Italy’s Agenzia delle Entrate has issued Ruling No. 2/2026 clarifying that a returning Italian engineer who now works fully remotely for a new foreign employer can qualify for the revamped Impatriati tax regime from the 2026 tax year. The response, published on 12 January and widely analysed by tax advisers on 15 January, settles market doubts about whether cross-border remote employment meets the ‘operating in Italy’ test introduced by Decree-Law 209/2023. (studiodorighelli.it)
Key points. • Eligibility hinges on tax residence in Italy and physical performance of work from Italian soil, irrespective of the employer’s location. • The 50 percent income exemption (down from 70 percent under the old rules) applies for five years, provided the worker has been non-resident for at least three of the previous seven years and holds a bachelor-level degree. • If the employer cannot apply the relief via payroll, the employee may claim it in their annual tax return.
Corporate relevance. Multinationals operating virtual talent pools can now confidently second Italian nationals back home without losing tax efficiency. Mobility teams should update assignment-cost projections and shadow-payroll instructions to reflect the narrower 50 percent rebate and the new obligation to track presence days digitally.
![Tax agency confirms ‘Impatriate’ relief extends to remote employees of foreign firms]()
For those tackling the practicalities of relocating talent, VisaHQ can smooth the visa and documentation process. Through its dedicated Italy portal (https://www.visahq.com/italy/), the platform provides step-by-step guidance and application support for residence permits, family visas and more, helping employers and employees alike focus on maximizing the Impatriati benefits rather than wrestling with paperwork.
Practical implications. • Remote workers must keep evidence of effective workdays in Italy (VPN logs, travel records). • HR should issue Italian payslips or withholding certificates even if the employment contract is governed by foreign law. • Companies should revisit permanent-establishment risk assessments, as the ruling focuses on personal taxation and not corporate nexus.
Strategic outlook. The decision may accelerate ‘work-from-Italy’ requests from diaspora talent. Regions offering additional incentives—such as Calabria’s €1,000 relocation grant—stand to benefit.
Key points. • Eligibility hinges on tax residence in Italy and physical performance of work from Italian soil, irrespective of the employer’s location. • The 50 percent income exemption (down from 70 percent under the old rules) applies for five years, provided the worker has been non-resident for at least three of the previous seven years and holds a bachelor-level degree. • If the employer cannot apply the relief via payroll, the employee may claim it in their annual tax return.
Corporate relevance. Multinationals operating virtual talent pools can now confidently second Italian nationals back home without losing tax efficiency. Mobility teams should update assignment-cost projections and shadow-payroll instructions to reflect the narrower 50 percent rebate and the new obligation to track presence days digitally.
For those tackling the practicalities of relocating talent, VisaHQ can smooth the visa and documentation process. Through its dedicated Italy portal (https://www.visahq.com/italy/), the platform provides step-by-step guidance and application support for residence permits, family visas and more, helping employers and employees alike focus on maximizing the Impatriati benefits rather than wrestling with paperwork.
Practical implications. • Remote workers must keep evidence of effective workdays in Italy (VPN logs, travel records). • HR should issue Italian payslips or withholding certificates even if the employment contract is governed by foreign law. • Companies should revisit permanent-establishment risk assessments, as the ruling focuses on personal taxation and not corporate nexus.
Strategic outlook. The decision may accelerate ‘work-from-Italy’ requests from diaspora talent. Regions offering additional incentives—such as Calabria’s €1,000 relocation grant—stand to benefit.
