Residents pay on everything, non-residents on Italian income
Italian income tax applies to the worldwide income of residents, and to non-residents only for income produced in Italy (art. 3 of the income tax code, the TUIR). Citizenship does not decide anything: an Italian who genuinely lives abroad is taxed in Italy only on Italian income — rent from a flat in Italy, for example — while an Italian who remains resident is taxed on every euro earned from the laptop in Lisbon or Bangkok.
The residence test since 1 January 2024
Legislative decree 209/2023 rewrote the test in art. 2 of the TUIR with effect from 1 January 2024. You are resident in Italy for tax purposes if, for most of the tax year (counting fractions of a day), any one of these applies:
Your habitual abode, in the civil-law sense, is in Italy.
The place where your personal and family relationships mainly develop is Italy.
You are physically present in Italy for most of the year.
Being registered with an Italian municipality's resident registry for most of the year makes you presumed resident, unless you prove otherwise.
Two consequences matter for nomads. First, deregistering is not enough: if your partner and children stay in Italy, your domicile — and with it your tax residence — can stay there too. Second, the registry rule is now a presumption that can be rebutted with facts, so someone who genuinely lives abroad but forgot to deregister can in principle prove it. The test applies to the tax year as a whole: meet it for most of the year and you are resident for the entire year.
Black-list presumption — Italian citizens who deregister and move to a country with a privileged tax regime are presumed to remain resident unless they prove otherwise (art. 2, paragraph 2-bis). The law's newer "white list" wording applies only once the Ministry of Economy publishes the list it foresees; the IVAFE rules still refer to the black list in the ministerial decree of 4 May 1999.
Italian income that stays taxable after you leave
As a non-resident you pay Italian tax only on income produced in Italy. Art. 23 of the TUIR lists what counts, and several items matter to remote workers:
- Property income from land and buildings in Italy, for example rent from your flat.
- Capital income paid by the Italian State or by Italian residents — except interest on bank and postal deposits and current accounts, which is excluded.
- Employment income for work performed in Italy and self-employment income from activities carried out in Italy. Work you actually do abroad does not fall under these two headings.
- Whatever the place of work, pensions paid by Italian payers, certain income treated like employment income — including coordinated and continuous collaborations — and royalties paid by Italian residents are treated as Italian income.
That last point surprises many freelancers: a collaboration contract with an Italian company can remain Italian-source income even if you perform it from abroad. The double tax treaty between Italy and your new country can change the final allocation, so read it before you plan around the domestic rule.
What changes on 1 January 2027
A new consolidated income tax code, legislative decree 117 of 19 June 2026, has been in force since 4 July 2026 but applies from 1 January 2027 (its art. 377). The residence rules are carried over word for word into its art. 2; the black-list presumption moves from paragraph 2-bis to paragraph 3. For the 2026 tax year, keep citing the TUIR of 1986; from 2027, the new code.
AIRE: the registry of Italians abroad
- Duty: Italians who move their residence from an Italian municipality abroad must declare it to the consular office for their new area within 90 days of arrival (art. 6, Law 470/1988). The same 90-day limit applies when you move again abroad.
- Penalty: failing to declare the move is punished with an administrative fine of €200 to €1,000 for each year the omission lasts, reduced to a tenth of the minimum if you declare within 90 days of the deadline and before any check has started (art. 11, Law 1228/1954). The municipality imposes it.
- Effect: AIRE registration is how Italy records that you live abroad — for consular services, passports and voting — but for tax purposes it is only one element: the domicile and presence tests above still apply.
If you remain an Italian tax resident while abroad
Staying resident is sometimes the right choice — for example on a short programme such as Japan's six-month status — but it comes with obligations on foreign assets:
| Tax | On what | Rate in 2026 |
|---|---|---|
| IVAFE | Financial products held abroad | 0.2% of value; 0.4% if held in a black-listed country (from 2024) |
| IVAFE | Current and savings accounts abroad | Fixed amount equal to the stamp duty on bank statements (€34.20 for individuals) |
| IVIE | Real estate abroad | 1.06% of value; not due if the amount is €200 or less |
A foreign wealth tax paid on the same assets can be credited against IVAFE. Both taxes currently live in art. 19 of decree-law 201/2011; from 1 January 2027 those paragraphs are repealed and the taxes move into the new consolidated codes, so check the new references for the 2027 tax year. Residents also report foreign assets in the monitoring section of their tax return.
How this meets the nomad visas
When a host country makes you tax resident — Spain, Portugal and Greece all tax residents on worldwide income, with their own regimes for newcomers — and Italy still considers you resident because your family life stayed in Italy, the double tax treaty between the two countries decides where you are resident and how double taxation is relieved. The cleaner your move — AIRE within 90 days, family relocated, a settled base abroad — the less room there is for dispute.
Checklist
Register with AIRE
Declare your move at the consulate within 90 days; late declarations cost €200–1,000 a year.
Move your life, not just your address
Domicile follows your personal and family relationships; presence counts days, including parts of days.
Avoid black-list surprises
Moving to a privileged-tax country reverses the burden of proof: keep evidence of your real life there.
If you stay resident, declare foreign assets
IVAFE on accounts and investments, IVIE on property, and the monitoring section of the return.
Watch the 2027 switch
From 1 January 2027 the rules sit in the new income tax code (d.lgs. 117/2026) with new article numbers.
Related guides: U.S. taxes, United Kingdom, Canada, Australia, Italy's own nomad visa (for foreigners moving to Italy).