With response no. 263 of 20 March 2026, the Italian Tax Authority clarified the implementation of the new tax relief regime introduced by Art. 5 of Legislative Decree No. 209 of 27 December 2023 (the so-called “impatriates regime”) for impatriate workers (i.e., those who transfer their residence to Italy after a period of work abroad), with particular reference to work performed on a continuous basis for a foreign employer but under a remote work arrangement in Italy.
Specifically, the case brought to the attention of the Authority concerns an Italian citizen who has lived continuously in Finland for over 30 years, but whose family (including three minor children) has been residing in Italy since 2025. He is an employee of a private Finnish company, for which he currently works exclusively remotely but never on Italian territory.
In such a situation, the petitioner asks whether it is possible to apply the “impatriates regime” to income derived from a continuous employment relationship with a foreign employee – not operating in Italy and not belonging to a group with entities resident in Italy – where such activity is carried out entirely remotely in Italy. The petitioner also asks whether, considering the three minor children residing in Italy, the eligible income is included in the calculation of total income at the more favorable rate of 40%.
In this regard, the Authority responded that continuous work for the same foreign employer under a remote work arrangement from Italy does not preclude eligibility for the impatriates regime (which applies from the tax year in which residency is transferred and for the following four tax years), provided that the requirements set forth in Art. 5 of Legislative Decree No. 209/2023 are met and, in particular, provided that:
- the work activity is performed primarily in Italy, where the employee transfers his tax residence;
- the employee has met the minimum required period of residence abroad.
Finally, the Authority confirms that the increased tax benefit also applies if the worker eligible for the impatriates regime has minor children who were already residing in Italy prior to the worker’s return to Italy, provided that the children remain tax residents of Italy for the entire duration of the benefit.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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