Italy has emerged as Europe’s top destination for high‑net‑worth individuals, driven by a capped flat‑tax regime for foreign income and an investor‑visa program with the continent’s lowest serious entry threshold.
Flat‑Tax Regime (Article 24‑bis)
- Applies to individuals who become Italian tax residents after spending at least nine of the previous ten years abroad.
- Replaces ordinary taxation on all foreign‑source income with a single annual payment for up to 15 years.
- The payment is flat regardless of income size: €100 000 when the regime launched in 2017, €200 000 from August 2024, and €300 000 after the 2026 Budget Law (effective 1 January 2026).
- The family‑member surcharge doubled to €50 000 under the 2026 rules.
Impact:
- Court of Auditors data show 1 500 participants in 2023, a 31.6 % year‑on‑year increase, and €315 million in revenue recorded between 2020‑2023.
- Henley & Partners estimates roughly 4 000 sign‑ups since 2017, including family members.
- Despite the €300 000 hike, interest remained strong among ultra‑high‑net‑worth families, whose marginal rates elsewhere can reach 45‑50 %.
Design features supporting resilience:
- Grandfathering: earlier entrants keep their original rate (e.g., a 2017 participant still pays €100 000).
- No mandatory investment requirement attached to the flat‑tax election.
Migration Flow from the United Kingdom
- The UK abolished its non‑dom regime in April 2025, triggering a net outflow of 16 500 millionaires that year—the largest recorded for any country.
- Prominent leavers to Milan include Goldman Sachs vice‑chairman Richard Gnodde, Aston Villa owner Nassef Sawiris, consumer‑goods executives Elio Leoni‑Sceti and Bart Becht, and Icelandic billionaire Thor Björgólfsson.
- Lionard Luxury Real Estate reported a 260 % surge in UK purchase inquiries for Milan between 2023 and 2025, versus 42 % growth across the broader Italian market.
Investor Visa (Golden Visa)
| Investment option | Minimum amount |
|---|---|
| Innovative startup | €250 000 |
| Italian company | €500 000 |
| Government bonds | €2 million |
| Donation | €1 million |
- No minimum stay requirement; the investment is required only after visa approval.
- 209 applications were filed by December 2025, reflecting a 62.6 % compound annual growth rate since 2018.
- Decisions are typically issued within 30 days.
Comparative context:
- Spain closed its golden‑visa scheme in April 2025.
- Portugal’s fund route now starts at €500 000.
- Greece’s “prime zones” require €800 000.
- Italy therefore offers the lowest serious entry point among Western European programs.
Additional Fiscal Incentives
- Foreign pensioners in towns up to 30 000 residents pay a 7 % flat rate on all foreign income for ten years (expanded in April 2026 to 74 new towns).
- Working relocators can claim the “impatriati” exemption: 50 % reduction on Italian employment income up to €600 000, rising to 70 % in southern regions.
Outlook
The combination of a rising flat‑tax price, sustained application growth, and complementary residency options suggests strong product‑market fit. Families considering relocation from high‑tax jurisdictions are advised to act before further recalibrations, as early planning influences residence timing, advance tax rulings, and the interaction between the flat‑tax election and the investor visa.
Source article: www.imidaily.com
