Italian Budget Law 2026: key developments for Family Offices and non-dom individuals
Michele Saletti, Founder & Partner of TEMPORA Tax&Legal, took part as a speaker in the second edition of the webinar organised by Across Family Advisors, focused on the key developments introduced by the Italian Budget Law 2026, with specific reference to Family Offices and international private clients.
The contribution addressed the recent amendments to the Italian non-dom regime under Article 24-bis of the Italian Income Tax Code (ITCA), with particular focus on the following aspects:
Increase of the flat tax for new residents
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increase from €200,000 to €300,000 per year for the main applicant;
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increase from €25,000 to €50,000 per year for qualifying family members.
The new thresholds apply to individuals transferring their civil law residence in Italy pursuant to Article 43 of the Italian Civil Code as from 1 January 2026.
As a best practice, the filing of a ruling request (interpello) with the Italian Tax Authorities remains strongly advisable.
Confirmation of grandfathering rules
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€100,000 flat tax for individuals who transferred their residence up to 10 August 2024;
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€200,000 flat tax for individuals falling within the transitional phase between the two legislative amendments.
Unchanged core features of the regime
All other structural elements of the non-dom regime remain unchanged, including:
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the “9 out of 10 years” requirement;
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the 15-year duration of the regime;
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the interpretative guidance provided by the Italian Tax Authorities, in particular Circular Letter No. 17/E of 2017.
Investor Visa for Italy
The Investor Visa for Italy programme remains fully unchanged, continuing to provide a stable visa and residence permit framework for non-EU investors.
📌 Despite the recent amendments, Italy continues to rank among the limited number of jurisdictions considered attractive for the relocation of HNWI and UHNWI individuals, particularly in the context of international wealth planning and Family Office structures.
The discussion benefited from the contributions of
Stefano Capaccioli, Marco Finocchi Finn, Edoardo Persico, Marco Sandoli, TEP, and Pietro Michele Villa,
and was moderated by Fabrizio Vedana.