Statements 2025

Tax, a paradise for 52,200 taxpayers in Italia

Among impatriates, Paperonians and pensioners in the South, the number of people attracted by the tax rebate from abroad grows by 10%

by Marco Mobili and Giovanni Parente

 Pcess609 - stock.adobe.com

4' min read

Translated by AI
Versione italiana

4' min read

Translated by AI
Versione italiana

In the hell of constantly changing paragraphs and laws, where tax reform has promised to bring greater legal certainty, there are those who find their corner of paradise. No one would ever say so, but Italia confirms itself as a corner where there are those who can profit from their tax advantage: a community of 52,200 taxpayers, who have taken advantage of the various existing concessions according to the data of the tax returns submitted in 2025 (tax year 2024) released by the Department of Finance. A favourable treatment reserved by various provisions that have stratified over the years. Provisions that look to those who move to Italy from abroad and especially to those who have significant assets and therefore a greater spending capacity. Of course, the effort made to reduce the tax burden on Italian taxpayers should also be mentioned, first with the reduction from four to three tax rates (effective from the 2024 tax year), the new tax wedge cut for employees, and most recently with the reduction of the second tax rate from 35% to 33% effective from 1 January.

Impatriates

Yet the foreign attraction schemes have aroused almost more debate and interest among insiders than the Irpef adjustments for the generality of the almost 43 million Italian taxpayers. There are mainly two concessions, with differentiated requirements and objective perimeter, that are catalysing attention and grinding out numbers in adhesions. On the one hand, there are the impatriates, who represent about 86% of the community of beneficiaries and who have reached almost 45 thousand adhesions. The impact is articulated among the changes that have affected the scheme, which allows those who meet the required criteria to enter or re-enter Italy and have a substantial tax deduction on income produced in our country.

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The 2025 declarations in spite of a generalised growth (+9.4%) on the cumulative figure of all the 'articulations' provided for by the successive regulations show the first signs of the tightening imposed by one of the implementing decrees of the tax delegation (Legislative Decree 209/2023), since the 50% taxability concerns 1,617 new entrants and the 40% taxability only 455. This is another reason why it will be interesting to verify the trend in the statistics of next years' declarations. In any case, an indirect confirmation that the entire regime looks to taxpayers with average incomes far above the general average of Italian taxpayers (EUR 25,820) emerges that the average gross income for this category is just under EUR 121,000.

Neoresidents

The other benefit that fuels the tax debate is that of the Paperoni, or in technical jargon, the newly resident. The flat taxation - approved under the Renzi government with the 2017 manoeuvre (law 232/2016) concerns only foreign incomes and has seen the bar progressively rise: from the initial 100 thousand euros, it rose to 200 thousand with the Omnibus decree of summer 2024 and to 300 thousand with the latest manoeuvre in force from 1 January 2026 (naturally the higher thresholds apply to new 'arrivals'). Here, the numbers of the tax statistics are to be compared with those with a higher level of detail that the Court of Auditors provides every year on the occasion of the report on the general state accounts.

In the 2025 declarations, the account of the Scrooges (which includes both the main taxpayer and family members who can count on reduced taxation, even if it has risen from EUR 25,000 to EUR 50,000 since the beginning of 2026) rose to 1,631, which still marks a continuous growth of options and in particular of 9.1% compared to the figure provided by the accounting judges for the 2023 tax year.

But how much is this attractive regime worth to the Italian tax authorities? It is safe to say that they are crumbs compared to the declared net Irpef (for the 2024 tax year 197.4 billion). Between 2020 and 2023, payments of about 315 million arrived (287.5 for main taxpayers and about 27.7 million for family members). The counter argument is that these individuals with their spending capacity can bring other revenues, such as indirect taxes on consumption, or can encourage new investments in Italia. But there is a distorting effect highlighted by the Court of Auditors, which so far no government, regardless of political colour, has ever corrected: 'The discipline appears mainly aimed at favouring subjects who can draw sources of income from more than one country and who transfer their residence to Italia for work purposes (as in the probably frequent case of professional sportsmen), residential or other reasons, without however requiring - as should have been expected - an effective and tangible link with the realisation of productive investments in our country'. Moreover, it is not even known 'the amount of foreign income on which the substitute tax acts, nor the ordinary taxes that would actually have to be levied on such income in the absence of the substitute regime'. In the meantime, the tax decree - now being converted by the Senate - has eliminated the possibility of opting for the new impatriates' and Paperoni's regime from 2027.

Foreign pensioners

Then there is the flat tax at 7 per cent for foreign pensioners moving to southern regions or to municipalities affected by the earthquakes in central Italia. Here, too, we cannot speak of a success: 933 options, even though the 2025 declarations showed a leap forward of almost 39 per cent. The declared tax stops at 4 million. In the meantime, however, the SME law in force since 7 April has tried to widen the mesh a little, raising the pool of municipalities in which it is possible to move to take advantage of the facility from 20,000 to 30,000 inhabitants.

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