The proposed draft confirms the introduction of the new preferential tax regime in favour of talents who transfer tax residence from the 2024 tax year. The new regime replaces the current regime under Article 16 of Legislative Decree No. 147 of 14 September 2015.
As already foreseen in the draft circulated in recent weeks (see https://belluzzo.net/news/focus-alert/regime-impatriati-il-testo-allesame-della-camera), in addition to a reduction in the tax deduction percentage, stricter requirements for access to the tax relief are introduced, such as a longer period of tax residence abroad of the taxpayer before entering Italy (three years) and a commitment to remain resident in Italy after re-entry for a longer period (five years).
The benefit is now limited to 5 tax periods, eliminating the current system based on various durations differentiated on the basis of requirements relating to the taxpayer’s family or wealth situation.
Moreover, in the event that the worker does not maintain tax residence in Italy for at least 5 years, it is clarified that the benefits will be forfeited and those already enjoyed will be recovered, with interest applied.
Important new elements in the updated text of the draft decree concern the starting date of the new regime. Without prejudice, in fact, to the applicability of the new regime to individuals who transfer their tax residence to Italy starting from the 2024 tax period, with respect to what has already been circulated, a transitional regime is provided: “the provisions previously in force continue to apply in respect of persons who have transferred their registered residence to Italy by 31 December 2023 or, in the case of sporting employment relationships, who have entered into the relevant contract by the same date”
Our professionals continue to monitor developments in the approval process to provide timely updates.
