The provisions under Article 44 of Decree Law 78/2010 outline conditions for excluding 90% of the earnings of academics and researchers relocating their residency to Italy from their taxable income.

Transfer of Tax Residency

This benefit applies from the tax period in which the academic or researcher becomes tax resident, as per Article 2 of the Tax Consolidation Act (TUIR), in the territory of Italy.

Regulation for Transfers to Italy Until 2019

Characteristics of the Incentive

Reserved for academics and researchers who come to Italy to carry out their teaching and research activities.

Specifically:

  • Limited to university graduates.
  • Available to all individuals, both EU and non-EU citizens.
  • Allows work in Public Administration.

Extent and Duration of the Incentive

Income from employment and self-employment income carried out in Italy for teaching and research purposes is considered for 10% of the total income (thus, 90% is excluded).

The incentive applies for 4 years from the acquisition of tax residency, with the option to extend under certain conditions.

Requirements

  • Having resided abroad non-occasionally.
  • Possessing a university degree or equivalent.
  • Having worked in teaching or research abroad for 2 years at public or private research centers or universities.
  • Transferring tax residency to Italy.
  • Engaging in teaching and research activities in Italy.

Documentation of Research Activity

Research entities include universities, research institutes, etc., regardless of their legal status. Teaching can be conducted at public and private institutions.

Documentation from research centers or universities should attest to the nature of the entity, the activities performed, and their duration.

Duration of Research or Teaching Activity Abroad

The activity must have been carried out abroad for a minimum and uninterrupted period of 24 months before returning to Italy.

For teaching, 2 consecutive academic years are required.

Subjects Not Registered with the AIRE

Italian academics and researchers not registered with the Registry of Italians Residing Abroad (AIRE) who returned to Italy by December 31, 2019, are entitled to tax benefits as per the previous regime, provided they were residents in another state under a double taxation agreement.

Duration of the Incentive

In general, the incentive applies for 4 years from the acquisition of tax residency.

There's an option to extend the duration up to 8, 11, and 13 years under certain conditions.

Regulation for Transfers to Italy from 2020

Amendments introduced by Decree Law 34/2019 extend the duration of the fiscal benefit from 4 to 6 years.

The extension to 8, 11, and 13 years is possible with specific conditions (depending on family size).

Italian academics and researchers not registered with AIRE returning to Italy from January 1, 2020, may access the new version of the incentive under certain conditions.

De Minimis Regime

The incentive falls within the limits of the de minimis regime.

Compatibility with Other Benefits

These incentives cannot be cumulated with other benefits for the same tax period.

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