Can I combine Italy's flat tax for new residents with the impatriate regime from 2027?

No. Article 2 of Decree-Law 38/2026, converted by Law 88/2026, adds the new impatriate regime (Article 5 of Legislative Decree 209/2023) to the reliefs that cannot be combined with the flat tax, for people who move their tax residence to Italy from tax year 2027.

Does it affect people who moved before 2027?

Paragraph 2 of Article 2 says the rule applies to people who transfer their tax residence to Italy from tax year 2027. Earlier movers are outside that text, but each regime's own conditions still apply.

How much is the flat tax for new residents?

For people who moved their residence to Italy from 1 January 2026, the substitute tax on foreign income is EUR 300,000 per year, plus EUR 50,000 for each family member included in the option.

What does the impatriate regime give?

Only 50% of employment and self-employment income produced in Italy is taxed, up to EUR 600,000 a year, for the year of the move and the next four; 40% if you move with a minor child.

Which other reliefs were already excluded?

According to the parliamentary research dossier, the returning researchers incentive (Article 44 of Decree-Law 78/2010) and the old impatriate regime (Article 16 of Legislative Decree 147/2015).

Italy flat tax and impatriate regime: no combining in 2027

By Francesco Bonifazi, Co-founder and CTO of Relomatrix · 11 November 2026 · Also available in Italiano

From tax year 2027, people who move their tax residence to Italy can no longer combine the flat tax for new residents with the impatriate regime for workers. Article 2 of Decree-Law 38 of 27 March 2026 sets this rule, and Law 88 of 22 May 2026 converted it without changing that article.

This matters most for people with large foreign income who also plan to work in Italy, for example Americans relocating with a US portfolio and an Italian job. See also our guide to the US-Italy totalization agreement.

TL;DR

What changes: the impatriate regime of Legislative Decree 209/2023 joins the reliefs that cannot be combined with the flat tax.
From: people who transfer tax residence to Italy from tax year 2027.
Law: Article 2 of Decree-Law 38/2026, converted by Law 88/2026.
Flat tax today: EUR 300,000 a year on foreign income, plus EUR 50,000 per family member, for moves from 2026.
Impatriate regime: 50% of Italian work income taxed, up to EUR 600,000 a year.

What the law says

Article 2 amends paragraph 154 of Article 1 of Italy's 2017 budget law (Law 232/2016). In the consolidated text published in the Official Gazette, that paragraph now says the effects of the flat tax option cannot be combined with those of:

Article 44 of Decree-Law 78/2010 (returning teachers and researchers);
Article 16 of Legislative Decree 147/2015 (old impatriate regime);
Article 5 of Legislative Decree 209/2023 (new impatriate regime), added by Decree-Law 38/2026.

Paragraph 2 limits the change to people who transfer their tax residence to Italy from tax year 2027.

Why it changed

The research dossier of the Italian Chamber and Senate says the aim, stated in the government's explanatory report, is to restore the ban that already applied to the old impatriate regime. The 2023 regime had not been listed. The dossier also notes that the Revenue Agency, in ruling 159 of 2024, had allowed the impatriate regime for people who had opted for the flat tax, while barring both in the same tax year.

The two regimes side by side

	Flat tax for new residents	New impatriate regime
What it covers	Income produced abroad	Employment, similar and self-employment income produced in Italy
How	Fixed substitute tax: EUR 300,000 a year (moves from 2026), EUR 50,000 per family member	50% of income taxed (40% with a minor child), up to EUR 600,000 a year
Time abroad required	Not Italian resident for at least 9 of the previous 10 tax periods	Not resident in the previous 3 tax periods (6 or 7 if staying with the same group)
Length	Under the rules of Article 24-bis of the income tax code	Year of the move and the next four, with a commitment to stay 4 years

Figures as reported in the parliamentary dossier on Decree-Law 38/2026.

What to do if you move in 2027

If you plan to move your tax residence to Italy in 2027 or later and have both significant foreign income and Italian work income, you will need to choose one regime, because their effects can no longer be combined. The answer depends on how your foreign income compares with your Italian earnings. Italy's new consolidated income tax code (Legislative Decree 117/2026) also reorganises these rules, so check the version that applies to your year of arrival with an adviser.

For a first view of your move, try a Relomatrix Snapshot. If you are planning the reverse move, read our guide to Italy's proposed 2027 exit tax and the one on the Italy digital nomad visa.

FAQ

Can the two be combined from 2027? No, for people moving their tax residence to Italy from tax year 2027.

Am I affected if I moved in 2026? The text applies only to moves from 2027.

Is it final? Yes, Decree-Law 38/2026 was converted by Law 88/2026 and Article 2 was not amended.

How much is the flat tax? EUR 300,000 a year for moves from 2026, plus EUR 50,000 per family member.

General information, not tax or legal advice. Check your case with the Italian Revenue Agency or a qualified adviser.

Sources

Consulted on 11 November 2026.