Brain return, 50% tax also for smart workers

Returning to Italy and continuing to work in smart working for a company based in Germany or England, or any other country for that matter, opens the way, however, to a 50% discount on taxes to be paid in the next five years. This discount is recognised by the tax authorities with the facilitated regime for impatriates, but only under one very specific condition: the work activity must be carried out predominantly on Italian territory.

The clarification came directly from the Agenzia delle Entrate (Inland Revenue Agency) asked about the possibility or otherwise of benefiting from the facilitated regime for the return of brains by a girl with a master's degree in business engineering who had moved to the United Kingdom at the end of 2020 and, in March 2021, had started working as a Strategic Solutions Architect for a company with its registered office in the UK and then registered with the Registry of Residents Abroad six months later. The employee in the following years, while changing jobs, continued her work in London until September 2025 when she decided to return to Italy. All this with a new Italian-based employment contract for a company with its registered office in Germany. A job with a Level 1 classification in the national collective agreement for commerce, with an open-ended contract and an office in Milan, and the possibility of working remotely.

The Entrate's answer with Interpretation No. 2/2026 reiterates, as mentioned, that an Italian employer is not necessary: the prevailing place of work in Italy counts, even in smart working for a foreign company. The prerequisites for obtaining the IRS rebate include not having had Italian tax residence in the previous three years, a high level of qualification and a commitment to remain resident for at least two years (extendable). The relief applies from the tax year following the year of return (2026 for those returning at the end of 2025) and for four years thereafter.

Although revised by the Meloni government, the impatriate regime still grants an important discount on taxes due to the tax authorities. Firstly, income from employment or self-employment is taxed at 50 per cent (out of 100,000 euro of taxable income, the tax authorities tax 50 per cent), however within the limit of 600,000 euro per year. The way the discount is structured, this is applied in the tax return, also by virtue of the fact that the worker who has returned to Italy has an employer based across the border anyway.