Italy’s Flat Tax Regime is an attractive option for high-net-worth individuals (HNWIs) seeking to optimize their tax situation while enjoying the benefits of residing in Italy. This special tax regime allows eligible individuals to pay a fixed annual tax of €100,000 on foreign-sourced income, regardless of the actual amount earned. Before benefiting from this system, however, it is advisable to seek pre-approval from the Italian tax authorities. Here’s a step-by-step guide on how to obtain pre-approval for Italy’s Flat Tax Regime.
1. Understand the Eligibility Criteria
Before applying for pre-approval, ensure that you meet the eligibility requirements:
You must not have been a tax resident of Italy for at least 9 out of the past 10 years.
The Flat Tax Regime applies only to foreign-sourced income; Italian-sourced income remains subject to regular taxation.
Family members can also benefit from this regime, with an additional €25,000 per dependent.
2. Prepare a Ruling Request (Interpello)
To obtain confirmation from the Italian tax authorities, you need to submit an official ruling request, known as an Interpello. This process allows you to receive a formal opinion on whether you qualify for the Flat Tax Regime before committing to relocation.
Your request should include:
Personal details (name, nationality, and previous tax residency history)
Proof of non-residency in Italy for the last 9 out of 10 years
Details of foreign-sourced income and how it complies with the regime’s requirements
Clarification on worldwide assets and income sources
Statement of intent to become an Italian tax resident
3. Submit the Request to the Italian Tax Authorities
The ruling request must be sent to the Italian Revenue Agency (Agenzia delle Entrate) via certified email (PEC) or registered mail. It is advisable to consult a local tax advisor or lawyer to ensure proper documentation and compliance with Italian regulations.
4. Await the Response
The Italian Revenue Agency typically responds within 120 days of receiving the request. During this period, they may request additional documents or clarifications. If no response is received within this timeframe, the request is considered implicitly approved.
5. Finalize Your Tax Residency in Italy
Once pre-approval is obtained, you must establish tax residency in Italy by spending more than 183 days per year in the country. You should also:
Register with the local Anagrafe (Registry Office)
Obtain an Italian tax identification number (Codice Fiscale)
File annual tax returns to comply with the regime
Conclusion
Seeking pre-approval for Italy’s Flat Tax Regime is a strategic step for HNWIs looking to minimize tax liabilities while relocating to Italy. By following the correct procedure and obtaining confirmation from the Italian tax authorities, you can ensure a smooth transition into this attractive tax structure. Consulting with a tax professional can further simplify the process and maximize benefits under this regime.