy: 46% for 2022 and 2023, and 48.4% for 2024. That Italian income totaled €75m, €87m and €102.5m. Most of it was employment income: 86%, 82% and 73.3% of the total. The flat tax covers only foreign income, so these filers paid ordinary Italian tax on their Italian salaries.

A sponsored piece in ItaliaOggi (18 July 2026, written by advisers at DLA Piper and AlTi Tiedemann Global) uses the same figures to argue that managers of multinational groups are joining investors in the regime. The returns support the narrower point. Nearly half of filers have Italian income, mostly from work.

Where they come from and where they live is known only from Assonime, through the press. MF Milano Finanza reported that nearly 40% of 2025 beneficiaries moved from the United Kingdom and 52% chose Milan. Panorama (26 July 2026) added Rome at 17% and reported that one in two new residents bought at least one property, at an average price just under €4m, for more than €4bn in 2017-2025. None of these figures has an official counterpart. The Finance Department and the Corte publish no split by nationality, previous country or city.

The UK figure has a plausible policy background that the data cannot confirm. The UK abolished its non-domiciled regime and the remittance basis on 6 April 2025 and replaced them with a four-year relief for people not UK-resident in the previous ten years, under the Finance Act 2025 (ACCA, May 2025). No source we opened links UK departures to Italian flat-tax arrivals with data.

For a city like Milan, the residency thread overlaps with tourism and housing. A small number of very high-spending residents can matter in prime property and services. The scale is small next to visitors. The 2,468 beneficiaries Assonime reports for 2025 compare with 61.4 million foreign overnight travelers to Italy in 2025 (Bank of Italy, international tourism survey, June 2026). Our Rome travel guide and the Italian citizenship ruling in numbers cover the visitor and residency sides of the same cities.

What the State knows about the money

The State counts the payments it receives. The Corte dei conti summary of June 2025 gives about €315m paid in 2020-2023: €287.5m by main taxpayers and about €27.7m by family members. QuiFinanza reported the court's June 2026 figures as about €469m in 2020-2024, of which €153m in 2024. Subtracting the two totals gives €154m (derived, ours), consistent with the reported 2024 figure. The tax agency also answered 706 ruling requests on the regime in 2024, according to the Corte.

What the State does not know is the cost. The Corte wrote in June 2025 that the agency does not know the foreign income covered by the flat tax or the ordinary taxes that would have applied without it. Without those, nobody can say whether the regime raises or loses revenue compared with taxing the same people normally, assuming they would have come anyway. The court also said that no specific survey was set up to assess whether the regime meets its stated aim, which the 2017 Budget Law report described as encouraging investment in Italy. In 2024 the economy minister, Giancarlo Giorgetti, called reinvestment "molto difficile valutare" (Pagella Politica, 19 August 2024).

QuiFinanza's headline on the June 2026 report spoke of a "rischio di incostituzionalità". The article's text is more cautious. It reports that the magistrates said the measure "could" conflict with the constitutional principle that everyone contributes to public spending. We did not read the court's wording.

The economic estimates in circulation are private. Assonime's €5.3bn is described as direct and indirect effects on the country, property and consumption included, and its €38.4bn by 2040 is a projection (MF Milano Finanza; Panorama). The method was not published in either article. They are model outputs. The official revenue figure is the payment total, and the official cost figure does not exist.

Italy against Greece, Switzerland and the UK

Italy is not the only country with a lump-sum regime. Greece's article 5A of its income tax code charges €100,000 a year on foreign income and €20,000 per relative, for up to 15 years, to people who were not Greek tax resident in seven of the previous eight years. It requires an investment of at least €500,000 in Greece within three years, waived for people who hold an investment residence permit (Independent Authority for Public Revenue, AADE, 12 November 2025). Italy's regime has no investment requirement. Italy's main amount is now three times Greece's and its family amount two and a half times (derived, ours).

Switzerland taxes some foreign residents on their spending instead of their income. The Federal Department of Finance reported 4,557 people taxed this way at the end of 2018, paying CHF 821m, fewer than 0.1% of taxpayers. The page sets no single national amount and suggests asking the cantons for current figures.

The UK moved the other way. Since 6 April 2025 it no longer offers the remittance basis and limits relief on foreign income to four years for new arrivals.

