New inbound workers regime in Italy: smart working for foreign employers is compatible
Italy’s Revenue Agency, with Ruling No. 82 of 20 March 2026, clarified that an employee who moves to Italy in 2026 and continues to work remotely for a foreign employer may still qualify for the new inbound workers tax regime under Article 5 of Legislative Decree No. 209/2023, provided all legal requirements are met.
The ruling is particularly relevant because it confirms two practical points. First, remote work for a foreign employer does not automatically prevent access to the regime. Second, the more favorable taxation level, where only 40% of the qualifying income is taxable, may still apply even if the taxpayer’s minor children moved back to Italy before the taxpayer.
Under the new regime, qualifying employment income, similar employment income and self-employment income produced in Italy is generally taxed on 50% of its amount, up to an annual ceiling of €600,000. The taxable portion drops to 40% if the worker moves to Italy with a minor child, or if a child is born or adopted during the benefit period, provided the child is resident in Italy during that period.
The key legal conditions include:
- no Italian tax residence in the three tax periods before the move;
- commitment to remain tax resident in Italy for at least four years;
- work performed in Italy for the greater part of the tax period;
- possession of high qualification or specialization requirements under the relevant legislation.
A stricter rule applies if the worker continues to work for the same foreign employer or for a company of the same group: in such cases, the required prior period of foreign tax residence rises to six or seven tax periods, depending on whether the worker had previously been employed in Italy by the same employer or group.
This ruling is favorable, but it is not a blanket approval. The Italian Revenue Agency expressly notes that the tax ruling interprets the law based on the facts declared by the taxpayer; it does not verify those facts. Therefore, taxpayers must be able to prove their actual transfer of tax residence to Italy under Article 2 of the Italian Income Tax Code.
If you are planning to move to Italy while keeping a foreign employment contract, a preventive tax review is strongly advisable to assess eligibility, family timing, employer-group relationships, payroll issues and double taxation exposure.
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