Italy's EUR 300,000 Flat Tax: Who Is Actually on It, What It Did to Prime Milan, and What a Non-Resident Pays to Buy

Article 24-bis of the Italian income tax code was introduced in 2017 at EUR 100,000 a year. Decree 113 of 2024 doubled it to EUR 200,000 for anyone transferring residence after 10 August 2024. Legge 199 of 30 December 2025, the Budget Law for 2026, took it to EUR 300,000 for transfers from 1 January 2026 and raised the family member add-on from EUR 25,000 to EUR 50,000. The Agenzia delle Entrate guidance confirms both new figures. It also confirms the 15-year maximum and the requirement to have been non-resident in nine of the ten preceding tax years.

Everything else survived intact. The payment covers all foreign-source income and gains. Foreign assets are exempt from IVIE and IVAFE, the wealth taxes on overseas property and financial holdings, and from the RW reporting form. Foreign-situs assets sit outside Italian inheritance and gift tax while the option runs. Italian-source income is taxed at ordinary rates, as are gains on qualified shareholdings sold within the first five years. Anyone who was resident by 31 December 2025 keeps the charge that applied when they opted.

The ministry's technical note to the Budget Law, as summarised by the tax advisory Fiscalità Patrimoniale, assumed about 270 new entrants a year on 2021 to 2023 data and expected the higher charge to cut that to about 130, for additional revenue of roughly EUR 14.5 million a year from 2027. The government judged that the people it wants are not price-sensitive at that level, and the arithmetic of a family paying EUR 350,000 on EUR 20 million of foreign income says it is probably right.

The Ministry of Economy and Finance publishes one official count. For the 2024 tax year, 1,631 taxpayers filed the quadro NR return that the regime requires. Of those, 48.4% also declared Italian-source income, EUR 102.5 million in total, and 73.3% of that was employment income. So roughly half the people on the regime work in Italy, which is a different population from the retired-rentier picture the flat tax is often given. No official figure for 2025 or 2026 exists yet.

The UK abolished non-dom status on 6 April 2025. Henley & Partners' Private Wealth Migration Report of June 2025 projected a net loss of 16,500 millionaires from the UK that year, the largest of any country, and a net gain of 3,600 for Italy, behind the UAE at 9,800 but ahead of Switzerland at 3,000. Its June 2026 report published no new flow forecasts at all. It replaced them with a competitiveness score, giving Italy 72.3 out of 100 and the UK 68.3, and reported that British citizens now make up about half of Henley's own applications, up from 8% in 2018. Tax Policy Associates has argued that the Henley figures cannot be measured and show patterns consistent with manual adjustment. Henley sells relocation. Its numbers are estimates, and the only hard count is the ministry's 1,631.

Tecnocasa's figures, reported by CNBC in September 2025, have Milan prices up 49% since 2017 against 10.9% across Italy's other large cities. The Engel & Völkers and Nomisma Market Report Italia 2026 puts prime Milan at EUR 10,000 to 23,000 per square metre, with peaks of EUR 27,000. Immobiliare.it's citywide asking price for the first half of 2026 was EUR 5,675, up 2.6%. The historic centre sits around EUR 11,200 on OMI and Immobiliare.it data, with Brera and the Quadrilatero at EUR 10,000 to 12,000. Knight Frank's Wealth Report 2026 has USD 1 million buying about 45.8 square metres of prime Milan at the end of 2025, down from about 60 in 2020.

The growth has slowed at the top. Knight Frank says prime Milan only edged up in 2025, and summaries of its PIRI index cite 0.4% for Milan against 6.5% for Lake Como. The rental market moved first: in December 2024 Knight Frank's Bill Thomson told The Telegraph that prime Milan rents were up 10% on the year with deal volumes up 30% and London enquiries doubled, and Sotheby's reported most deals between EUR 15,000 and 30,000 a month. New arrivals rent before they buy. The purchase data for 2026 is the lagging indicator of a rental surge that began the winter before non-dom status ended.

The Lake Como range is wide because the two sources measure different things. One is a report headline for the lake as a whole, the other a broker quote for specific lakefront villages. Carry both numbers. Anything priced at the top of the report range is a negotiation. Nationally, the Engel & Völkers report has foreign buyers at 35% of luxury purchases, rising to 52% in central Italy and 65% in Florence. Transactions across the whole market reached 766,757 in 2025, up 6.4%, with Milan at 25,173 and Rome at 37,293, and the first quarter of 2026 added another 4.4% on the Agenzia delle Entrate's count.

The purchase taxes are the same whether or not the buyer is on the flat tax, because the regime covers foreign income and says nothing about Italian property. A resale from a private seller carries 9% registration tax for a second home or a non-resident, charged on the cadastral value rather than the price, plus EUR 50 each in fixed cadastral and mortgage taxes. The 2% prima casa rate requires the buyer to take up residence in the municipality within 18 months. A new build from a developer carries VAT at 10%, or 4% for a main home, or 22% for the luxury cadastral categories A/1, A/8 and A/9, plus EUR 200 in each fixed tax. IMU, the annual property tax, runs from a base of 0.86% to a municipal maximum of 1.06% of the cadastral value, and non-residents get no main-home exemption. A gain on a sale inside five years is taxed at 26%.

Short lets have tightened. Every property let for short stays needs a national identification code, the CIN, with fines of EUR 500 to 8,000 for letting without one. The cedolare secca flat rate is 21% on the first property and 26% on the second, and from three properties the activity is a business with VAT and no flat rate. The threshold was five. Florence, Venice, Rome, Milan and Bologna each add local restrictions. For a family on the EUR 300,000 regime none of this is likely to matter. A buyer counting on short lets to fund an apartment in one of those five cities now finds the rules cap the number of properties, the platform listing and the tax rate at once.

The visa is the separate hurdle for non-EU families. The Investor Visa needs EUR 250,000 in an innovative startup, EUR 500,000 in an Italian company, EUR 1 million in philanthropy or EUR 2 million in government bonds, gives a two-year permit renewable for three, has no minimum stay, and is suspended for Russian and Belarusian nationals. The Elective Residence Visa needs proof of passive income, with advisers quoting a floor of around EUR 31,000 a year, and does not permit work. A Gulf or Asian family will usually pair the flat tax with one of these two. A British family does not need either, and that, more than the tax rate, is why the ministry's 2024 return shows Italian employment income on half the filings.