by Stefano Serbini.
Article 5 of Law Decree No. 34 of 30 April 2019 amends the existing tax regime provided for workers (sportsmen included), lecturers and researchers, improving a legislation that was already favourable. The new provisions will be applicable to listed individuals who move their tax residence to Italy as of 1 January 2020 and provides for a 70% exemption of their Italian source employment, self-employment and business income (for sportsmen the exemption is limited to 50% and they are also due to pay an annual contribution equal to 0.5% of the taxable income).
The new regime is granted to individuals who will not have been resident in Italy in the two years preceding the year in which the residence is to be transferred and applicants no longer need to fulfil the requirement to perform managerial and executive roles or be highly qualified/specialized employees. The Decree provides also for an extension of the timeframe of the regime if specific requirements are met (the extension varies depending the category of the listed individuals and on other conditions).
Last, but not least, it is worth noting that the amended legislation also facilitates the repatriation of Italian citizens who have not enrolled in the register of Italian citizens living abroad (AIRE). Failing to fulfil this formality was a major obstacle to workers/lecturers/researches moving back to Italy under the former legislation. Now, the only requirement that they will need to comply with is being resident in a country with which Italy has a tax treaty that is in force.
To learn more, see the Article published on European Taxation, October 2019, ‘Recent Legislation on the Tax Regime Applicable to Inbound Workers, Qualified Lecturers and Researchers’ (Vol.59: 10 -2019).