Uk To Italy Flat Tax Relocation

---
name: uk-to-italy-flat-tax-relocation
description: "Moving from the UK to Italy in 2026/27: which Italian regime fits which mover, set against the UK departure rules. Covers the Italian new-residents flat tax under TUIR art. 24-bis (EUR 300,000 a year for those who move their residence from 1 January 2026, EUR 200,000 for moves from 10 August 2024 to 2025, EUR 100,000 before; EUR 50,000 or 25,000 per family member), the impatriati regime for workers (50% of Italian work income taxed, 40% with a minor child, EUR 600,000 cap), the 7% regime for foreign pensioners in the south, Italian residence under art. 2 TUIR from 2024, the UK-Italy treaty pension articles, and the UK side (SRT, split year, 5-year rule, IHT tail). Trigger phrases: move to Italy flat tax, Italy non-dom, 300k flat tax Italy, impatriati UK, retire to Italy 7%, leave UK for Italy. Out of scope, see siblings: uk-statutory-residence-test, uk-non-resident-sa109, uk-to-uae-relocation-tax, uk-non-dom."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/uk-to-italy-flat-tax-relocation"
  jurisdiction: "GB"
  tax_year: "2026"
  last_updated: "2026-10-23"
---

# Moving from the UK to Italy: the flat-tax corridor (2026/27)

UK tax year in force: 2026/27 (6 April 2026 to 5 April 2027). Italian tax year: the calendar year 2026. Changelog v1.1 (2026-10-23): the flat tax moved to EUR 300,000 (EUR 50,000 per family member) for residence moved from 1 January 2026; impatriati and 7% pensioner rules taken from Agenzia delle Entrate guidance, including the 30,000-inhabitant limit from 7 April 2026; Italian residence test updated; unsourced Italian rates and wealth-tax percentages removed; UK side brought to 2026/27; worked examples and Sources table added. Review fixes (2026-10-23): 7% regime length settled at 10 tax periods from the TUIR text; 30,000-inhabitant limit credited to L. 34/2026 and applied to the earthquake municipalities too; the flat-tax amount tied to the date residence moves; close-company charge limited to material participators; the 1 January 2027 move of these articles into the new Testo unico noted.

**Why this corridor matters.** Italy offers a fixed annual substitute tax on all foreign income for new residents, a partial exemption for relocating workers, and a 7% rate for foreign pensioners in small southern towns. The UK end (the Statutory Residence Test, the 5-year return rule, the inheritance tax tail) applies whatever Italy offers. The main risk is the matching problem: three Italian regimes, three kinds of mover, and costly results from picking the wrong one or electing too late.

**Who this skill is for.** UK residents considering Italy (wealthy families, working professionals, retirees) and their advisers. Map, not advice: the Italian regimes have eligibility windows and election deadlines.

## Part 1: The UK end in brief

The UK departure rules are the same as on any corridor. They are set out in `uk-to-uae-relocation-tax` (Parts 1, 2, 3 and 5) and `uk-statutory-residence-test`. The points that matter here:

- **Breaking UK residence:** the third automatic overseas test (full-time work abroad, fewer than 91 UK days, fewer than 31 UK work days), or the sufficient ties table (as a leaver: 16 to 45 days needs 4 ties, 46 to 90 needs 3, 91 to 120 needs 2, 121 to 182 needs 1) (FA 2013 Sch 45).
- **Split year:** Case 1 (full-time work overseas), Case 2 (partner of a Case 1 leaver), Case 3 (ceasing to have any UK home).
- **5-year rule:** if you had sole UK residence in 4 of the 7 years before leaving and return within 5 years, gains on pre-departure assets and, for returns from 6 April 2026, the full amount of close-company distributions received while away by a material participator (or an associate of one) are taxed in the year you come back (FA 2013 Sch 45 para 110; RFIG21600).
- **IHT tail:** a long-term UK resident (10 of the previous 20 tax years) stays in UK IHT on worldwide assets for 3 to 10 tax years after leaving (IHTA 1984 s.6A).
- **UK property** stays in UK tax: rent (Non-resident Landlord Scheme), and the 60-day return on any sale. See `uk-non-resident-sa109`.

