The country has continued to attract affluent new residents despite substantial increases in the cost of its special tax regime, supported by a fixed tax on foreign income, a comparatively accessible Investor Visa and a stable legal framework for existing participants.
For much of the last century, wealthy families leaving high-tax jurisdictions generally focused on Switzerland, Monaco and the United Kingdom. That pattern has shifted. Switzerland has become more cautious about foreign wealth, Monaco has limited capacity, and the United Kingdom replaced its non-dom regime with worldwide taxation in April 2025.
Italy has increasingly benefited from this changing environment. Over the past 18 months, prominent bankers, industrialists and billionaires previously based in London have moved to Milan. The country has developed a broad relocation framework combining favourable taxation for new residents with immigration routes for non-EU nationals.
Italy received a net inflow of 3,600 migrating millionaires in 2025, the largest figure in Europe and the third-largest worldwide after the UAE and the United States. Switzerland recorded 3,000 millionaire arrivals, Portugal 1,400 and Greece 1,200.
The figures came during a record period for global wealth migration. A total of 142,000 millionaires relocated worldwide in 2025, while 165,000 are expected to move in 2026. Italy captured a greater share of this movement than any other European jurisdiction.
Italy’s Flat-Tax Regime
Article 24-bis of Italy’s tax code provides a flat-tax option for qualifying individuals who become Italian tax residents. To use the regime, an individual must have spent at least nine of the preceding ten years outside Italy.
Eligible taxpayers may replace ordinary taxation of foreign-source income with a fixed annual payment for a period of up to 15 years. The payment does not vary with the level of foreign income: the annual amount is the same whether foreign income totals €1 million or €50 million.
The annual charge has increased several times since the regime began:
The charge for qualifying family members also increased to €50,000.
The full impact of the 2026 increase is not yet known, as tax-declaration data are published with a two-year delay. Government forecasts assume that the €300,000 rate could reduce the number of future entrants by approximately half. Initial signs have not indicated a reduction in demand, particularly among ultra-high-net-worth families for whom the fixed annual charge remains lower than marginal tax rates of 45% to 50% elsewhere in Europe. The 2024 increase likewise did not result in an apparent decline in relocations.
Nearly 1,500 individuals participated in the regime in 2023, an increase of 31.6% from the previous year. Revenue from the programme reached €315 million between 2020 and 2023. Since 2017, total participation, including family members, is estimated at approximately 4,000.
A key element of the regime is the continued application of earlier tax rates to existing participants. Individuals admitted in 2017 remain liable for the original €100,000 annual charge, while those joining in 2026 pay €300,000. The government also abandoned a proposal to introduce a mandatory investment requirement for the flat-tax regime.
The Impact of UK Tax Changes
The United Kingdom has become a significant source of incoming wealth for Italy. After the non-dom regime ended in April 2025 and worldwide taxation took effect, the UK experienced a net outflow of 16,500 millionaires during the year. This was the largest recorded annual outflow and more than twice the figure recorded for China.
Milan has been chosen by several well-known individuals who previously lived in London, including Richard Gnodde, vice chairman of Goldman Sachs; Aston Villa owner Nassef Sawiris; consumer-goods executives Elio Leoni-Sceti and Bart Becht; and Iceland’s first billionaire, Thor Björgólfsson. Björgólfsson has since advocated for the United Kingdom to consider a capped-tax model similar to Italy’s.
Interest in Milan’s luxury property market has also increased. Enquiries from UK buyers for property in Milan rose by 260% between 2023 and 2025, compared with 42% growth across the Italian market as a whole.
Investor Visa Options
A favourable tax regime does not by itself confer a right to reside in Italy. For non-EU nationals, the Investor Visa may provide the immigration route needed to establish residence alongside the flat-tax election.
Qualifying options include an investment of €250,000 in an innovative startup, €500,000 in an Italian company, €2 million in government bonds or a €1 million donation. The investment is made after the application receives approval, and the programme does not impose a minimum physical-presence requirement.
By December 2025, the Investor Visa programme had received 209 applications. Applications have grown at a compound annual rate of 62.6% since 2018, while decisions have continued to be issued within 30 days.
Italy’s relative position has improved as comparable European routes have narrowed or become more expensive. Spain closed its golden visa programme in April 2025. Portugal’s fund-based route now begins at €500,000, while Greece requires €800,000 in its most sought-after areas. Italy’s €250,000 innovative-startup route therefore remains the lowest substantial investment threshold among comparable options in Western Europe.
Additional Tax Incentives
Italy’s tax incentives also extend beyond the highest wealth brackets.
Foreign pensioners who relocate to qualifying municipalities in southern Italy may pay a 7% flat tax on foreign income for ten years. In April 2026, the regime was expanded to cover municipalities with populations of up to 30,000, making 74 additional towns eligible.
Eligible individuals relocating to Italy for employment may use the impatriati regime. It exempts 50% of qualifying Italian employment income up to €600,000. The exemption rises to 70% for qualifying moves to southern Italy.
Planning a Move to Italy
Italy’s continued ability to attract wealthy residents after two material flat-tax increases in two years points to the country’s strong position in the international relocation market. For families assessing a move from higher-tax jurisdictions, the current framework may be more attractive to evaluate before another policy adjustment occurs.
The success of a relocation depends on more than choosing a destination. The timing of Italian tax residence, the use of an advance tax ruling and the relationship between the flat-tax regime and the Investor Visa should be considered carefully before establishing residence.
If you're planning to obtain a residence permit, invest in a country's economy, or purchase foreign real estate, we invite you to a consultation with our company. During a personal online meeting, we'll discuss your questions in detail and create a step-by-step action plan for you.
