Even Remote Workers Can Access the Facilitated Taxation Regime for Impatriates (Ferrari & Associati)

Business Opportunities
June 8, 2022 - Ferrari & Associati – Studio Legale e Commerciale

This is a thought leadership article on how firms can benefit from the Italian facilitated tax regime for impatriates from PrimeGlobal member firm Ferrari & Associati in Italy.

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Moving to Italy can be a very good deal: keep your job in the motherland and enjoy the Italian weather, food, and landscape. All at a bargain tax rate. The confirmation comes directly from the Revenue Agency.

With ruling no. 186/2022, in fact, it is established that even employees of companies established abroad who carry out their work mainly in the Italian territory can benefit from the facilitated tax regime for impatriates. This is essentially a discount from 50% to 90% of income tax with a duration of 5 to 10 years.

This regime, which Ferrari & Associati has previously discussed, is based on Article 16 of Legislative Decree no. 147 (the so-called Internationalization Decree), and is intended for a worker who:

  • transfers residence to the territory of the State, pursuant to Article 2 of the Consolidated Income Tax Act referred to in the Decree of the President of the Republic of 22 December 1986, no. 917 (TUIR);
  • was not resident in Italy in the two tax periods prior to the transfer and undertakes to reside in Italy for at least two years; and
  • carries out the work activity mainly in the Italian territory

The regime of expatriate workers is usable for five tax periods and can be renewed for a further five years if specific requirements are met.

With ruling no. 186/2022, mentioned at the beginning of this article, the doubt that had initially arisen regarding the application of the aforementioned regime is put to an end. In fact, the rationale of the law is to welcome human capital into the territory of the Italian state. As a prerequisite to the application, it is envisaged that anyone who transfers residence to Italy from abroad is a worker, employee, or self-employed. Nothing is explicitly established, however, regarding the “nationality” of the entity to which the worker established in Italy is employed, nor the possibility that, despite being a foreign company, it has a permanent establishment in Italy.

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Ferrari & Associati – Studio Legale e Commerciale

Ferrari & Associati is the complete solution for individuals, partnerships, and corporations. The firm was established in 2001, as a result of the transformation of the Accounting firm founded in 1965 by Dr. Nazzareno Ferrari. We are based in Rome, Italy. We provide highly qualified legal and commercial assistance to our clients, offering a full range of services in the areas of accounting and auditing, taxation, financial, and advisory services. Our work focuses on the creation of assets and trusts, personal planning, corporate reconstructing operations, banking and insurance, development of entrepreneurial projects, and much more.

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