Italy retains appeal for super-rich new residents despite tax hike

Italy’s doubling of a “flat” tax on the overseas income of wealthy new residents will curb its tax shelter appeal that risked becoming excessive, but the country’s inheritance tax set-up will continue to draw the ultra-rich, tax advisers said.

Italy on Wednesday doubled the so-called flat tax it applies on the overseas income of wealthy individuals who transfer their tax residence to the country to 200,000 euros ($218,180) per year.

Footballers, including Cristiano Ronaldo, and many finance professionals who left London for Milan after Britain’s departure from the European Union, have taken advantage of the flat tax regime, which was introduced in 2017.

Designed to help the economy by attracting big spenders, the scheme has been blamed for heating up housing demand in Italy’s financial capital and increasing its social divide.

Italy’s tax arrangements are also under the spotlight partly because of Britain’s decision to end in April 2025 its centuries-old “non-dom” tax regime that exempted from taxation the overseas income of UK residents with a foreign domicile, including for inheritance purposes.

“Italy’s government, whilst in favor of the (flat tax)regime, also needs to avoid that the arrival of many new high net worth individuals triggers a political discussion about its fairness,” said Marco Cerrato, a partner at tax law firm Maisto e Associati.

“The 200,000 euro flat tax may reasonably contain the regime to an acceptable overall number of non doms,” Cerrato said.

With inflation soaring, the previous 100,000 euro figure had “started to be perceived as cheap,” he added.

Italy is expected to be the top 2024 European destination for globally mobile millionaires, British investment migration consultancy Henley & Partners said, ahead of Switzerland, Greece and Portugal.

Based on relocations up to June, Henley & Partners expected 2,200 individuals with at least $1 million in liquid investable wealth to move to Italy this year.

Italy’s tax incentives had prompted 1,136 relocations at the end of 2022, and tax advisers estimate the total is currently close to 3,000.

Inheritance

Marco Palanca, a partner at international law firm Simmons&Simmons who heads its Italian tax department, said the changes could prompt some of their clients who work in the European fund management industry to reconsider Italy as a destination, given the fluctuating nature of their foreign earned income.

But Italy’s move will have little impact on people with a net worth of at least 7 million euros, Vito Di Pede, a tax adviser at Milan’s Studio Rock tax and law firm, said.

“Italy remains a very good option for such individuals,” he said pointing to the importance of its inheritance tax provisions.

Britain’s new Labour government has proposed scrapping temporary relief measures for non-doms including one that would allow them to set up trusts to shield their foreign assets from inheritance tax.

Outside the non-dom regime, Britain’s inheritance tax rate is 40 percent above a 325,000 pound threshold.

By contrast, the Italian inheritance tax rate is between 4 percent and 8 percent applied above various thresholds, but the flat tax regime exempts foreign assets from inheritance tax.

The regime is for a 15-year period and can be extended to family members paying 25,000 euros per person.

Palanca said Italy was attracting new ultra-wealthy residents not just from the UK but also Switzerland, where a proposal has been put forward to impose a 50 percent inheritance tax on assets worth more than 50 million Swiss francs to fund the country’s green transition.

Italy’s flat tax regime also works well in combination with a wide number of bilateral agreements Rome has in place to avoid double taxation of income and capital, unlike the situation in a number of other countries, Di Pede said.

“It’s obvious the changes may have caused some alarm, but all in all Italy still offers a very advantageous set-up,” he added.