## Part 2: Italy's three doors

Italy runs three separate regimes. They suit different lives and each has an eligibility clock. Choose before you arrive.

For the Italian tax year 2026 the regimes sit in TUIR arts. 24-bis and 24-ter and D.Lgs. 209/2023 art. 5, and residence in TUIR art. 2. From 1 January 2027 these provisions are replaced by arts. 246, 247, 225 and 2 of the new Testo unico delle imposte sui redditi (D.Lgs. 19 June 2026 n. 117, arts. 376 and 377), which carry over the same amounts and periods.

### 2.1 Door 1: the new-residents flat tax (TUIR art. 24-bis)
- **Who:** anyone who moves tax residence to Italy and was **not Italian resident for at least 9 of the 10 tax years** before the option starts. There is no wealth test.
- **The charge:** a fixed annual substitute tax on all **foreign-source** income, whatever its amount:

| Residence moved to Italy | Main taxpayer, per year | Each family member, per year |
|---|---|---|
| Up to 10 August 2024 | EUR 100,000 | EUR 25,000 |
| After 10 August 2024, up to 31 December 2025 | EUR 200,000 | EUR 25,000 |
| From 1 January 2026 | **EUR 300,000** | **EUR 50,000** |

The amount follows the date residence moves (civil code art. 43), not the year the option is elected: the EUR 300,000 and EUR 50,000 apply to people who move residence from 1 January 2026 (L. 199/2025 art. 1 commi 25 and 26). Someone who moved in 2025 and elects in a later return pays EUR 200,000.

- **Duration:** renews each year and ends after **15 years** from the first year. It can be revoked. It **lapses** if the tax is not paid in full on time. Revocation or lapse bars a new option.
- **Payment:** in one sum by the Italian income tax balance date, on form F24 (the Agenzia deadline calendar lists 30 June 2026 for the payment due in 2026). Late payment cannot be cured (no ravvedimento).
- **Election:** in the Italian tax return for the year of the move or the following year. An advance ruling (interpello) is optional.
- **Cherry-picking:** you can name foreign states whose income stays under the ordinary regime, with foreign tax credit (art. 24-bis(5)). This matters where a source state, or a treaty, does not treat flat-tax income as taxed.
- **Not covered:**
  - **Italian-source income**: taxed under the ordinary IRPEF rules.
  - **Gains on qualified shareholdings sold in the first 5 tax years** of the option (art. 67(1)(c) TUIR income): taxed under the ordinary regime. Layered on the UK 5-year rule, a founder selling a large stake has two 5-year clocks to respect.
- **The extras** (Law 232/2016 art. 1 commi 153 and 158, explained in Circolare 17/E 2017): no Italian foreign-asset reporting (quadro RW) and no IVIE or IVAFE (Italian taxes on foreign property and foreign financial assets) for the states covered by the option; and for deaths and gifts while the option runs, Italian inheritance and gift tax applies **only to assets in Italy**.
- **When it pays:** compare the fixed charge with the Italian tax the same foreign income and gains would bear under the ordinary regime with treaty credits, for a representative year, before electing.

### 2.2 Door 2: impatriati (relocating workers, D.Lgs. 209/2023 art. 5)
- **Who:** employees and self-employed people who move tax residence to Italy from 2024, were **not Italian resident in the 3 previous tax years** (6 years if they keep working for the same employer or group, 7 if they previously worked in Italy for that group), commit to stay resident **at least 4 years**, work mainly in Italy, and meet the high-qualification or specialisation requirement.
- **The relief:** Italian employment and self-employment income up to **EUR 600,000 a year** is taxed on **50%** of its amount, or **40%** with a minor child (moving with the worker, or born or adopted during the regime and living in Italy).
- **Duration:** the year of the move plus the next 4 tax years. Leaving before 4 years claws the benefit back with interest.
- **Fit:** a salary, not a portfolio. Investment income is taxed in full, and RW reporting, IVIE and IVAFE apply.

