30.05.2017

Rule n. 17/E, published by the Italian Tax Authorities, has as recipients “transferred ”.  “Transferred " means workers, employees, managers, highly skilled workers and graduates who transfer their tax residence from abroad to work in Italy.

For the abovementioned individual, art. 16 D.lgs n.147/2015 provided a special regime, for the self-employed or dependent worker could request taxable income, produced in Italy, on a taxable basis of 70% for year 2016, subsequently, on the basis of the changes introduced by Budget Act 2017, the tax break has been reinforce, changing from 70% to 50% for the years 2017-2020.

Regulations specified that the special regime can be used also for managers transferred to Italy from another group company without being registered in civil registry of resident population and without transferring to Italy the habitual residence or the center of their interests.

It is possible that the individual can be used the aforementioned facilities if he moves his residence in Italy before starting the activity, as long as the two events can be connected. In this case the benefits would apply from the tax period in which the person acquires the tax residence in Italy.

Facilitations do not apply people who come to Italy after their transfer abroad and have obtained foreign residence. In this case their return to Italy would be in implementation with the terms of the existing employment contract, and would be in substantial continuity with the previous position of workers resident in Italy.

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