Since 2017, Italy has attracted major international fortunes with one of Europe’s most competitive tax regimes. In 2026, the flat rate rises to 300,000 euros per year, a revaluation that takes nothing away from the appeal of the scheme for those considering settling on the Costa Smeralda or in Cagliari. Clear decryption, without detours, to understand what the flat tax really changes for you.
In summary
The Italian flat tax allows new residents to pay a fixed tax of 300,000 € per year on all their foreign income for a maximum of 15 years.
This regime is reserved for people who have not been tax residents in Italy for at least 9 of the last 10 years, and can be extended to family members for 50,000 € per person.
Sardinia brings together all the ideal conditions to activate this scheme: exceptional living environment, high-end real estate stock and access to an alternative 7% regime for retirees.
The Italian Flat Tax, in Brief
Officially, it is called the regime for new residents (regime dei nuovi residenti), provided for in article 24-bis of the TUIR, the Italian tax code. The principle is deceptively simple: a newcomer transfers their tax residence to Italy and pays an annual fixed tax on all their foreign-source income, regardless of amount.
No progressivity, no surprises. Where classical Italian IRPEF climbs to 43% and where French IFI or IR can weigh heavily on international wealth, the flat tax replaces everything with a fixed amount.
Figures to Know for 2026
Italy’s 2026 finance law raised the fixed rate. Here is the essential:
| Element | Amount 2026 |
|---|---|
| Annual fixed tax on foreign income | €300,000 |
| Fixed tax per family member | €50,000 / person |
| Maximum regime duration | 15 years |
| Tax history required | Non-resident 9 of last 10 years |
| Italian-source income | Subject to classical IRPEF |
Important: these 300,000 euros apply only to newcomers as of January 1, 2026. Beneficiaries already in the regime retain their original rate, 100,000 euros for those who opted before August 2024, 200,000 euros between August 2024 and December 2025.
A Trajectory That Says Much
The fixed rate has continued to rise. To understand the scheme’s logic:
| Year | Rate |
|---|---|
| 2017—2024 | €100,000 |
| August 2024 | €200,000 |
| January 2026 | €300,000 |
| Status | Regime maintained |
The message sent by Rome is clear: the scheme remains open, but now targets clientele with confirmed wealth. The operation’s profitability remains, provided foreign income reaches a relevance threshold, above approximately 1.5 million euros annual income, the calculation becomes particularly advantageous.
Who Can Benefit from the Regime?
The regime is intended for individuals who transfer their tax residence to Italy in the sense of article 43 of the Italian Civil Code, that is, who establish their permanent residence on Italian soil.
Three cumulative conditions:
- Not have been a tax resident in Italy for at least nine of the ten years preceding the transfer.
- Effectively transfer their permanent residence to Italy (not just a mailbox).
- Exercise the option in the first Italian tax return, or via advance ruling with the Agenzia delle Entrate.
- The advance ruling, though not mandatory, is strongly recommended. It secures eligibility before installation and avoids any subsequent administration dispute.
What the Flat Tax Really Covers
Beyond the fixed tax on foreign income, the regime offers ancillary advantages often underestimated:
- Exemption from the reporting obligation for financial assets held abroad (RW form).
- Exemption from IVIE and IVAFE wealth taxes on real estate and financial property located outside Italy.
- Complete exemption from inheritance and gift taxes on foreign-located property for the regime’s entire duration.
- Possibility to extend the regime to family members for 50,000 euros per person : spouse, children, parents.
- This last point is decisive. For a wealthy family with diversified international wealth, controlled-cost transmission often represents the most structural argument.
Limitations to Anticipate
No tax regime is without blind spots. Three points merit particular attention:
Italian-source income remains normally taxable
Any income generated in Italy, rentals, professional activity conducted there, dividends from Italian companies is subject to progressive IRPEF, with brackets ranging from 23% to 43%.
Qualified securities gains are excluded the first five years
Capital gains from qualified participations held abroad are not covered by the fixed rate during the regime’s first five years. A significant sale must therefore be planned accordingly.