For much of the last century, wealthy families leaving high-tax jurisdictions generally focused on Switzerland, Monaco and the United Kingdom. That pattern has shifted. Switzerland has become more cautious about foreign wealth, Monaco has limited capacity, and the United Kingdom replaced its non-dom regime with worldwide taxation in April 2025.
Italy has increasingly benefited from this changing environment. Over the past 18 months, prominent bankers, industrialists and billionaires previously based in London have moved to Milan. The country has developed a broad relocation framework combining favourable taxation for new residents with immigration routes for non-EU nationals.
Italy received a net inflow of 3,600 migrating millionaires in 2025, the largest figure in Europe and the third-largest worldwide after the UAE and the United States. Switzerland recorded 3,000 millionaire arrivals, Portugal 1,400 and Greece 1,200.
The figures came during a record period for global wealth migration. A total of 142,000 millionaires relocated worldwide in 2025, while 165,000 are expected to move in 2026. Italy captured a greater share of this movement than any other European jurisdiction.
Italy’s Flat-Tax Regime
Article 24-bis of Italy’s tax code provides a flat-tax option for qualifying individuals who become Italian tax residents. To use the regime, an individual must have spent at least nine of the preceding ten years outside Italy.
Eligible taxpayers may replace ordinary taxation of foreign-source income with a fixed annual payment for a period of up to 15 years. The payment does not vary with the level of foreign income: the annual amount is the same whether foreign income totals €1 million or €50 million.
The annual charge has increased several times since the regime began:
- €100,000 when introduced in 2017;
- €200,000 from August 2024;
- €300,000 from 1 January 2026, following the entry into force of the 2026 Budget Law.
The charge for qualifying family members also increased to €50,000.
The full impact of the 2026 increase is not yet known, as tax-declaration data are published with a two-year delay. Government forecasts assume that the €300,000 rate could reduce the number of future entrants by approximately half. Initial signs have not indicated a reduction in demand, particularly among ultra-high-net-worth families for whom the fixed annual charge remains lower than marginal tax rates of 45% to 50% elsewhere in Europe. The 2024 increase likewise did not result in an apparent decline in relocations.
Nearly 1,500 individuals participated in the regime in 2023, an increase of 31.6% from the previous year. Revenue from the programme reached €315 million between 2020 and 2023. Since 2017, total participation, including family members, is estimated at approximately 4,000.
A key element of the regime is the continued application of earlier tax rates to existing participants. Individuals admitted in 2017 remain liable for the original €100,000 annual charge, while those joining in 2026 pay €300,000. The government also abandoned a proposal to introduce a mandatory investment requirement for the flat-tax regime.
The Impact of UK Tax Changes
The United Kingdom has become a significant source of incoming wealth for Italy. After the non-dom regime ended in April 2025 and worldwide taxation took effect, the UK experienced a net outflow of 16,500 millionaires during the year. This was the largest recorded annual outflow and more than twice the figure recorded for China.
Milan has been chosen by several well-known individuals who previously lived in London, including Richard Gnodde, vice chairman of Goldman Sachs; Aston Villa owner Nassef Sawiris; consumer-goods executives Elio Leoni-Sceti and Bart Becht; and Iceland’s first billionaire, Thor Björgólfsson. Björgólfsson has since advocated for the United Kingdom to consider a capped-tax model similar to Italy’s.
Interest in Milan’s luxury property market has also increased. Enquiries from UK buyers for property in Milan rose by 260% between 2023 and 2025, compared with 42% growth across the Italian market as a whole.
Investor Visa Options
A favourable tax regime does not by itself confer a right to reside in Italy. For non-EU nationals, the Investor Visa may provide the immigration route needed to establish residence alongside the flat-tax election.
Qualifying options include an investment of €250,000 in an innovative startup, €500,000 in an Italian company, €2 million in government bonds or a €1 million donation. The investment is made after the application receives approval, and the programme does not impose a minimum physical-presence requirement.
By December 2025, the Investor Visa programme had received 209 applications. Applications have grown at a compound annual rate of 62.6% since 2018, while decisions have continued to be issued within 30 days.
Italy’s relative position has improved as comparable European routes have narrowed or become more expensive. Spain closed its golden visa programme in April 2025. Portugal’s fund-based route now begins at €500,000, while Greece requires €800,000 in its most sought-after areas. Italy’s €250,000 innovative-startup route therefore remains the lowest substantial investment threshold among comparable options in Western Europe.
Additional Tax Incentives
Italy’s tax incentives also extend beyond the highest wealth brackets.
Foreign pensioners who relocate to qualifying municipalities in southern Italy may pay a 7% flat tax on foreign income for ten years. In April 2026, the regime was expanded to cover municipalities with populations of up to 30,000, making 74 additional towns eligible.
Eligible individuals relocating to Italy for employment may use the impatriati regime. It exempts 50% of qualifying Italian employment income up to €600,000. The exemption rises to 70% for qualifying moves to southern Italy.
Planning a Move to Italy
Italy’s continued ability to attract wealthy residents after two material flat-tax increases in two years points to the country’s strong position in the international relocation market. For families assessing a move from higher-tax jurisdictions, the current framework may be more attractive to evaluate before another policy adjustment occurs.
The success of a relocation depends on more than choosing a destination. The timing of Italian tax residence, the use of an advance tax ruling and the relationship between the flat-tax regime and the Investor Visa should be considered carefully before establishing residence.
If you're planning to obtain a residence permit, invest in a country's economy, or purchase foreign real estate, we invite you to a consultation with our company. During a personal online meeting, we'll discuss your questions in detail and create a step-by-step action plan for you.