flat tax FOR THE SUPER RICH
YOUR ANNUAL INCOME IS ABOVE 500K €?
THEN YOU MUST READ THIS:
Under the flat-tax regime, individuals who previously have not been tax residents of Italy and who transfer their tax residence to Italy will pay, instead of ordinary tax, a flat-rate substitute tax of € 100,000 per year on all their non-Italian sourced income for the next 15 years; each family member opting for the flat tax regime, will be subject to € 25,000 annual tax instead of € 100,000.
Under the flat-tax regime, foreign income subject to the flat tax includes:
Corporate income (with or without permanent establishment)
By opting for the new tax regime individuals might be exempt from:
Donations and inheritance taxes relating to assets and real estate owned abroad,
Tax on real estate owned abroad and from wealth tax on foreign financial investments;
Fulfilling the requirements provided by the foreign investments monitoring legislation, that is filing the RW reporting form (disclosure form to be attached to the Italian tax return with respect to any asset held abroad).
The flat tax does not apply to any Italian sourced income and on capital gains realised upon the transfer of non-Italian "qualified" shareholdings in the first 5 years after the election.
HOW TO APPLY?
The Tax Authorities have confirmed that the election of such regime must be made by the deadline for submitting the income tax return for the fiscal year during which the individual has become Italian tax resident or during the following fiscal year.
The taxpayer may submit to the Italian Tax Authorities a formal ruling reporting the following:
Taxpayer’s personal data, including Italian tax code;
Jurisdiction (or jurisdictions) under which the taxpayer has been tax resident during the previous fiscal years;
Jurisdiction (or jurisdictions) that the taxpayer wishes to exclude from the flat tax.
According to the recent guidelines, it has been clarified that a formal advanced ruling with the Italian Tax Authorities is not strictly mandatory; however it is advisable.
Furthermore, the ruling could be requested before the taxpayer moves to Italy; Italian Tax Authorities have up to 120 (180) days to approve or deny such request and such time could be spent to plan the move to Italy.
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