Flat tax in Italy and the impatriati regime: from 2027 you won’t be able to combine them

Italy has introduced an important change for foreign professionals and high-net-worth taxpayers who are planning a move and considering preferential tax regimes.

Under a recently approved law (already in force after publication in the Official Gazette), Italy’s flat tax regime for new tax residents can no longer be combined with the inbound workers regime (impatriati).

Crucially, the restriction will not apply immediately: it will affect only those who transfer their tax residence to Italy starting with the 2027 tax year.

This “delayed start” is what makes the news especially relevant for tax planning.

Both regimes can be combined until the end of 2026

The new rule creates a transition period running until the end of the 2026 tax year.

If an individual becomes an Italian tax resident in 2026, they can combine the two regimes, provided that all requirements are met.

In particular, the taxpayer may access:

• the flat tax regime (in the current version — €300,000, starting from 1 January 2026), and
• the inbound workers regime in its updated form, applicable from 2024.

In practice, this means that during the limited window, taxpayers may structure their relocation in a way that produces a more advantageous outcome by using both regimes at the same time.

However, from 2027, this combination will no longer be available.

Each regime has its own “timeline” and its own conditions

The transitional window is a real opportunity, but there is no automatic “mixing” of the regimes.

Each regime has its own rules on timing and eligibility requirements, which must be aligned precisely.

For example:

• Flat tax typically must be claimed within the first tax returns filed after changing tax residence (or within a limited period after that). You cannot simply “defer” the choice indefinitely.
• Impatriati can be applied either through employer payments (via payroll mechanisms) or through a tax return. At the same time, guidance from the Italian tax authorities has introduced interpretation limits and practical nuances.

As a result, contentious and borderline cases can arise, especially when:

• tax residence periods are incomplete (partial);
• employment status changes;
• taxpayers move between regimes;
• international income is structured in complex ways.

Interpello as a way to reduce risk

Given the technical complexity of special tax regimes and the increased attention from the authorities, getting certainty in advance becomes particularly important.

In this context, the Italian procedure of a tax ruling on request — interpello — may help.

Essentially, the taxpayer formally describes their specific situation to the Italian tax authorities and receives an official view on the applicability of the regimes—especially where questions remain a “grey area” or are not addressed unambiguously in existing guidance.

This is especially relevant if:

• the planned move is close to the 2027 threshold date;
• the interaction between regimes has no clear answer in the current guidance;
• there is a risk that the tax position or structure will be challenged.

The change matters even for people who have already relocated

The update affects not only future participants in the preferential regimes.

For individuals who have already moved to Italy and are currently applying (or considering applying) one of the two regimes, a strategic decision point now arises.

In such cases, the choice between flat tax and the impatriati regime may have long-term consequences and requires an assessment of:

• the nature and source of income;
• expected future income streams;
• family and asset ownership structure;
• the duration and sustainability of the selected regime.

Sometimes a transition between regimes is also considered, but it must be handled in line with strict timing rules and potential interpretive risks.

At first glance, the revised wording looks like a limitation. In practice, however, it sets a clear planning horizon:

the period from now until the end of 2026 is a window in which the combination is still possible. From 2027, the boundaries will become more restrictive.

As often happens in international tax planning, timing becomes the decisive factor.

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