### 2.3 Door 3: the 7% regime for foreign pensioners (TUIR art. 24-ter)
- **Who:** people receiving pension income from foreign payers who move tax residence to a municipality of **no more than 30,000 inhabitants** in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia, or to a municipality hit by the 2009 or 2016 earthquakes that is within the same 30,000 limit. The limit was 20,000 until L. 34/2026 art. 26(1) raised it, in force from 7 April 2026. They must not have been Italian resident in the **5 previous tax years** and must move from a state with which Italy has administrative cooperation agreements.
- **The relief:** a **7%** substitute tax on **all foreign-source income**, not only the pension. RW reporting, IVIE and IVAFE do not apply for the states covered (Circolare 21/E 2020).
- **Duration:** the year the option takes effect (the year residence moves) plus the next 9 tax periods, 10 in all (TUIR art. 24-ter(4) and (5); Circolare 21/E 2020). The Agenzia summary page's "nine periods of validity" counts only the following years.
- **Fit:** a retiree living on a UK pension and modest investments who will genuinely live in a small southern town.

### 2.4 Matching table

| Mover | Door | Why |
|---|---|---|
| Wealthy family, large foreign portfolio or trusts | Flat tax | Caps tax on foreign income, removes RW, IVIE and IVAFE for covered states, keeps foreign assets out of Italian inheritance tax |
| Founder planning to sell a large stake | Flat tax, with both 5-year clocks diarised | Qualified-shareholding gains are outside the flat tax in years 1 to 5; the UK 5-year rule may also bite |
| Salaried professional | Impatriati | 50% (or 40%) of the salary taxed; the flat tax does nothing for Italian-source pay |
| Retiree willing to live in a small southern town | 7% regime | 7% on all foreign income for 10 years |
| Modest income, none of the above | Ordinary regime plus treaty | The special regimes cost more than they save |

## Part 3: Becoming Italian resident

- From 1 January 2024 (art. 2 TUIR as amended by D.Lgs. 209/2023), you are Italian resident for a tax year if, for **most of the year** (183 days, 184 in a leap year, counting part days), you are registered with the Anagrafe, or have your domicile (main personal and family relationships), or your civil-law residence in Italy, or are **physically present** there. Registration is now a rebuttable presumption (Circolare 20/E 2024).
- Residence is decided for the whole Italian tax year. Arriving in the second half of a year usually means the first resident year is the next calendar year. A UK split-year departure in, say, October pairs with Italian residence starting on 1 January. Plan where you are taxable in the months between.
- Post-Brexit, a UK national needs an Italian visa route, which constrains timing.

## Part 4: The UK-Italy treaty

- **Private pensions** paid to a resident of one state are taxable only in that state (UK-Italy convention, Article 18(1)). An Italian resident's UK private pension is taxed in Italy, under the ordinary regime, the flat tax or the 7% regime as applicable. Claim UK relief on form DT-Individual.
- **Government service pensions** are taxable only in the paying state unless the recipient is both a resident and a national of the other state (Article 19(2)).
- **UK property:** rent and gains stay taxable in the UK (see `uk-non-resident-sa109`). Under the ordinary regime and impatriati, Italy also taxes them with a credit, and IVIE applies to the property.

## Part 5: Sequenced checklist

**Year before the move**
1. Choose the door with a two-country model of a representative year, and check the clocks: 9 of 10 years (flat tax), 3 years (impatriati; 6 or 7 with the same group), 5 years (7% regime) of prior non-Italian residence.
2. Founders: overlay the UK 5-year rule and the flat tax's 5-year carve-out for qualified shareholdings on any planned sale.
3. Start the visa process.
4. UK side: pick the SRT route and split-year case, and build the diary around it.

**The move**
5. Time it around Italy's whole-year rule: more than half the year in Italy makes that year resident.
6. Register with the Anagrafe; file the UK P85 and SA109.
7. Elect the regime in the first Italian return (or the next one for the flat tax); consider an interpello for the flat tax.

**Steady state**
8. Diarise: the flat-tax payment at each balance date (a missed payment ends the regime), the two 5-year clocks, the UK IHT tail end-date, RW, IVIE and IVAFE if on impatriati or the ordinary regime, and the UK 60-day return on any UK property sale.
9. Reassess before each regime ends (15 years flat tax, 5 impatriati, 10 pensioner).

