No benefits for “impatriates” coming from other group companies

The draft Italian Legislative Decree on international taxation (implementing Italian Law of 9 August 2023, no. 111, containing “Delegation to the Government for the revision of the tax system”) which contains the new regime for impatriate workers is currently being discussed in the Chamber of Deputies within the Italian Parliament. 

At present the text amends Article 16 of Italian Legislative Decree no. 147/2015, which regulates the regime governing impatriate workers’ employee income. 

Among the new features, the draft Decree provides that the provisions will not affect “registry” transfers which take place by the end of the year. Therefore, the “special” tax regime reserved for impatriate workers will also apply to those who have transferred their registered residence to Italy in the second half of 2023. 

Furthermore, the draft Decree provides that to fall within the category of impatriate workers during 2024, the work activity must be carried out in Italy with an employer other than the “foreign” one, including those belonging to the same group. 

We are therefore awaiting discussion of the draft Decree, which is currently under examination by the Chamber of Deputies, to assess any further changes to the text.