Article 24-bis of the TUIR provides for the possibility for taxpayers who transfer their tax residence to Italy to apply a flat-rate substitute tax of € 100,000 on income produced abroad in derogation of the principle of world taxation and the application of progressive Irpef rates. The new provisions apply starting from the income relating to the 2017 tax year.
The regime introduced by Article 24-bis of the TUIR is aimed exclusively at individuals and can be activated on an optional basis under specific conditions:
The option can be revoked by the interested party at any time, and in any case ceases to have effect after fifteen years from the first tax period of validity (Article 24-bis, paragraph 4); the possibility of renewal of the scheme upon expiry is excluded (Revenue Agency circular n.17/2017, part III, paragraph 6).
At the request of the person exercising the option, the latter can be extended, throughout the period of the option, to one or more family members as provided by Article 433 of the Italian Civil Code, provided that physical. In this case, the substitute tax due must be increased by an amount equal to 25,000 euros for each tax period and for each family member.
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