Researchers, events relevant to the extension of the option

The option to extend the regime for teachers and researchers who moved to Italy before the 2020 tax year must be exercised - by paying the 10% or 5% substitute tax - on the occasion of each relevant event, such as the birth of a child. In general, therefore, each child entails a new payment to access the further extension of the regime. An exception is the case where the next child is born before the 30 June deadline by which the tax relating to the extension already due must be paid: in this case, the extension can be 'merged', avoiding duplication of costs. This is the main clarification contained in the answer to interpello no. 80/2026 of 18 March 2026. The Inland Revenue Agency has resolved the interpretative doubt raised by a university professor who, after having been resident abroad, benefited for the period 2019-2022 from the facilitative regime in favour of teachers and researchers governed by article 44 of Decree-Law no. 78/2010. In this regard, it is worth recalling that the benefit in question, which consists in the detaxation of 90% of the teacher's or researcher's salary, unlike in the case of the expatriate regime, has not undergone any change following the recent tax reform. In the present case, after having benefited from the regime in question for the ordinary period, the petitioning taxpayer exercised in April 2023 the option to extend the regime to a total of eight years, paying the substitute tax by the deadline of 30 June 2023, in the presence of a minor child born in 2018. A second child was then born during 2023, but after the 30 June deadline. The taxpayer believed that the payment already made was sufficient to directly access the longer extension (equal to eleven tax periods in total), arguing that the requirement of the presence of two children had to be verified with reference to the entire tax period in which the birth occurred and not at the time of payment of the substitute tax. Instead, the Inland Revenue Agency clarified that the requirement must be met at the time the option is exercised, which coincides with the payment by 30 June. In particular, the presence of one or more children must exist on that date. In the present case, therefore, the taxpayer had only one child on 30 June 2023 and can only access the first extension of the regime, a new payment being necessary to benefit from the further extension.