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Updated: June 2026

Case study · Italy · Residence permit

How a high-net-worth individual locked in a fixed tax rate of €100,000 per year when relocating to Italy

In tax regimes, the timing of entry is as important as the rate itself: those who opt into the regime earlier lock in their conditions for years to come. Our high-net-worth client was relocating to Italy and wanted to take advantage of the special regime for new residents—a fixed tax on foreign-source income. Timing proved to be key. We explain how we secured for him a rate of €100,000 per year at the right moment.

Dmitry NagyDmitry NagyInternational Tax Consultant, BRIDGESReading time9 min readVerificationReviewed by an expert

This case is based on a real matter. The name and certain identifying details have been changed to protect confidentiality.

BRIDGES client story - How a high-net-worth individual locked in a fixed tax rate of €100,000 per year when relocating to Italy
Contents

Case at a glance

Situation, solution and outcome in seven lines

Client
High-net-worth individual with foreign-source income, from Yekaterinburg
Objective
Relocation to Italy + preferential tax regime
Program
Italy, Investment Residence Permit (Investor Visa for Italy)
Key considerations
Locking in the rate before its increase
Regime
Non-resident: fixed tax on foreign-source income
Solution
To properly register and opt into the regime in time
Result
Rate of €100,000 per year locked in for the duration of the regime

Client story

Client's story

Where they started

The client faced a typical situation for a high-net-worth individual: primary income was generated outside Italy—from foreign assets, business operations, and investments. Upon relocation to the country, such income would normally be subject to high progressive tax rates under the standard regime, making the relocation economically unfavorable.

Why the standard route did not work

Italy offers a special non-resident regime (regime forfettario per neo-residenti) for such cases: instead of standard taxation, a new resident pays a fixed annual amount on all foreign-source income, regardless of amount, and is exempt from tax on foreign assets, inheritance, and gifts, as well as from reporting requirements on foreign assets. The regime is valid for up to fifteen years.

What BRIDGES had to solve

The critical nuance is that the fixed payment amount changed over time: the historical rate of €100,000 per year was subsequently increased for new applicants. The regime operates on the principle that conditions are locked in at the point of entry: those who correctly opt into the regime at the prevailing rate retain that rate for their entire period.

Why a standard answer would not do

The client came to BRIDGES to capitalize on the favorable window: to complete the relocation and opt into the regime correctly and on time, securing the €100,000 annual rate while it remained available within his timeline.

Irena arranged the 100 thousand euro annual flat tax for me in time for my move to Italy. The rate is fixed for the whole period.

Gleb · High-net-worth residentThe name and certain identifying details have been changed to protect confidentiality.

Key considerations

Key considerations

There was no risk of capital loss here—only the cost of delay. The special regime locks in conditions at the point of entry, and the rate for new applicants increased over time. Delay or an error in documentation would have meant entry under less favorable, different terms. Therefore, the critical factor was precise and timely activation of the regime, not "sometime later."

That regime conditions are locked in at the point of correct entry;

  1. 01That the rate for new applicants increased over time;
  2. 02Proper documentation of new tax resident status;
  3. 03Timely and error-free exercise of the non-resident regime option;
  4. 04Coverage of foreign-source income and exemptions provided by the regime.

The logic of the solution

How the matter progressed: from checks to result

The chart is built from the facts of this matter and shows the logic of the work without decorative or unverified data.

  1. 01
    Stage 1

    We assessed the client's tax situation. First, we analyzed the structure of his income and confirmed that the main portion was generated abroad. This immediately showed that the standard rate schedule would make relocation expensive, while the non-resident regime would be beneficial, which set our objective.

  2. 02
    Stage 2

    We explained the importance of entry timing. We emphasized to the client the critical point: regime terms and conditions are fixed at the time of proper option election, and the rate for new applicants increases over time. Thus, the value lies not only in the regime itself but also in entering it at the right time.

  3. 03
    Stage 3

    We established new tax resident status. The regime is available to new residents, so we properly transferred tax residency to Italy - the foundation for the option election. An error at this stage would have nullified all benefits.

  4. 04
    Stage 4

    We timely elected the non-resident regime option. We completed the regime option without delay or errors, under the terms applicable at the time of entry. This locked in a fixed tax of EUR 100,000 per year on foreign income for the client.

  5. 05
    Stage 5

    We secured the regime exemptions. Beyond the rate, we accounted for associated benefits: exemption from tax on foreign wealth, inheritance, and gifts, and exemption from reporting requirements on foreign assets. The regime benefits were fully realized.

