What the Programme Is
Article 24-bis of the Italian Consolidated Income Tax Code (TUIR) allows individuals who transfer their Italian tax residence to pay a substitute flat tax of €100,000 per year on all income produced abroad. Unlike the 7% programme, there is no income ceiling, no regional constraint (it is available nationwide including Rome, Florence, Milan, and Lake Como), and the programme runs for fifteen years rather than ten.
The trade-off: €100,000 per year regardless of how much foreign income you actually have. The break-even versus the 7% programme is approximately €1.43M in annual foreign income — above that level, the €100K fixed charge produces a lower effective rate than 7%.
Who It Suits
The €100K regime suits ultra-HNW American buyers with substantial foreign income who want to establish Italian residency in a major city or premium property market not covered by the 7% programme's southern municipality constraint. The typical profile: annual foreign income of €2M+, a preference for Lake Como, Tuscany, Rome, or Florence as a base, and a long-term residency intention of 15 years or more.
How It Compares to the 7% Programme
| Feature | 7% Programme | €100K Programme |
|---|---|---|
| Rate / charge | 7% of all foreign income | €100,000 fixed per year |
| Duration | 10 years maximum | 15 years |
| Geographic constraint | Under-20K municipalities, southern regions only | Nationwide — no constraint |
| Break-even income | Any level — 7% always applies | ~€1.43M foreign income/year |
| Family inclusion | €1,500/year per additional member | €25,000/year per additional family member |
Residency Requirements
The €100K programme requires genuine Italian tax residency — anagrafe registration and spending the majority of the calendar year in Italy. The Italian Revenue Agency has increased scrutiny of flat-tax elections where physical presence is not demonstrable. A buyer who purchases a €4M Como villa but spends only 60 days per year in Italy cannot validly claim the regime. This is not theoretical — it is a compliance risk that your Italian commercialista must advise on specifically.
US Tax Interaction
The United States taxes its citizens on worldwide income regardless of Italian tax elections. The US-Italy tax treaty and Foreign Tax Credit mechanism apply. The €100,000 Italian payment may be claimed as a foreign tax credit against US tax liability on the same foreign income, but the calculation — given the fixed-charge nature of the Italian tax versus the income-proportional US tax — requires specific modelling. FBAR and FATCA reporting obligations remain for all qualifying foreign accounts.