Europe’s private wealth landscape is changing.
For decades, London was one of the preferred European bases for internationally mobile high-net-worth individuals (HNWIs), entrepreneurs, and family offices. Its former non-domiciled tax regime allowed qualifying residents to limit UK taxation on certain foreign income and gains.
That system fundamentally changed on 6 April 2025, when the UK abolished the remittance basis and replaced it with a residence-based Foreign Income and Gains (FIG) regime. The new regime provides relief on qualifying foreign income and gains for only the first four years of UK residence for eligible new arrivals.
Against this backdrop, Italy has attracted growing attention from internationally mobile wealthy families.
At the center of Italy’s proposition is Article 24-bis of the Italian Income Tax Code (TUIR) , a special regime allowing qualifying new Italian tax residents to replace ordinary Italian taxation on eligible foreign-source income with a fixed annual substitute tax.
For individuals establishing Italian tax residence from 1 January 2026, that amount is €300,000 per year for the principal taxpayer.
But the appeal of Italy extends beyond a single tax number. For the right family, the combination of predictable taxation of foreign income, EU residence, Milan’s business ecosystem and Italy’s lifestyle infrastructure creates an increasingly distinctive European wealth proposition.
Why Italy Is Gaining Attention After the UK Non-Dom Era
The UK remains one of the world’s leading financial centers, but its tax proposition for internationally mobile wealth has changed substantially.
Since April 2025, the former remittance-basis system has been replaced by the FIG regime. Individuals who have not been UK tax resident during the previous 10 consecutive tax years may qualify for relief on eligible foreign income and gains during their first four years of UK residence. Outside that window, UK residents are generally subject to the normal arising-basis rules on worldwide income and gains.
This has changed the calculation for some long-term international residents considering where to establish their European tax base.
Italy offers a very different model. Rather than providing a short introductory exemption, Article 24-bis can apply for up to 15 tax years, subject to eligibility and continued compliance.
For investors with substantial foreign investment portfolios, dividends, business interests or capital gains, that longer planning horizon can be particularly relevant.
How Italy’s €300,000 Flat Tax Works
Article 24-bis is designed for individuals who transfer their tax residence to Italy after having been non-resident for Italian tax purposes for at least nine of the previous ten tax years.
For qualifying new residents from 2026, the regime allows eligible foreign-source income to be covered by an annual €300,000 substitute tax, rather than being taxed separately under Italy’s ordinary personal income tax rules.
Importantly, this is not a €300,000 cap on every Italian tax liability.
The regime primarily concerns qualifying foreign-source income. Italian-source income generally remains subject to ordinary Italian taxation.
This distinction is critical for entrepreneurs and family offices contemplating a move. A portfolio producing significant dividends or investment gains outside Italy may fall within the substitute-tax framework, while salary, business income, rental income or other income sourced in Italy may be treated differently.
What Does Article 24-bis Cover?
The regime can apply broadly to eligible foreign-source income, including investment income and capital gains, subject to specific sourcing rules and statutory exceptions.
Another important feature is its treatment of foreign assets. Where the relevant foreign jurisdiction remains within the Article 24-bis election, qualifying taxpayers may benefit from relief from certain ordinary Italian foreign-asset reporting and wealth-tax obligations.
The regime also provides flexibility through a form of “cherry picking.” A taxpayer may exclude one or more countries from the substitute-tax regime. Income from those jurisdictions then falls back under ordinary Italian taxation, potentially allowing applicable foreign tax credits or treaty treatment to be considered.
This can make Article 24-bis useful for families whose assets, businesses and investments are spread across several jurisdictions rather than concentrated in a single country.
What the Flat Tax Does Not Cover
The headline €300,000 figure should not obscure several important limitations.
First, Italian-source income is generally outside the substitute-tax regime and remains taxable under Italy’s ordinary rules.
Second, special rules apply to certain capital gains from substantial shareholdings during the initial years of the regime.
Third, moving to Italy can have implications extending beyond annual income tax. Trusts, holding companies, estate planning arrangements and the location of underlying assets should all be reviewed before tax residence changes.
For this reason, Article 24-bis should be viewed as a tax residency framework, rather than a blanket exemption from the Italian tax system.
Why Italy Appeals to HNWIs and Family Offices
For internationally mobile families, the attraction of Italy increasingly comes from the combination of fiscal and non-fiscal factors.
Long-term predictability. The regime may operate for up to 15 tax years, providing a substantially longer planning horizon than some temporary new-resident incentives elsewhere.
No traditional remittance-basis restriction. The Article 24-bis model is fundamentally different from the UK’s former non-dom regime. Qualifying foreign income covered by the substitute tax does not become ordinarily taxable merely because the money is brought into Italy.
European location. Italy offers a base inside the European Union with direct connectivity to Switzerland, France, Germany and other major European markets.
Business and financial infrastructure. Milan in particular has developed into an increasingly relevant center for private banking, asset management, fashion, technology, private equity and family-office activity.
Lifestyle considerations. For families actually relocating rather than simply acquiring a residence permit, Italy combines established international schools, healthcare, culture, real estate and connectivity with major European financial centers.
These factors help explain why Italy increasingly enters the same wealth-location conversations as Switzerland, Monaco and other established European hubs , although their tax and residence models remain fundamentally different.
Is Italy Becoming the “New Monaco”?
Calling Italy the “new Monaco” makes for an attractive headline, but the comparison has limits.
Monaco remains a highly specialized microstate built around private wealth and generally does not impose personal income tax on most residents. Italy is a large EU economy with a comprehensive tax system, and Article 24-bis represents a specific exception within that system.
Italy’s advantage is therefore different.
It allows qualifying individuals to combine Italian tax residence and EU lifestyle with a predictable annual tax treatment for eligible foreign income, without requiring them to isolate themselves in a traditional low-tax micro-jurisdiction.
For founders, investors and families who want to actually live in a major European economy, that distinction may matter more than simply finding the jurisdiction with the lowest headline rate.
Key Considerations Before Moving to Italy
Relocation should be planned before, not after, Italian tax residence begins.
Investors should review the sourcing of income and capital gains, corporate directorships, trusts and foundations, existing holding companies, foreign real estate, succession structures and double-tax treaties applicable to their circumstances.
For particularly complex structures, taxpayers may also seek an advance ruling from the Italian tax authorities to obtain greater certainty regarding eligibility and the treatment of specific assets or income streams.
The objective should not simply be to qualify for the €300,000 regime, but to ensure that the family’s immigration status, tax residence, corporate structures and estate planning remain aligned across jurisdictions.
Conclusion: Italy’s Emerging Role in European Wealth Migration
Italy’s Article 24-bis regime represents a distinctive approach to attracting internationally mobile private wealth.
For qualifying new residents from 2026, a €300,000 annual substitute tax on eligible foreign-source income, combined with a potential 15-year regime period, creates a level of predictability that may be particularly valuable to individuals with substantial international portfolios.
At the same time, the end of the UK’s traditional non-dom system has changed the competitive landscape. The UK now offers a four-year FIG regime to qualifying new residents rather than the former domicile-based remittance system.
Italy is therefore not simply a “cheaper Monaco” or a replacement for London. Its proposition is different: a major EU economy offering internationally mobile HNWIs a structured tax framework alongside the ability to establish a genuine long-term European home.
For family offices, entrepreneurs and investors evaluating a relocation, the central question is not simply whether €300,000 is an attractive tax figure. It is whether Italy fits the family’s broader combination of wealth structure, business interests, succession planning and long-term lifestyle objectives.
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