Takeaway. Conclusion: In the non-resident regime, both rate and timing matter - terms and conditions are fixed at entry, and rates for new applicants increased over time. Timely and correct entry locks in benefits for years.

How we handled the matter

How we handled the matter

The work was split into verifiable stages so that every conclusion rested on documents.

  1. 01

    We assessed the client's tax situation

    First, we analyzed the structure of his income and confirmed that the main portion was generated abroad. This immediately showed that the standard rate schedule would make relocation expensive, while the non-resident regime would be beneficial, which set our objective.

  2. 02

    We explained the importance of entry timing

    We emphasized to the client the critical point: regime terms and conditions are fixed at the time of proper option election, and the rate for new applicants increases over time. Thus, the value lies not only in the regime itself but also in entering it at the right time.

  3. 03

    We established new tax resident status

    The regime is available to new residents, so we properly transferred tax residency to Italy - the foundation for the option election. An error at this stage would have nullified all benefits.

  4. 04

    We timely elected the non-resident regime option

    We completed the regime option without delay or errors, under the terms applicable at the time of entry. This locked in a fixed tax of EUR 100,000 per year on foreign income for the client.

  5. 05

    We secured the regime exemptions

    Beyond the rate, we accounted for associated benefits: exemption from tax on foreign wealth, inheritance, and gifts, and exemption from reporting requirements on foreign assets. The regime benefits were fully realized.

  6. 06

    We locked in the terms for the regime period

    As a result, the client entered the regime on favorable, fixed terms - with a rate of EUR 100,000 per year for the duration of the regime. Timely entry translated into long-term tax savings.

How the work went

From first contact to the result

  1. 01We assessed the client's tax situation
  2. 02We explained the importance of entry timing
  3. 03We established new tax resident status
  4. 04We timely elected the non-resident regime option
  5. 05We secured the regime exemptions
  6. 06We locked in the terms for the regime period

The sequence and timing reflect this specific case and depend on how complete the documents are and on the decisions of the competent authorities.

Expert comment

Tax regimes are always about two things: rate and timing. Clients typically focus only on the first - how much to pay - and miss the second, yet it often determines the outcome equally. Italy's non-resident regime is structured so that terms and conditions are fixed at the time of entry, and the rate for new applicants increases over time. Therefore, those who establish the regime timely and correctly lock in favorable conditions for the entire period - up to fifteen years. My client's nearly all income was foreign-sourced, and under the standard rate schedule, relocation would have been prohibitively expensive. We transferred his residency and timely elected the regime option, locking in a rate of EUR 100,000 per year. I always tell high-net-worth clients: in such regimes, delay is costly. Entry must happen when conditions are favorable, not "when you get around to it."

Dmitry Nagy, International Tax Consultant, BRIDGESDmitry NagyInternational Tax Consultant, BRIDGES

Outcome

What the client received

What was required
How we accomplished it · Result
Reduce relocation costs
Non-resident regime instead of standard rate schedule · Fixed tax instead of progressive taxation
Lock in terms
Timely regime option election · Rate fixed at time of entry
Resident status
Proper residency transfer · Foundation for the regime
Realize benefits
Accounting for regime exemptions · Full benefit realization
Realize benefits
Accounting for regime exemptions · Full benefit realization

Situation: A high-net-worth client with substantial foreign income was relocating to Italy and wanted to access a preferential tax regime where favorable terms depend on entry timing. Actions taken: We assessed the tax picture; explained the importance of entry timing; established new resident status; timely elected the non-resident regime option; secured the exemptions; locked in the terms for the regime period. Client outcome: Fixed tax of EUR 100,000 per year on foreign income for the duration of the regime.

Practical takeaway

What matters in a similar situation

  • Conclusion: In the non-resident regime, both rate and timing matter - terms and conditions are fixed at entry, and rates for new applicants increased over time. Timely and correct entry locks in benefits for years.
  • The client locked in a favorable rate for years ahead - because we managed the relocation and elected the regime option timely, while these conditions were available to him.
  • The flat tax regime can be secured at the current rate if you apply in time. We will look at your case.

FAQ

Questions people ask in a similar situation

01What is Italy's non-resident regime?

A special tax regime for new residents: instead of standard taxation, a fixed annual amount is paid on all foreign income, with exemption from tax on foreign wealth, inheritance, and gifts. The regime applies for up to 15 years.

