| S N S / International Clients |
The Italian Non-Dom Regime and Real Estate Investment (Updated 2025)
The Italian “non-dom regime” (Article 24-bis of the TUIR, introduced by Law 232/2016 and amended in 2024) is one of the most attractive opportunities for High-Net-Worth Individuals (HNWIs) and international families relocating to Italy. It combines tax certainty, international recognition, and the chance to invest in Italian real estate under favorable conditions.
Eligibility:
The regime is available to individuals transferring their tax residence to Italy who have not been tax resident in Italy for at least nine of the ten years prior to relocation. Both Italian citizens and foreign nationals can apply. The option is exercised in the annual tax return; a preliminary ruling from the Italian Revenue Agency is possible but not mandatory.
Main advantages:
-
Foreign-source income is subject to a substitute flat tax. For new residents relocating after 10 August 2024, the amount is € 200.000 per year, regardless of the actual income. The regime can be extended to family members with an additional € 25.000 each.
-
The regime lasts up to 15 years, with the possibility of early termination.
-
Exemptions apply from IVIE (tax on foreign real estate), IVAFE (tax on foreign financial assets), and from reporting foreign assets in the RW form, subject to specific caution for qualifying shareholdings during the first five years.
-
No Italian inheritance or gift tax applies to assets located abroad; only Italian assets remain subject to domestic inheritance and gift rules.
-
The regime is internationally recognized as stable and competitive and facilitates relationships with private banks, wealth managers, and family offices.
Limitations:
Capital gains on qualifying foreign shareholdings realized within the first five tax years are excluded from the regime and subject to ordinary taxation. Taxpayers may also opt to exclude one or more countries (“cherry picking”): in this case, all income sourced in those jurisdictions is taxed in Italy under ordinary rules, with possible foreign tax credits.
Link with real estate investment:
Acquiring property in Italy under the non-dom regime allows HNWIs to combine Italian residency with efficient tax planning. Italian properties are subject to local taxation, while foreign assets remain shielded by the flat tax. Real estate purchases can be structured through direct ownership, companies, or trusts, always under notarial supervision. Succession planning becomes more straightforward: Italian properties fall under Italian law and taxation, while foreign wealth remains excluded from Italian inheritance and gift tax.
Our role:
At | S N S | – Milan & Brescia, we assist HNWIs and international families in structuring real estate acquisitions in Italy, coordinating cross-border tax and estate planning, and ensuring compliance with Italian, EU, and international legal frameworks. This approach guarantees not only efficient tax planning but also legal certainty in high-value real estate transactions.
| S N S / International Clients |
The Italian Non-Dom Regime and Real Estate Investment (Updated 2025)
The Italian “non-dom regime” (Article 24-bis of the TUIR, introduced by Law 232/2016 and amended in 2024) is one of the most attractive opportunities for High-Net-Worth Individuals (HNWIs) and international families relocating to Italy. It combines tax certainty, international recognition, and the chance to invest in Italian real estate under favorable conditions.
Eligibility:
The regime is available to individuals transferring their tax residence to Italy who have not been tax resident in Italy for at least nine of the ten years prior to relocation. Both Italian citizens and foreign nationals can apply. The option is exercised in the annual tax return; a preliminary ruling from the Italian Revenue Agency is possible but not mandatory.
Main advantages:
-
Foreign-source income is subject to a substitute flat tax. For new residents relocating after 10 August 2024, the amount is € 200.000 per year, regardless of the actual income. The regime can be extended to family members with an additional € 25.000 each.
-
The regime lasts up to 15 years, with the possibility of early termination.
-
Exemptions apply from IVIE (tax on foreign real estate), IVAFE (tax on foreign financial assets), and from reporting foreign assets in the RW form, subject to specific caution for qualifying shareholdings during the first five years.
-
No Italian inheritance or gift tax applies to assets located abroad; only Italian assets remain subject to domestic inheritance and gift rules.
-
The regime is internationally recognized as stable and competitive and facilitates relationships with private banks, wealth managers, and family offices.
Limitations:
Capital gains on qualifying foreign shareholdings realized within the first five tax years are excluded from the regime and subject to ordinary taxation. Taxpayers may also opt to exclude one or more countries (“cherry picking”): in this case, all income sourced in those jurisdictions is taxed in Italy under ordinary rules, with possible foreign tax credits.
Link with real estate investment:
Acquiring property in Italy under the non-dom regime allows HNWIs to combine Italian residency with efficient tax planning. Italian properties are subject to local taxation, while foreign assets remain shielded by the flat tax. Real estate purchases can be structured through direct ownership, companies, or trusts, always under notarial supervision. Succession planning becomes more straightforward: Italian properties fall under Italian law and taxation, while foreign wealth remains excluded from Italian inheritance and gift tax.
Our role:
At | S N S | – Milan & Brescia, we assist HNWIs and international families in structuring real estate acquisitions in Italy, coordinating cross-border tax and estate planning, and ensuring compliance with Italian, EU, and international legal frameworks. This approach guarantees not only efficient tax planning but also legal certainty in high-value real estate transactions.