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The legislative decree 147/2015 entered into force on October 7, contains provisions aimed at making the Italian tax system more attractive and competitive for both foreign investors and Italian companies. Such measures include a new ruling procedure for substantial investments as well as a tax relief regime for highly qualified immigrant workers.


A new form of ruling will be available for companies that intend to invest in Italy. 
The new system is aimed at providing them with a framework of certain and stable tax treatment, arising from their investment plan.

The investor, either resident or non-resident, shall forward its application to the Italian Revenue Agency presenting a business plan, detailing the amount of the investment, the timing and implementation modalities, the expected number of new hires and the consequences of such investment on the Italian tax system. 
The procedure applies to investments of not less than euro 30 million.

Tax Authorities will send a written response within 120 days (to be extended by further 90 days, should additional information be required) on the overall direct and indirect tax treatment.

Expatriates benefiting from the dedicated Italian special tax regime

The Decree includes provisions aimed at repatriating into Italy highly skilled workers, including top managers and EU citizens.

The facility consists of a reduction of 30% of the taxable income (IRPEF) for workers that transfer their residence into Italy, provided that the following conditions are fulfilled:

  • the worker was fiscally resident abroad and not in Italy in the five years preceding the transfer and commits to living in the country for at least two years;
  • once in Italy, an employment contract is concluded with a resident Company;
  • the employment activity shall be carried out mainly in Italy;
  • the worker occupies a managerial role and his job in Italy requires high qualifications and specialization.

The benefit is applicable from the fiscal year in which the transfer of residence occurs and for the following four. A decree, to be issued by the Ministry of Finance in 90 days since October 7, 2015 will contain the rules for the implementation of the new regime.