The legislative decree scheme. on international taxation, implementing Law 111/2023, transmitted to Parliament, formalizes the changes for expatriated workers pursuant to art. 16 of the Legislative Decree. 147/2015.
The relief will only concern workers with a higher level of specialization and qualification and will be limited in terms of the percentage of tax-free income (50% compared to the current 70%, or 90% for transfers to the South), the amount of income subsidized (with the introduction of a ceiling of 600.000 euros), as well as the required requirements of previous residence (three years); a minimum period of Italian residence after impatriation of five years is also required.
The changes concern those who transfer their tax residence to Italy from 2024, with the exception of those who transfer their registered residence to Italy by 31.12.2023 (i.e., for sports employment relationships, for those who stipulate the relevant contract by that date).
The current and more favorable regime applies to the latter.
