
Legal advisory firm Interconsulting notes that the latest Budget Law triples the original 2017 flat-tax entry cost for high-net-worth individuals – from €100,000 to €300,000 – and doubles the per-dependent surcharge to €50,000. The change, effective for anyone establishing residence from 1 January 2026, could reduce the regime’s relative attractiveness compared with rival programmes in Portugal or Greece. (pragma.international)
For investors who decide that Italy still makes sense despite the higher levy, the next step is securing the right immigration paperwork. VisaHQ can streamline this process by handling elective-residence visa applications, stay permits and any attendant document legalisation through its dedicated Italy portal (https://www.visahq.com/italy/), giving applicants and their advisors more bandwidth to focus on the tax strategy itself.
Under Article 24-bis of Italy’s Income-Tax Code, the flat tax exempts foreign income (including capital gains and CFC profits) from ordinary taxation and removes foreign-asset reporting obligations. Uptake has remained strong – 1,150 active beneficiaries in 2025 – but tax advisers predict a segmentation effect whereby only ultra-affluent families will continue to apply, while “mass-affluent” professionals pivot to the impatriati relief.
Interconsulting emphasises the practical importance of the municipal-register date: two transferees arriving on the same assignment contract may pay different substitute-tax amounts if their residence registration formalities straddle 31 December 2025. Mobility managers should therefore schedule housing searches and municipal appointments carefully in Q4 2025.
From a policy perspective, the government hopes higher revenue per beneficiary will offset public concern that the scheme is too generous. Whether the calculus works will depend on whether elite relocators choose to stay or look elsewhere.
For investors who decide that Italy still makes sense despite the higher levy, the next step is securing the right immigration paperwork. VisaHQ can streamline this process by handling elective-residence visa applications, stay permits and any attendant document legalisation through its dedicated Italy portal (https://www.visahq.com/italy/), giving applicants and their advisors more bandwidth to focus on the tax strategy itself.
Under Article 24-bis of Italy’s Income-Tax Code, the flat tax exempts foreign income (including capital gains and CFC profits) from ordinary taxation and removes foreign-asset reporting obligations. Uptake has remained strong – 1,150 active beneficiaries in 2025 – but tax advisers predict a segmentation effect whereby only ultra-affluent families will continue to apply, while “mass-affluent” professionals pivot to the impatriati relief.
Interconsulting emphasises the practical importance of the municipal-register date: two transferees arriving on the same assignment contract may pay different substitute-tax amounts if their residence registration formalities straddle 31 December 2025. Mobility managers should therefore schedule housing searches and municipal appointments carefully in Q4 2025.
From a policy perspective, the government hopes higher revenue per beneficiary will offset public concern that the scheme is too generous. Whether the calculus works will depend on whether elite relocators choose to stay or look elsewhere.