These regimes differ in amount, duration and conditions, so a straight price ranking misleads. Greece's €100,000 comes with a €500,000 investment. Switzerland's charge depends on the canton and on spending. The comparison shows that Italy raised its price while a nearby competitor kept a lower one with an investment test.

What nobody publishes

No official source counts new arrivals by year. Every series in this article is a stock of returns or beneficiaries, or an increment calculated by the government for costing.

No data exists yet on the €300,000 cohort. People who moved in 2026 will first report the regime in returns for tax year 2026, filed in 2027. The Finance Department gives no publication date for its analyses; its tax year 2024 figures were in the press by April 2026. On that pattern, figures for 2025 would appear around spring 2027 and the first €300,000 year around 2028 (our inference from the publication pattern).

No official split by nationality, previous country of residence or Italian city exists. The UK, Milan and Rome shares are Assonime's, reported by the press.

No measure of the regime's cost or benefit exists. The agency does not know the foreign income covered or the tax forgone, and no specific survey was set up to assess the investment aim (Corte dei conti). The technical report scores only the payment difference.

No count of people leaving the regime exists, apart from the 27 revocations in tax year 2024 returns. The regime ends if a person stops paying or moves abroad, and neither is counted in anything we opened.

This is the same gap our insights series has found in Venice, Rome, Florence and at Italy's borders. Rules, payments and forecasts are published. Measured effects are not.

Claims that did not survive checking

Several claims about the flat tax do not match the technical report, the Finance Department or the Corte dei conti. Some came from the press. Some came from our own content plan, which we checked against the same sources.

Our own leads needed correcting. Our plan said the technical report expects new adherents to fall from about 270 to about 130 a year; the 270 is a historic increase in people covered and the 130 is a costing assumption. Our plan described the rise to €300,000 from 1 January 2026 without saying it applies only to new arrivals. A research lead cited Greece's article 5B; the lump sum is article 5A. Our brief described planned article #329 as a tax planning guide; in our content plan it is the guide to retiring in Italy.

What this means for travelers, businesses and analysts

Travelers who visit Italy are not affected by the flat tax. It concerns people who move their residence. For readers weighing a move, the published facts are these. The price depends on the date of transfer of residence under article 43 of the civil code: €300,000 a year and €50,000 per family member for transfers from 1 January 2026, €200,000 for transfers after 10 August 2024, and €100,000 before. From tax year 2027 the regime cannot be combined with the impatriati regime by people who transfer tax residence to Italy (Decree-Law 38/2026); the Chamber's summary does not say how 2026 transfers are treated. The tax agency's page has not been updated, and no agency guidance on the 2026 rule was found. None of this is advice; the conditions and the transition date are matters for a qualified adviser. Our planned guide to the cost of living in Italy covers everyday costs for people who settle.

Tourism businesses and investors in Milan, Rome and other prime markets have no official data on how many wealthy residents arrive, from where or where they settle. The only numbers on nationality, city and property purchases are Assonime's, reported by the press, from a study we could not find. The 2025 and 2026 arrivals under the higher price are not yet in any official series. The government's own revenue estimate assumes the 2026 rise halves the yearly growth in new optants. It is an assumption, and the first data to test it will come from 2026 tax returns.

Journalists and analysts can cite these figures with their sources: €300,000 and €50,000 for transfers of residence from 1 January 2026 (Law 199/2025, art. 1 commi 25-26; technical report, art. 11); €200,000 for moves after 10 August 2024 (Decree-Law 113/2024); 957, 1,242 and 1,631 returns with the new-residents section for tax years 2022, 2023 and 2024 (Finance Department); 1,495 beneficiaries in 2023, 1,070 main and 425 family (Corte dei conti, June 2025); about €315m paid in 2020-2023 (same); €14.5m a year of extra revenue from 2027 (technical report estimate). Do not repeat: that the technical report forecasts a fall in adherents from 270 to 130; that existing users now pay €300,000; that 3,600 people moved under the flat tax in 2025; that about 4,000 people have used it since 2017; that it raised €315m in three years; that Greece's regime is article 5B. The running series finding holds here too: Italy publishes rules, payments and a costing assumption, and the Corte dei conti says the tax agency cannot measure what the regime costs.