Italy’s Lump-Sum Tax Regime: Why Article 24-bis Still Matters in 2026
- Marianna Penna
- Apr 7
- 3 min read
For internationally mobile high-net-worth individuals, Italy’s Article 24-bis regime remains one of the most interesting residence-planning tools in Europe. Introduced to attract new wealthy residents, it allows qualifying individuals who move their tax residence to Italy to pay a fixed annual substitute tax on foreign-source income and gains, rather than ordinary Italian progressive income tax on those amounts. Italian-source income remains taxed in the usual way.
The regime has become even more relevant since the end of the UK non-dom regime on 6 April 2025. For many internationally connected individuals now reconsidering where to live and how to structure their affairs, Italy offers a framework that combines tax certainty with long-term planning stability. For the right client, it can be a highly attractive alternative.
That said, the numbers changed significantly from 1 January 2026. For new entrants, the annual charge is now €300,000, with an additional €50,000 per qualifying family member. Earlier entrants are grandfathered at their previous rates, which remains an important planning distinction over the possible fifteen-year life of the regime.
The regime can still be compelling because its value is not limited to the fixed tax charge alone. A valid Article 24-bis election also disapplies IVIE on foreign real estate, IVAFE on certain foreign financial assets, and the quadro RW foreign asset reporting obligation. For clients with substantial offshore wealth, those exemptions may represent a material part of the overall benefit. In addition, foreign assets may fall outside the scope of Italian inheritance and gift tax for an Article 24-bis elector, which can be especially relevant in longer-term wealth and succession planning.
However, Article 24-bis is not a regime to approach casually. To qualify, an individual must transfer tax residence to Italy, must not have been tax resident in Italy for at least nine of the previous ten tax years, and must make a valid formal election. In many cases, a preventive ruling request to the Italian tax authorities is advisable before the move takes place, as it can provide useful certainty and force a proper review of the wider planning picture.
There are also important technical traps. The regime does not allow foreign tax credits against the substitute tax, so withholding tax exposure in other jurisdictions must be reviewed carefully. The country exclusion option can sometimes improve the result where overseas taxes would otherwise be irrecoverable. There is also a five-year restriction on gains arising from the disposal of qualifying participations in foreign entities, and the annual payment deadline of 30 June is absolute: if it is missed, the regime is lost permanently.
The central point is simple. At €300,000 per annum, Article 24-bis is no longer a broadly attractive headline regime for everyone. But for individuals with substantial foreign-source income, international assets, and cross-border succession considerations, it may still represent exceptional value. The right answer depends on the client’s income profile, asset structure, family position and long-term objectives.
At LEXeFISCAL, we see Article 24-bis not as a lifestyle talking point, but as a serious strategic planning tool. In the new post-non-dom world, the question is not simply whether Italy is attractive. It is whether the regime is right for the individual behind the move.
Otherwise you can download the article below:
Dr Clifford John Frank, LLM(Tax) PhD HDipICA ATT
Senior Partner
LEXeFISCAL LLP
Suite 428a, 4th floor,
33 Cavendish Square, London
Tel: +44 (0)20 8092 2111
Website: www.lexefiscal.com
Disclaimer
This blog post is for general information purposes only. It does not constitute legal or tax advice and should not be relied upon without seeking professional advice tailored to your specific circumstances. Tax law is complex and constantly evolving. Each person’s situation is unique. LEXeFISCAL LLP accepts no liability for reliance on the general commentary contained in this publication.
Comments