Italy’s €200,000 Flat Tax Regime and Why You Should Consider a Tax Ruling Before Moving.

Italy’s flat tax regime for new residents is one of the most powerful fiscal incentives available in Europe. Introduced to attract high-net-worth individuals, this regime allows eligible taxpayers to pay a fixed annual tax of €200,000 on all their foreign-sourced income. In a recent article published on IMI Daily, Italian tax lawyer Marco Mesina and Founder of Move to Dolce Vita outlined how an advance tax ruling—known as an interpello—can provide essential legal certainty for those looking to apply the regime strategically.

But despite the simplicity of the rule on paper, many individuals have complex situations—multiple residencies, trusts, capital gains, foreign holding companies—and want to ensure legal certainty before making a move. That’s why filing an advance tax ruling (interpello) before moving to Italy is one of the smartest steps you can take.

This guide will explain how the interpello works, who benefits from it, and why pre-approval offers a clear advantage when planning your relocation under Italy’s flat tax regime.

The Flat Tax Regime at a Glance

Under Article 24-bis of the Italian Income Tax Code, new residents in Italy can opt to pay a flat annual tax of €200,000 on all their foreign-source income, regardless of how much they earn or where the income is generated. The regime is available for up to 15 years and can be extended to family members for an additional €25,000 per person, per year.

Eligible foreign-source income includes dividends, interest, capital gains, pensions, real estate income, and trust distributions. It also offers several important exemptions:

  • No requirement to declare foreign assets (no RW section of the tax return)
  • No IVIE or IVAFE wealth taxes on foreign property or accounts
  • No inheritance or gift tax on foreign assets
  • No application of Italy’s CFC (Controlled Foreign Corporation) rules
  • No foreign income taxed progressively, regardless of amount

The regime is designed to be simple and stable, but the real advantage lies in using it as a planning tool—especially when combined with an advance tax ruling.

What Is an Interpello and Why Does It Matter?

An interpello is a formal request submitted to the Italian Revenue Agency, asking for a binding opinion on the tax treatment of a specific case or question. While not mandatory to apply the flat tax regime, filing an interpello before moving is a way to receive confirmation on your eligibility or on the tax treatment of certain foreign income or structures.

For many globally mobile clients, the interpello is a key step to:

  • Get clarity on eligibility, particularly in cases involving past Italian residency or time spent in the country
  • Understand whether specific income qualifies for the flat tax
  • Confirm whether foreign entities (like trusts or holding companies) fall within the regime
  • Avoid future disputes or audits with the Tax Authority

By obtaining a written response from the Italian Revenue Agency, you get legal certainty and peace of mind before relocating and restructuring your tax affairs.

When to File the Interpello

One of the best times to file a tax ruling is before transferring your tax residence to Italy. This offers several benefits:

  • It ensures that your position is reviewed in advance, without any potential pressure or urgency
  • It gives you time to restructure or adjust your plans based on the Revenue Agency’s response
  • It helps you plan the move with precision, aligning it with investment decisions, liquidity events, or personal milestones

While some choose to rely on their interpretation of the law and apply the flat tax directly in their first Italian tax return, many high-net-worth individuals prefer to have full clarity before taking that step.

What to Include in Your Interpello Request

The interpello should be written in Italian and submitted with a clear structure. It must include:

  • Full personal details of the applicant (and any family members applying for the regime)
  • A detailed history of the applicant’s tax residency over the past 10 years
  • An overview of income types, assets held abroad, and any relevant trusts or entities
  • Supporting documentation where appropriate (e.g. tax returns, AIRE registration, residence permits)
  • Specific questions that the applicant is submitting to the Tax Authority for interpretation

Each interpello is a personalized legal document. Working with an experienced tax advisor ensures that your request is well-framed, precise, and supported by strong legal arguments.

What Happens After You File?

Once the interpello is submitted to the Central Directorate for Individuals and Non-Commercial Entities at the Italian Revenue Agency, the Agency has 90 days to issue a response. If they request additional information or documentation, the deadline is extended by an additional 60 days from the date the requested materials are submitted.

If no response is issued within the applicable timeframe, the interpello is considered accepted (a mechanism known as silenzio-assenso).

If your ruling is favorable, it becomes binding for the Tax Authority, as long as the facts stated in the request remain accurate. This means you can move forward with confidence, knowing that your tax position has been vetted and confirmed.

Who Should Consider an Interpello?

While the flat tax regime itself is available to anyone who has not been an Italian tax resident for at least 9 out of the last 10 years, an interpello is especially useful for:

  • Individuals with partial ties to Italy (past residency, family, property)
  • Entrepreneurs or investors with foreign holding companies or trusts
  • Families relocating with minor children or dependents
  • US citizens with global income, estate structures, and tax filing complexities
  • Anyone planning to include their spouse or family in the flat tax election
  • Individuals with recent liquidity events (sale of a company, trust payout, etc.)

If your profile includes any level of complexity—or if you simply want certainty—filing a ruling is an excellent strategic step.

How Move to Dolce Vita Can Help

At Move to Dolce Vita, Tax and Legal Advice in Italy, we have helped dozens of international clients successfully obtain tax rulings from the Italian Revenue Agency. Our approach is legal, strategic, and fully personalized.

We assist with:

  • Tax residency analysis and pre-assessment
  • Drafting and submitting the interpello request
  • Translation, legal argumentation, and formatting
  • Liaising with the Tax Agency during the process
  • Coordinating immigration, residence registration, and family inclusion
  • Post-ruling support with the actual application of the flat tax regime

Our founder, Marco Mesina, is an Italian tax lawyer with extensive experience advising global clients on the flat tax regime and relocation strategies.

Ready to Move with Confidence?

Italy’s flat tax regime offers an extraordinary opportunity. Filing a tax ruling in advance allows you to seize it with confidence, legal security, and full clarity.

Read our complete guide to the flat tax regime and our Q&A.

And if you're ready to move forward with professional support, contact us for a consultation.

We’ll help you structure your relocation the right way—before you take the leap.

Move smart. Plan ahead. Live beautifully.

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Move to Dolce Vita, Tax and Legal Advice in Italy.

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