On 14 September 2026, boutique tax firm Zanovello & Partners released a client circular summarising long-awaited clarifications from Italy’s Revenue Agency on the “Regime degli Impatriati”, the incentive that halves personal income tax for returning workers. The Agency finally defines the notion of “previous foreign residence” introduced by Legislative Decree 209/2023, confirming that applicants must have been tax-resident abroad for at least two consecutive years out of the ten preceding their move—rather than the five years originally hypothesised. The circular explains that fragmented periods abroad can be aggregated as long as the taxpayer can demonstrate effective residence through certificates of fiscal domicile, rental contracts or employment records. For posted workers who maintained an Italian address on the population register (AIRE), substance prevails over form: objective evidence of centre-of-life abroad will suffice. For employers this is crucial. Many multinational groups had frozen offers to Italian talent abroad, fearing claw-backs if the residence test were interpreted restrictively. With the two-year rule confirmed, HR can safely model after-tax packages for assignments starting 1 January 2027, when the new regime replaces the old Article 16 of Decree 147/2015. The document also clarifies that the impatriate benefit cannot be combined with the €100 000 flat tax for new residents, aligning the two regimes with existing anti-abuse rules. Payroll departments must therefore collect a written declaration from incoming staff on which incentive they intend to use. Zanovello notes that a Revenue Agency ruling is expected by year-end to digitise the application via the “Piattaforma Lavoratori Impatriati”, cutting processing times to 30 days. Companies planning mass transfers should prepare documentation early, as a rush of filings is anticipated in Q1 2027.
Source: Studio Zanovello and Partners
