The Budget Law for the year 2026 has amended Article 24-bis of Law No. 917 of 1986 concerning the “Option for a substitute tax on income produced abroad by individuals who transfer their tax residence to Italy.”

As of 1 January 2026, individuals who transfer their tax residence to Italy may opt to pay tax on income produced abroad through a flat-rate substitute tax of € 300,000, regardless of the amount of income earned, provided that they have not been tax-resident in Italy during the previous ten years.

This amount is reduced to € 50,000 per tax period for each family member.