Art. 24 bis of the Presidente della Repubblica Decree December 22nd, 1986 nr. 917, as modified by Art. 2 of the D.L. August 9th, 2024 nr. 113 (as converted by the L. October 7th, 2024, nr. 143) provides that physical persons who transfer their tax residence to Italy may choose to be subject to a substitutive tax with regard to non-Italian source incomes.
The decree clarifies that as a consequence of that choice, incomes generated abroad are subject to a flat rate substitutive tax on physical persons of Euros 200,000 regardless of the amount of the income, for a maximum period of 15 years.
Interesting to observe that relatives can also join and be subject to a Euros 25,000 tax.
The regulation provides all the specific requirements and limitations to be checked in every specific case.
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