02Why is entry timing important for the regime?

Because terms and conditions are fixed at the time of proper option election, and the rate for new applicants increased over time. Those who entered timely locked in a favorable rate for the entire period.

03Does the fixed tax depend on income amount?

No, that is the essence of this regime: the payment is fixed regardless of foreign income size. For substantial income, it is significantly more advantageous than the standard progressive tax scale.

04Who is eligible for the non-resident regime?

New Italian tax residents who have correctly transferred their tax residency and met the regime requirements. Exact conditions and current rates should be confirmed with the tax authority.

05Is the regime linked to investment residence permit?

This is a separate tax regime, but it naturally aligns with relocation under investment residence permit: the status grants the right to reside in Italy, while the regime optimizes taxation on foreign-source income.

06Which documents were key in this case?

We assessed the client's tax situation. First, we analyzed the structure of his income and confirmed that the main portion was generated abroad. This immediately showed that the standard rate schedule would make relocation expensive, while the non-resident regime would be beneficial, which set our objective. We explained the importance of entry timing. We emphasized to the client the critical point: regime terms and conditions are fixed at the time of proper option election, and the rate for new applicants increases over time. Thus, the value lies not only in the regime itself but also in entering it at the right time.

07Why did the standard route not suit the client?

Italy offers a special non-resident regime (regime forfettario per neo-residenti) for such cases: instead of standard taxation, a new resident pays a fixed annual amount on all foreign-source income, regardless of amount, and is exempt from tax on foreign assets, inheritance, and gifts, as well as from reporting requirements on foreign assets. The regime is valid for up to fifteen years.

08What risk had to be closed before filing?

There was no risk of capital loss here—only the cost of delay. The special regime locks in conditions at the point of entry, and the rate for new applicants increased over time. Delay or an error in documentation would have meant entry under less favorable, different terms. Therefore, the critical factor was precise and timely activation of the regime, not "sometime later." That regime conditions are locked in at the point of correct entry;

09How did BRIDGES check that the chosen solution would hold?

We secured the regime exemptions. Beyond the rate, we accounted for associated benefits: exemption from tax on foreign wealth, inheritance, and gifts, and exemption from reporting requirements on foreign assets. The regime benefits were fully realized. We locked in the terms for the regime period. As a result, the client entered the regime on favorable, fixed terms - with a rate of EUR 100,000 per year for the duration of the regime. Timely entry translated into long-term tax savings.

10What confirmed the result in the end?

Situation: A high-net-worth client with substantial foreign income was relocating to Italy and wanted to access a preferential tax regime where favorable terms depend on entry timing. Actions taken: We assessed the tax picture; explained the importance of entry timing; established new resident status; timely elected the non-resident regime option; secured the exemptions; locked in the terms for the regime period. Client outcome: Fixed tax of EUR 100,000 per year on foreign income for the duration of the regime. What was required: How we accomplished it · Result. Reduce relocation costs: Non-resident regime instead of standard rate schedule · Fixed tax instead of progressive taxation. Lock in terms: Timely regime option election · Rate fixed at time of entry. Resident status: Proper residency transfer · Foundation for the regime. Realize benefits: Accounting for regime exemptions · Full benefit realization. Realize benefits: Accounting for regime exemptions · Full benefit realization

About the author

Dmitry Nagy

Author: Dmitry Nagy

International Tax Consultant, BRIDGES

I lead the international tax practice at BRIDGES and work at the intersection of tax residence, cross-border reporting and banking compliance. I assess how citizenship, residence, relocation or a new ownership structure may affect the client's tax obligations, banking profile and capital.

My work covers tax residence, CRS and FATCA requirements, source of funds and the questions a bank may raise. These elements should be considered together, because inconsistencies between documents, declarations and the underlying circumstances can create risks after a status has been obtained or an account has been opened.

During the consultation, you will receive an assessment of the tax and banking implications of the proposed decision. Where further work is required, I determine the financial documentation and personally oversee the tax and compliance aspects of the BRIDGES project.

Prepared on the basis of BRIDGES practice and reviewed by a subject-matter expert.

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Dmitry NagyInternational Tax Consultant, BRIDGES
Dmitry Nagy, International Tax Consultant, BRIDGES

Names and certain details have been changed to protect client confidentiality. The result described reflects one specific situation and is neither a public offer nor a guarantee of a similar outcome. Programme terms are stated as of 2026 and may change - please confirm current parameters with a BRIDGES consultant.