Neo-Domiciled HNWI (High Net-Worth Individuals)
Back in 2024 Italy has increased the tax rate in its special flat tax regime (regime forfettario per neo-residenti) from 100.000 EUR up to 200.000 EUR increasing by this measure also the limits which the HNWI need to reach in their countries before the move to Italy becomes attractive.
The flat tax regime for new residents was first introduced back in 2017 and attracted thousands of wealthy people from around the world since its introduction.
It is important to keep in mind that this tax regime applies only to new tax residents, not to existing ones. This fact can also be beneficial as the existing tax residents already using the flat tax continue to benefit from the tax amount of 100.000 EUR until the end of their individual regime validity.
HNWI customers wishing to get into this regime need to comply with the following rules:
- Not being a tax resident in Italy for the last 9 years out of 10 before moving the tax residency
- Transfer tax residency to Italy
- Provide sufficient evidence of previous residency abroad and the relocation to Italy
- File a request (interpello) to the local tax authorities
Once approved, the flat tax regime is valid for 15 consecutive years. But if it is abandoned in the course of validity, it cannot be reactivated afterwards.
The applicant can also include his family members in the application. For each additional family member, the flat tax increases by 25.000 EUR. It means that a couple without children would need to pay a flat tax of 225.000 EUR if applied for it in the year 2025 or 125.000 EUR if the application was approved before the change.
Depending on where your current tax residency is, the thresholds for the relocation might be different.
Let’s have a look at few countries within Europe and check what would be the threshold of attractiveness in each of them assuming that we check for a couple without children. For simplicity reasons we assume that the amount is a pure taxable amount.
France
In France, a couple without children might reach the tax level of 225.000 EUR when the taxable amount is around 595.000 EUR per year. French tax calculator can be found here: https://simulateur-ir-ifi.impots.gouv.fr/cgi-bin/calc-2025.cgi
Germany
In Germany, a couple can reach the tax threshold of 225.000 EUR when having a taxable income of 560.000 EUR per year. The German tax calculator can be found here: https://www.bmf-steuerrechner.de/ekst/eingabeformekst.xhtml?ekst-result=true
Switzerland
The situation in Switzerland is a bit more complex, as each canton has its own tax rates and even each town (Gemeinde) has its own tax levels. Let’s assume that our comparison couple lives at the Golden Coast of Zurich lake in a nice town of Küsnacht which offers one of the lowest local tax rates in canton Zurich.
In order to reach the total taxes (federal, cantonal and communal) to the level of 225.000 EUR (or somewhat around 209.000 CHF) the couple residing in Küsnacht would need to earn a taxable income of 718.000 CHF or approximately 772.000 EUR.
Tax calculator covering all cantons and towns in Switzerland can be found here: https://en.comparis.ch/steuern/steuervergleich/steuerrechner
UK
To reach the level of 225.000 EUR (or roughly 196.000 GBP) of income tax, you would need to have an annual income of 347.000 GBP or roughly 399.000 EUR. The UK tax calculator can be found here: https://www.gov.uk/estimate-income-tax
As we can see, UK residents reach the threshold much faster than residents in other three countries. Compared to Switzerland, it is nearly the half of the revenues which would cause the same level of taxes. No wonder that the fact of abolishing the non-dom taxation by the UK government has caused an increased interest in the Italian flat tax by UK residents.
France has already accused Italy of “fiscal dumping”: https://www.lemonde.fr/en/economy/article/2025/09/02/italy-retorts-after-fiscal-dumping-remarks-by-french-mp-bayrou-revive-tensions_6744959_19.html
But actually, creating conditions acceptable for both – the country (Italy) and the migrants (HNWI) – is not a crime. It is an economic balance with benefits for both parties involved. It creates competition between the states allowing also to France, Germany, UK or any other country to revise what they do wrongly in order to attract HNWI. It is not by creating new restrictions, imposing higher income taxes or being creative with exit taxes that a government could make its country more attractive to wealthy people and win fresh capital.
Retirees
Italy seems to be positively creative also towards other groups, like retirees. Retirees moving over from abroad to Southern Italy (Abruzzi, Apulia, Basilicata, Calabria, Campania, Molise, Sardinia, Sicily) into towns with no more than 20.000 inhabitants may benefit from a flat tax of 7% only.
The applicant should have had his tax residency outside Italy for at least 5 years before moving to the mentioned regions and should receive his pension (or other similar annuities) from outside of the country.
On top, an international agreement about an administrative cooperation between Italy and the original state of the applicant should exist (like it is the case with the EU countries or with Switzerland).
Once approved, retirees can benefit from the flat tax for the duration of 10 years.
For someone who does not want to completely leave Europe to whatever reasons, Italy can be a perfect choice.
On the other hand, if someone is willing to relocate, why not relocate directly to one of the countries with the territorial taxation scheme or without any personal taxes? We have quite few countries in our portfolio which do not tax your income coming from outside of the country at all.
Specifically for German customers: Singabiz cooperates with a legal advisor in Germany who can help our customers to prepare the exit and to optimize the exit taxes in Germany. The planning should ideally happen in advance in order for you to be able to prepare the necessary setup correctly.
If you need any assistance or are interested in further information do not hesitate to contact us and one of Singabiz representatives will be glad to help you.