No split year
Italy does not practice « split year. » If you transfer your residence mid-year, tax effects take place only on January 1 of the following year. This requires precise calendar planning to avoid a fiscally costly blank year.
Why Sardinia Is Particularly Suited to This Regime
The flat tax applies across Italian territory, but Sardinia brings together conditions rarely combined elsewhere.
First, the quality of living environment. The island offers one of Europe’s best-preserved coastlines, exceptional climate over ten months of the year, and population density among the country’s lowest, a rare luxury for those seeking discretion and tranquility.
Next, high-end real estate supply. From Porto Cervo to Villasimius, passing through Cagliari’s historic villas, Sardinia has an exceptional property stock that can serve as support for the permanent residence required by the regime.
Finally, and this is a major asset: Sardinia is among eight southern regions eligible for the alternative regime for foreign retirees, the 7% flat tax. For retirees with more modest wealth who do not meet the 300,000 euro threshold, this parallel scheme constitutes an equally attractive gateway to the island.
How OGGI Accompanies This Project
Activating the flat tax requires coordinating several expertises: tax lawyer for the advance ruling, notary for the property transaction, land agent for the property itself, tax expert for the first Italian return. This is precisely the orchestration that Murielle and Gérard handle at OGGI.
Our role is not to provide tax advice, that is the purview of sworn professionals with whom we work. Our added value lies in making connections, calendar coordination and securing each step: finding the property that will meet permanent residence requirements, articulating the transaction with the tax calendar, and ensuring installation occurs properly.
In Summary
The Italian flat tax remains, in 2026, one of the most structural schemes for anyone considering patrimonial expatriation in Southern Europe. The rise to 300,000 euros eliminates intermediate profiles, but confirms the regime’s permanence for major fortunes, precisely those that constitute the core target of high-end Sardinia.
To go further, our upcoming articles address Franco-Italian succession tax, the real cost of real estate purchase in Italy in 2026, and the alternative 7% regime for retirees.
Frequently Asked Questions About Italian Flat Tax
Must I really live in Italy full-time to benefit from the flat tax?
No, but you must establish your habitual residence there in the sense of Italian Civil Code (article 43). Concretely, Italy must become your center of personal interests and you must spend more than 183 days per year there. Simply owning property is not enough: you need effective and demonstrable presence, verifiable notably via energy consumption or local invoices.
Can my spouse and children benefit from the regime with me?
Yes. The regime can be extended to family members (spouse, children, parents) for an additional fixed fee of 50,000 € per person per year. This represents considerable advantage for families with diversified income within the household, particularly when children themselves receive dividends or capital income.
What happens if I leave Italy before 15 years?
The regime ends on your effective departure date, without retroactive penalty. You become a non-resident for Italian tax purposes, and your worldwide income exits the Italian purview. However, the option cannot be reactivated subsequently: you benefit from the flat tax only once in your life.
Is my rental income from a Sardinian villa covered by the flat tax?
No. Rental income from property located in Italy is Italian-source income, thus taxed under the classical regime (progressive IRPEF or cedolare secca at 21%). Only foreign-source income (foreign rentals, dividends, interest, capital gains) enters the 300,000 € fixed rate.
How long does it take to activate the regime after my installation?
The option must be exercised in the first Italian tax return, to be filed before September 30 of the year following residence transfer. We recommend, however, filing an advance ruling with the Agenzia delle Entrate before even installing, to secure eligibility—the response typically comes within 120 days.
Why use a property scout for this type of project?
Activating the flat tax requires a property meeting permanent residence requirements, but also your life project over 15 years. With the high-end Sardinian market being largely off-market, a scout like OGGI accesses unlisted properties and coordinates expertises (notary, tax specialist, surveyor) to secure the operation end-to-end.
This article is informational in nature. It constitutes neither tax advice nor legal advice. For any decision relating to a tax residence transfer, we recommend consulting a tax lawyer specialized in international mobility.
