29 Agosto, 2019

Rewarding scheme for “highly-qualified” workers that want to relocate to Italy.

The Italian government has recently implemented incentives for “highly-qualified” workers that want to relocate to Italy.

The rewarding system consists in a lowering of the personal income tax base to the extent of 50% and it applies from the tax year in which the transfer of tax residence in Italy occurred and for the next four taxing periods. Please note that “tax residence” requires compliance with at least one of the following conditions for most of the tax period: (a) registration in the Italian population register; (b) centre of vital interests in Italy (family etc.); (c) physical presence on the Italian territory.

The “lavoratori impatriati” lose the tax benefits if the residence in Italy is not maintained in the two years after the transfer, with consequent obligation of return the unpaid taxes together with penalties and interests.

The rewarding system applies to the following subjects, who transfer their fiscal residence in Italy:

1. workers (employees or self-employed – Italian citizens or foreigners):
   • non-residents in Italy in the five previous tax years;
   • who commit to stay in Italy for two years after the transfer of residence;
   • who commit to carry out their business operations mainly in the Italian territory;
2. Additional conditions are required for employees:
   • they must have leadership roles or they must be in possession of highly-qualified requirements;
   • the work must be carried out in a company residing in Italy by an employment relationship.
3. EU citizens, or citizens of non-EU States with which Italy adhered to treaties against double taxation or agreements for the exchange of information on tax matters, that:
   • have graduated and have carried out continuously abroad, in the preceding 24 months, an employment, self-employment or a business activities;
   • carried out a study activity earning an undergraduate or postgraduate specialization.