## Part 6: Worked examples

**6.1 A family electing the flat tax in 2026.** A couple and their adult son move residence from London to Milan in March 2026, each non-resident in Italy for the previous 10 years. The main taxpayer elects the flat tax and extends it to the spouse and the son. For 2026 the family pays EUR 300,000 plus EUR 50,000 for each of the two family members, EUR 400,000 in all, by the balance date in 2027, on all foreign income however large. Any gain on a qualified shareholding sold in 2026 to 2030 is taxed outside the flat tax.

```oa-check
name: Flat tax for a main taxpayer and two family members, residence moved in 2026
inputs:
  main_charge: 300000
  family_charge: 50000
  family_members: 2
steps:
  - family_total: family_charge * family_members
  - annual_flat_tax: main_charge + family_total
expected:
  family_total: 100000.00
  annual_flat_tax: 400000.00
```

**6.2 An impatriato with a minor child.** An engineer moves from Manchester to Turin in 2026 with her 8-year-old son, having been non-resident in Italy for the previous 3 years, and earns EUR 120,000 of Italian salary. With a minor child, 40% of the salary is taxed: EUR 48,000 enters her Italian taxable income and EUR 72,000 is left out, for 2026 and the next 4 years, provided she stays resident at least 4 years.

```oa-check
name: Impatriati taxable share with a minor child (40%)
inputs:
  salary: 120000
  taxable_pct: 40
  cap: 600000
steps:
  - eligible: min(salary, cap)
  - taxable: eligible * taxable_pct / 100
  - excluded: eligible - taxable
expected:
  taxable: 48000.00
  excluded: 72000.00
```

## The trap list

| Trap | Why it bites |
|---|---|
| Choosing the door after arriving | Eligibility depends on prior non-residence and first-year elections. |
| Flat tax for a salary, impatriati for a portfolio | Each regime relieves what the other does not. |
| Selling the company in year 2 | Qualified-shareholding gains are outside the flat tax for 5 years, and the UK 5-year rule may claim them too. |
| Assuming the 2025 price | A residence move from 1 January 2026 costs EUR 300,000 a year, plus EUR 50,000 per family member. |
| Mid-year arrival assumptions | Italian residence is decided for the whole year at the half-year mark. |
| Forgetting RW, IVIE and IVAFE | On impatriati or the ordinary regime, foreign property and investments carry Italian reporting and taxes. |
| Missing a flat-tax payment | The regime lapses and cannot be elected again. |
| Treating Italian inheritance tax relief as the end of UK IHT | The UK tail runs 3 to 10 tax years after departure on worldwide assets. |

