Residence history
Confirm the nine-out-of-ten-year nonresident history before treating the regime as available.
Italy tax planning
For the right American household, the regime can create a defined Italian charge on qualifying foreign income. The residence history, income map and arrival year have to be right before the move.
The direct answer
Italy's high-net-worth new-resident regime is designed for people who have spent most of the previous decade outside Italy. For people becoming Italian tax resident from 2026, the annual substitute tax is EUR300,000 for the principal applicant. Italian-source income remains subject to ordinary Italian rules.
The figure alone does not determine whether the election works. The value depends on what income is foreign-source, what remains Italian-source, which countries should be excluded from the election, how gains and distributions are timed, and how the US return interacts with the Italian position.
Fit test
Confirm the nine-out-of-ten-year nonresident history before treating the regime as available.
Map dividends, gains, trusts, partnerships, carried interests, pensions and business income by source.
Property income, local work and other Italian-source income sit outside the substitute-tax perimeter.
Model US filing, credits, entity reporting and the treatment of each income stream before election.
What the headline misses
Private-office sequence
The useful order is to map the household, confirm the residence route, obtain an Italian and US tax analysis, set the arrival year, prepare banking and source of funds, then choose the home. Read the elective residence guide and post-exit Europe guide for the adjacent decisions.
Plain answers
Yes. Eligible new Italian tax residents can elect an annual substitute tax on qualifying foreign-source income. Italian-source income remains under ordinary Italian rules.
The central residence-history condition is generally that the individual was not an Italian tax resident for at least nine of the ten tax years before the move. The full eligibility and income analysis should be completed before arrival.
No. US citizens generally continue filing US tax returns on worldwide income. The Italian election and US position must be coordinated.
Blueprint output
Private consultation
Bring the intended move date, income map, family profile and target cities. We will identify the decisions that need to be settled before arrival.
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