The €200,000 flat tax attracts the ultra-rich to Italy, the Court of Auditors raises the alarm

The new wave of Paperoni towards the Belpaese has now become a certainty: the €200,000 flat tax does not discourage, indeed it fascinates more and more millionaires and taxpayers with very high global assets. The optional regime provided by Article 24-bis of the TUIR, introduced in 2017, effectively offers a safe harbour from the temptations of the IRS to anyone who transfers residence to Italy from foreign countries, avoiding automatic worldwide taxation on income produced outside Italian borders. And those who had bet on a reversal by the ultrarich towards Italy at the moment seem to have lost despite the flat-rate levy for new entrants rising from 100 thousand to 200 thousand euros. A move by the Meloni government, which, according to data released by the Court of Auditors, does not seem to have slowed down the flow of new Paperoni to Italy in 2024.

The tax regime reserved for the ultra-millionaires provides that those who have not been tax residents in Italy for at least nine of the last ten years can obtain, with the transfer of residence, the application of an annual flat tax on all income produced abroad (excluding certain capital gains for the first five years), without Italy demanding to know the amount of that income or requesting additional taxes on real estate or financial assets held across the border. The extension to family members, with an additional lump sum of 25,000 euro per person, makes the flat tax for Paperoni particularly attractive to large and very wealthy families.

According to the numbers of the equalisation document, in 2023 almost 1,500 new tax residents benefited from the facilitated and attractive regime (of which about 1,070 main taxpayers and 425 family members), guaranteeing the Treasury EUR 117.6 million (of which 107 thousand from main taxpayers and 10.6 million from family members). The table of the Court of Auditors shows how arrivals in Italy have risen over time: from 2020 to 2023 the Paperoni who entered Italy were a total of 2,875 accompanied by 1,108 family members, bringing the total to almost 4 thousand taxpayers. To these must be added the 706 taxpayers who submitted a petition to the Revenue Agency in order to cross the Italian border. Overall, the State collected 315.3 million euro from these super millionaires.

Italy's attractiveness will increase from 2025. The Court of Auditors explains why. London has definitively put an end to the non-domiciled residents' regime ('non-dom'), which for decades has guaranteed global fortune-makers favourable taxation on foreign-source income. As of 6 April 2025, Great Britain will in fact consider the principle of worldwide taxation, effectively forcing hitherto resident high-net-worth individuals to look around: the new British regime offers only four years of benefits to those who have not been resident for the last ten years, after which full taxation on all foreign-source income and capital gains will be triggered.

Hence the alarm of the Corte dei Conti, which warns the government: precisely at the end of the English non-dom regime, a 'tax migration' of Paperoni is expected from London towards the Italian coast. A flow that is likely to increase the number of beneficiaries of the Italian flat tax, but without ensuring a real impact in terms of productive investments or development of the territory. In fact, the Court itself complains that 'no surveys have been carried out to assess the real compliance of the measure with the stated objectives. Italy, in essence, attracts wealth, but there is no transparency or traceability on the real benefits for the real economy