## Sources

| Source | URL | Read on |
|---|---|---|
| Agenzia delle Entrate, Neo residenti: regime opzionale (EUR 300,000 / 50,000 from 2026; 200,000; 100,000; 9 of 10 years; 15 years; payment; revocation) | https://www.agenziaentrate.gov.it/portale/schede/agevolazioni/opzione-per-i-neo-residenti/infogen-opzionale-neo-residenti | 2026-10-23 |
| Agenzia delle Entrate, Neo residenti: normativa e prassi (Law 199/2025 art. 1 commi 25-26; DL 113/2024 art. 2) | https://www.agenziaentrate.gov.it/portale/schede/agevolazioni/opzione-per-i-neo-residenti/normativa-e-prassi-regi-opz-neo-residenti | 2026-10-23 |
| TUIR art. 24-bis (text published by the Agenzia delle Entrate) | https://www.agenziaentrate.gov.it/portale/documents/20143/241456/Articolo+24+bis+del+Testo+Unico_24bisTuir.pdf/7cc66a01-df4c-67b0-ddfd-f13bc80a5ae3?t=1489738101421 | 2026-10-23 |
| Normattiva, TUIR art. 24-bis (text in force October 2026, EUR 300,000 / 50,000) | https://www.normattiva.it/uri-res/N2Ls?urn:nir:presidente.repubblica:decreto:1986-12-22;917~art24bis | 2026-10-23 |
| Normattiva, TUIR art. 24-ter (30,000 inhabitants; 9 periods after the first) | https://www.normattiva.it/uri-res/N2Ls?urn:nir:presidente.repubblica:decreto:1986-12-22;917~art24ter | 2026-10-23 |
| Normattiva, L. 30 December 2025 n. 199, art. 1 commi 25 and 26 | https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-12-30;199 | 2026-10-23 |
| Normattiva, amendments to TUIR art. 24-ter (L. 11 March 2026 n. 34, art. 26(1), GU 23 March 2026) | https://www.normattiva.it/do/atto/vediAggiornamentiAllArticolo?art.dataPubblicazioneGazzetta=1986-12-31%2000:00:00.0&art.codiceRedazionale=086U0917&art.flagTipoArticolo=0&art.idArticolo=24&art.idSottoArticolo=3&art.idSottoArticolo1=10&art.versione=5 | 2026-10-23 |
| Normattiva, D.Lgs. 19 June 2026 n. 117, Testo unico delle imposte sui redditi (arts. 2, 225, 246, 247, 376, 377) | https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2026-06-19;117 | 2026-10-23 |
| Agenzia delle Entrate, Circolare 17/E of 23 May 2017 (RW, IVIE, IVAFE; inheritance and gift tax) | https://www.agenziaentrate.gov.it/portale/documents/20143/297873/Circolare+n.+17+del+23+maggio+2017_CIRCOLARE+REGIMI+AGEVOLATIVI+PER+PERSONE+FISICHE+CHE+TRASFERISCONO+LA+RESIDENZA+FISCALE+IN+ITALIA+-REGISTRO+CIRCOLARI.0000017.23-05-2017-U+%282%29.pdf/8c361223-0cf1-b41b-be4a-db33664d5855?t=1497872005315 | 2026-10-23 |
| Agenzia delle Entrate, Lavoratori impatriati (D.Lgs. 209/2023) | https://www.agenziaentrate.gov.it/portale/lavoratori-impatriati-209-2023/infogen-lavoratori-impatriati-209-2023-cittadini | 2026-10-23 |
| Agenzia delle Entrate, Regime opzionale per i pensionati esteri (7%, 30,000 inhabitants from 7 April 2026) | https://www.agenziaentrate.gov.it/portale/schede/agevolazioni/regime-opzionale-per-i-pensionati-esteri-che-cose-cittadini | 2026-10-23 |
| Agenzia delle Entrate, Aliquote Irpef e agevolazioni (7% regime: 5 prior years, cooperation agreement) | https://www.agenziaentrate.gov.it/portale/aliquote-irpef-e-agevolazioni2 | 2026-10-23 |
| Agenzia delle Entrate, Circolare 21/E of 17 July 2020 (art. 24-ter: 10 years, RW, IVIE, IVAFE) | https://www.agenziaentrate.gov.it/portale/documents/20143/0/Circolare+n.+21E+del+17.07.2020.pdf/96191701-87ef-ce63-e163-a8a6e37e64ad | 2026-10-23 |
| Agenzia delle Entrate, Circolare 20/E of 4 November 2024 (residence under art. 2 TUIR) | https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/circolare+n.+20+de+4+novembre+2024+residenza+pdf.pdf/978517e4-aa40-d14c-be79-19028c0f8785?t=1730715943926 | 2026-10-23 |
| UK-Italy Double Taxation Convention 1988 (Articles 18, 19) | https://www.gov.uk/government/publications/italy-tax-treaties/1988-uk-italy-double-taxation-convention-in-force | 2026-10-23 |
| Finance Act 2013 Sch 45 (statutory residence test) | https://www.legislation.gov.uk/ukpga/2013/29/schedule/45 | 2026-10-23 |
| HMRC RDR3, Statutory Residence Test guidance note | https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-test-srt-rdr3 | 2026-10-23 |
| HMRC RFIG21600, temporary non-residence: close company distributions | https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/rfig21600 | 2026-10-23 |
| Inheritance Tax Act 1984 s.6A (long-term UK resident) | https://www.legislation.gov.uk/ukpga/1984/51/section/6A | 2026-10-23 |

Not yet confirmed: Italian ordinary IRPEF, IVIE, IVAFE and inheritance tax rates (left out until read from an Agenzia delle Entrate page).

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-10-23. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `uk-to-italy-flat-tax-relocation` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/uk-to-italy-flat-tax-relocation. If neither is available, confirm every figure against the official source pages cited above before relying on it.