The little-known tax rule that’s got the super-rich flocking to Italy

Wealthy non-Italians are moving to Italy in droves after the country introduced a flat tax on even the biggest of overseas fortunes.

The little-known tax rule that's got the super-rich flocking to Italy
Areas like Portofino, Capri and the Amalfi Coast are popular with the rich. Photo: Deposit Photos

Estate agents in some of Italy's most sought-after destinations say they're now selling more luxury properties than ever before, with the tax break attracting some of the world's wealthiest people to the country.

Introduced in 2017 as part of a budget package hoped to attract wealthy investors to Italy, the “substitutive tax” rule for “resident non-domiciled” taxpayers allows anyone who has not lived in Italy for nine out of the last 10 years to apply to pay a flat €100,000 annual tax on all income generated outside Italy.

One property near Liguria listed for sale at over €10m is attracting interest from overseas. Photo: Lionard Luxury Real Estate

Any income generated within Italy would still be subject to regular Italian tax rules.

When the rule was introduced there was an immediate spike in interest from wealthy buyers looking to relocate to Italy for tax purposes, one estate agent told The Guardian.

Demand faltered slightly following last year's election, amid fears that the country's new populist government would scrap the rule.

But the government has now confirmed the flat tax for the super-rich is here to stay for at least another fifteen years.

A person is considered an Italian resident for tax purposes if they are in the country for more than 183 days, or six months.

The flat tax also applies to inheritance payments and money brought into Italy from overseas.

The benefits can be extended to applicants' family members for an annual charge of €25,000 per person.

Property on the Italian island of Capri is highly sought after by the super-rich. Photo: Depositphotos

Italy's tax scheme has been compared to similar rules in Jersey, the Isle of Man, or Switzerland.

Some 350-400 people applied to move their tax domicile to Italy and take advantage of the law in 2017 and 2018, according to Italian government figures.

READ ALSO: The richest Florence families in 1427 are still rich today

Fabrizio Pagani, until recently the chief of staff to the Italian minister of finance, described the applicants as “people from the UK, Switzerland, Russia, from the US, the usual suspects”.

Estate agents say the multi-million euro properties most sought after by Italy's wealthy new residents tend to be concentrated in popular holiday destinations, such as Florence, Milan, Lake Como, Rome, Capri and the Amalfi coast.

Tax avoidance costs governments worldwide about $650 billion (€583 billion) per year in lost revenue, according to International Monetary Fund estimates.


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How much does it cost to raise a child in Italy?

How big is the financial commitment parents have to make in Italy to pay for their offspring’s needs and expenses until they’re grown up and independent? Here's a look at the predicted costs.

How much does it cost to raise a child in Italy?

Family is the bedrock of Italian society, but it’s also an unbalanced economic crutch, propping up children who leave home much later than most of their European counterparts.

Various factors are at play, from a declining birth rate, youth unemployment, being unable to get on the property ladder to young Italians moving abroad in search of better financial opportunities.

It probably comes as little shock, then, that parents in Italy end up forking out huge sums of cash to support their offspring through childhood and early adulthood (and beyond).

Even just up to the age of 18, raising a child in Italy can cost upwards of €320,000, according to data from Italian consumer research body ONF (Osservatorio Nazionale Federconsumatori).

The average spend of raising a child from 0-18 years is €175,642, but it rises in families with high incomes, classed as over €70,000 per year.

READ ALSO: Italian class sizes set to shrink as population falls further

Researchers noted that the cost of bringing up children has jumped up following the effects of the pandemic too: compared to 2018, child-rearing expenses increased by 1.2 percent by 2020.

The decrease in expenditure related to transport due to spending more time at home, as well as those incurred for sports and leisure activities, was not enough to mitigate the increase in costs for housing and utilities, which increased by 12 percent compared to 2018.

Photo by Suzanne Emily O’Connor on Unsplash

Food prices rose by 8 percent compared to 2018 and education and care jumped by 6 percent for the same timeframe.

In fact, Italy ranks as the third most expensive country in the world for raising children, only coming behind South Korea and China, according to data from investment bank JEF.

The pandemic has contributed to extending an already growing phenomenon: the decrease in annual income of Italian households.

Household income dropped by 2.8 percent from 2019 to 2020, the report found, citing data from national statistics agency Istat. It marks a further squeeze for families, especially low-income and single-parent families.

Depending on earnings, the amount needed to bring up a child until the age of 18 varies considerably.

READ ALSO: ‘Kids are adored here’: What being a parent in Italy is really like

A two-parent family with an annual income of €22,500 spends an average of €118,234.15 to bring up a child until the age of 18; for the same type of family but with an average income of €34,000 per year, the total expenditure to bring up a child increases to €175,642.72.

For high-income families, stated as over €70,000 annually, raising a child costs €321,617.36 on average.

The figures mark an increase of around €5,000 for low- and middle-income families, and a much sharper rise of €50,000 for high-income families, compared to ten years ago.

The money gets spent on housing, food, clothing, health, education and ‘other’ categories. The report revealed that the average spend on a child aged 16 years old is almost €11,500 annually, amounting to €955.78 per month.

Almost €2,000 per year gets spent on food, €1,615 goes on transport and communication, €782 goes on clothing and €1,600 goes on education annually, the report found.

They begin small, yet the costs are anything but. (Photo by LOIC VENANCE / AFP)

For the ONF, “these data highlight how, today more than ever, having a child is becoming a luxury reserved for the few, which fewer and fewer Italians are able to afford.”


The numbers on supporting children after their 18th birthday are a little hazier, as when children eventually fly the nest varies – but figures from Eurostat show that Italy ranks third in Europe for the average oldest age at which children move out of the parental home, at 30.2 years old.

Only young people from Croatia and Slovakia wait longer to live independently, while the EU average for flying the nest is 26.4 years old.

Even then after eventually leaving home at over 30 years old, it’s not entirely clear how many Italians are fully independent once they get their own address, or whether their parents continue to bankroll their living costs.

Italy’s president Sergio Mattarella sent a message to Italy’s Birth Foundation (Fondazione per la Natalità) in May stating, “The demographic structure of the country suffers from serious imbalances that significantly affect the development of our society.”

In response to worsening economic circumstances, the Italian government has recently pledged to do more to help people have families and reverse Italy’s continuing declining birth rate.

It has introduced the Single Universal Allowance (L’assegno unico e universale), but along with it has dropped various so-called ‘baby bonuses’ that provided lump sums to new parents.

The new allowance is a monthly means-tested benefit for those who have children, or are about to have a child. It is payable from the seventh month of pregnancy until the child reaches the age of 18 or in some cases, 21. For more information on what it is and how to claim it, see here.