Preferential tax regime for “inbound workers”, Italy becomes highly attractive

Published 14 June 2019 by de Bedin & Lee studio legale associato

The Italian law has always provided for a preferential tax regime for the employment incomes of the inbound workers, aimed at attracting in Italy non-resident employee and self-employed workers.

The law decree n. 34/2019 (commonly called, “Growth Decree”), recently issued, has enhanced the preferential tax regime.

Here below, few brief information on the changes introduced by the Growth Decree.

What exactly has changed?

The Growth Decree has enhanced the preferential tax regime by extending it to the individual business income and also by decreasing the period for which the individual must not have been a tax resident in Italy before the transfer.

The new legal discipline has also increased the amount of tax exemption, has eliminated the condition that the employee must cover a managerial role or be highly specialized and has extended the duration of the tax exemption in some cases (e.g. dependent children or a home property in Italy). In this last case, the exemption for the additional year is reduced.

Some requirements remained the same

In fact, to enjoy the tax exemption, the employee has to remain tax resident in Italy for a certain amount of time, has to work in the Italian territory for about half of the year and has to be hired by an Italian tax resident (but not only, in reality).

The preferential tax regime applies also to the “inbound workers” (EU citizens or citizens of a Country with whom Italy has a Double Tax Treaty or alternatively, a Tax Exchange of Information Agreement) who meet some specific requirements such as holding a university degree of at least three years of durations and perform and employment or self-employment activity in Italy, and have performed a work activity, or alternatively have spent a study period outside Italy for at least 24 months before the transfer to Italy.

The Decree enhancement incentives are applicable only to individuals considered tax resident in Italy as from tax year 2020 (i.e. eligible individuals are advised to wait until after July, the 3rd, 2019, before transferring their residence, in order to benefit from the tax regime enhancement).

For any further detail we invite you to read the attached table which contains a comparison between the old and the regulation (e.g. before and after the Growth Decree).

 

In bold the changes introduced by the Growth Decree

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