UHNWI Advisory · Sub-hub

Non-Resident Clients

Integrated advisory for international UHNWI choosing Italy.

We support international individuals and families in evaluating and implementing the transfer of tax residency to Italy. The work integrates eligibility assessment, the art. 24-bis TUIR (Italian Income Tax Code, flat tax for new residents) regime, cross-border wealth structuring, real estate, banking/custody, and relocation, with coordination of advisors licensed in the relevant jurisdictions.

Scope

Who it's for.

The Non-Resident Clients sub-hub serves UHNWI who have not been tax-resident in Italy for at least 9 of the 10 prior years and are evaluating Italian residency with structured preparatory planning.

International entrepreneurs

Founders and significant shareholders with global businesses and foreign dividend flows considering Italy as a personal hub.

Post liquidity event

Individuals following a business sale or IPO, with significant liquid wealth and flexibility on residency.

Expatriate families

Italians abroad for more than 10 years planning their return, or foreign families with multi-jurisdictional wealth.

Senior global executives

Executives with significant foreign investment income considering Italy as a long-term residency jurisdiction.

Regulatory focus

Flat tax €300,000.
The Italian regime for new residents.

The special regime for new residents introduced by art. 24-bis TUIR and subsequently amended by the 2026 Budget Law provides a flat substitute tax on foreign-source income with 15-year stability. The figures shown reflect the legislation in force for residency transfers from January 1, 2026.

How the regime works

  • €300,000 annual flat substitute tax on foreign-source income (principal taxpayer, from 2026)
  • €50,000 additional per family member under the optional extension
  • 15 years duration, non-renewable
  • Scope: foreign-source income only; Italian-source income taxed under ordinary rules
  • Exemption from IVIE, IVAFE, and RW monitoring obligations on foreign assets
  • Option to exclude specific jurisdictions from the regime (one-time, irreversible)

Eligibility conditions

  • No Italian tax residency for at least 9 of the 10 prior tax years
  • Effective transfer of residency under art. 2 TUIR
  • Optional advance ruling with the Italian Revenue Agency to confirm applicability
  • Election exercised in the income tax return for the first year of residency
  • Available to Italian and foreign citizens on equal terms

Break-even economics

  • The economic benefit depends on the composition of foreign income, source countries, assets held, family members included, exit tax, double-tax treaties, and residual obligations in the country of origin.
  • Against ordinary IRPEF rates of up to 43% on foreign dividends for individuals, the break-even threshold drops
  • IVIE/IVAFE exemption (0.4% on foreign real estate + 0.2% on financial products) adds benefit on wealth above €10M
  • Absence of RW reporting significantly reduces the compliance burden for assets spread across multiple jurisdictions

Limits and caveats

  • Does not neutralize the risk of prior tax residency being challenged in the country of departure
  • Some jurisdictions do not recognize treaty status absent ordinary taxation
  • Requires advance planning around exit tax, existing trusts, and holding structures
  • Missed tax payment results in immediate forfeiture with no reinstatement
  • Effective residency requirements must be maintained throughout the period

Method

Four phases, partner-led.

Every Non-Resident Clients engagement follows a structured path, with a single senior point of contact and direct coordination of corresponding advisors in the relevant jurisdictions.

01

Preliminary assessment

Eligibility analysis, review of prior tax residency, mapping of wealth by jurisdiction, identification of challenge risks in the country of origin.

02

Ruling with the Revenue Agency

Coordination of the advance ruling request under art. 24-bis and the dialogue with the Italian Revenue Agency through licensed tax advisors. The objective is to reduce applicative uncertainty, not to promise an outcome.

03

Execution

Operational transfer of residency, setup of Italian bank accounts and holding structures, reorganization of existing trusts and vehicles.

04

Ongoing compliance

Recurring support on annual returns, maintenance of regime requirements, client reporting, regulatory updates.

Practices

Six practices for new residents.

Six service areas for individuals evaluating or completing the transfer of tax residency to Italy. Each practice combines technical expertise with integrated coordination of third-party advisors.

01

Flat Tax Activation

Coordination of activation of the art. 24-bis TUIR regime: ruling, filings, ongoing compliance.

→ 02

Tax Relocation

Planning the transfer of tax residency, assessment of special regimes, cross-border coordination.

→ 03

Wealth Structuring

Cross-border holdings, trusts, private foundations, investment vehicles, multi-jurisdictional estate planning.

→ 04

Real Estate & Art Holdings

Acquisition of luxury homes in Italy, tax-efficient holding structures, wealth management.

→ 05

Banking & Custody

Setup of bank and custody accounts in Italy and abroad, selection of depositary banks, coordination with private banking.

→ 06

Citizenship & Relocation

Investor Visa for Italy, European golden visas, family-wide relocation, coordination with immigration counsel.

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The team

Lead partner.

Gian Piero Sala

President

Chartered accountant since 1993, court-appointed expert (CTU) at the Tribunal of Milano (Milan). Cross-border M&A negotiations.

Riccardo Puddu Cortesi

Managing Partner

Business development and SME internationalization. Cross-border coordination with Montesino Associates LLC.