New Rules for Expatriates from 2024? The draft of the new law on international taxation contains significant changes concerning the eligibility for the special regime for impatriates, effective from January 1, 2024.
The tax benefit available for those returning to Italy after a period of work abroad is reduced to 50% of employment income and assimilated or self-employed work, with an annual limit of 600,000 Euros. The worker can only be employed by a new legal entity not engaged with the previous employer in any control relationship.
The mandatory period of foreign residency before returning is extended to 3 years, and the maximum period for enjoying the tax benefit is limited to 5 years without the possibility of an extension.
Only highly specialized categories of workers, such as levels 1 (legislators, entrepreneurs, and senior management), 2 (intellectual, scientific, and highly specialized professions), and 3 (technical professions) according to the Istat classification of professions Cp 2011, will be eligible for the tax benefit.
The draft decree is raising concerns in the expat community, especially for those workers who had already planned their return to Italy from January 1, 2024.
It appears possible (but not certain yet) that workers who change their residence for civil registration purposes to Italy by December 31, 2023, may still benefit from the tax advantage based on the existing rules.
The purpose of this provision is to encourage the return to Italy of highly specialized personnel and to prevent any evasive practices.
There is hope for the introduction of a transitional regime to safeguard the rights of those who had already planned their return to Italy (source: link).
New rules for expatriates from 2024? For now, Studio BCZ is available to address any inquiries after contacting the interested party.