The lavoratori impatriati regime is Italy’s income tax break for skilled workers who move their tax residence here. It was rewritten from 2024 and is now narrower than the version many online guides still describe: smaller exemption, stricter conditions, no extension for buying a home.
This guide covers the rules in force for people who became resident from 2024 onward, what happened to those on the old regime, and the two traps that catch freelancers. It was checked against the law and the Agenzia delle Entrate’s pages in October 2026. It is general information, not tax advice: the regime is unforgiving of mistakes, so confirm your case with a commercialista before you move.
The regime in force since 2024
Article 5 of Legislative Decree 209/2023 applies to people who transfer their tax residence to Italy from the 2024 tax year. The Agenzia’s guide to the regime sets out the conditions:
What you save
Half of the qualifying income (50%) is exempt from income tax for the year of the move and the four following years, up to €600,000 of income a year; the exemption rises to 60% (only 40% is taxed) if you move with a minor child, or if a child is born or adopted while you are on the regime, as long as the child is resident in Italy (Legislative Decree 209/2023, art. 5; Agenzia delle Entrate). Leave Italy before four years and the benefit is clawed back with interest.
Qualifying income means employment income and income from arts and professions produced in Italy (Agenzia delle Entrate, professionals). Business income from a sole-trader activity does not qualify, and the exemption applies to income tax only: INPS is still due on the full amount.
What it is worth for an employee: €100,000 in Lecce
We ran a €100,000 salary ($111,930 at the ECB rate of 23 October 2026) through four cases: an Italian or any non-American in Lecce, an American in the US, an American living in Lecce on ordinary Italian rules, and an American in Lecce under the impatriati regime. US citizens are taxed by the US wherever they live, so an Italian tax break is only worth what the IRS does not take back.
Cite this: Puglia Everyday research, “Who keeps what of €100,000: employees”, October 2026, https://www.pugliaeveryday.com/business/us-taxes-living-in-puglia/ · Download the data (CSV)
Finding: on a €100,000 salary, an American keeps €78,239 in the US and €55,809 in Lecce, the same as an Italian or any non-American colleague, whoever the employer is. The impatriati regime lifts that to €76,261, close to the US figure; at this salary €538 goes back to the IRS because the Italian tax falls below the US tax.
| Employee, €100,000 | Italian or any non-American, in Lecce | American in the US | American in Lecce, Italian or American employer | American in Lecce, impatriati |
|---|---|---|---|---|
| IRPEF | €31,060 | – | €31,060 | €12,111 |
| Puglia regional surcharge | €2,531 | – | €2,531 | €1,032 |
| Lecce municipal surcharge | €972 | – | €972 | €430 |
| INPS (employee, 9.19%) | €9,628 | – | €9,628 | €9,628 |
| US federal income tax | – | €14,111 | €0 after credit | €538 after credit |
| Social Security / Medicare | – | €6,200 / €1,450 | not due | not due |
| Left over | €55,809 | €78,239 | €55,809 | €76,261 |
Old regime and new regime compared
| Feature | Old regime (moved by 2023) | New regime (from 2024) |
|---|---|---|
| Time abroad before the move | 2 tax years | 3 tax years (6 or 7 for the same employer or group) |
| Minimum stay in Italy | 2 years | 4 years |
| Qualifying income | Employment, self-employment and sole-trader business income | Employment and professional self-employment income |
| Exempt share | 70% (90% in the South, including Puglia) | 50% (60% with a minor child) |
| Annual income cap | None | €600,000 |
| Duration | 5 years, extendable by 5 with a child or a home purchase | 5 years, no extension |
| Qualifications | None required | High qualification or specialization |
People who became resident by the end of 2023 under Article 16 of Legislative Decree 147/2015 keep the old rules for their full term, including any extension they had already secured. The extension for buying a home in Italy belongs to the old regime only.
The forfettario trap
Freelancers often look at the forfettario flat-rate regime first. The two do not combine. Income taxed under the forfettario regime does not form part of your total taxable income, so the impatriati exemption has nothing to apply to. In ruling 190 of 2023, the Agenzia confirmed that someone who opts for the forfettario regime on arrival cannot switch to the impatriati regime later: the first choice counts as a decision not to use it. The same reasoning is applied under the new rules.
Run the numbers both ways before you open your partita IVA (VAT number). The flat-rate regime is simple and cheap for modest incomes; the impatriati regime can be worth more for higher earners.
What it is worth for a consultant with a partita IVA
The regime covers self-employed professionals too, but not on the forfettario (limit €85,000). On the ordinary regime an Italian or any non-American consultant pays INPS gestione separata at 26.07%.
Cite this: Puglia Everyday research, “Who keeps what of €100,000: consultants”, October 2026, https://www.pugliaeveryday.com/business/us-taxes-living-in-puglia/ · Download the data (CSV)
Finding: on €100,000 of revenue, an American consultant keeps €76,770 in the US and €53,448 in Lecce, more than an Italian or any non-American consultant (€47,181), because US self-employment tax costs less than INPS gestione separata and is deductible in Italy. The impatriati regime, which covers self-employed professionals, lifts take-home to €73,314; at that point €2,471 of US income tax remains after the credit.
The first pie applies to anyone who is not American, whether Italian, British or any other nationality. Most countries tax by residence, the UK included: once you have moved here and are no longer UK resident under the Statutory Residence Test (HMRC RDR3), HMRC does not tax your foreign income, so you pay only Italian tax on what you earn here. Under the UK–EU social security coordination rules, you also pay INPS like any Italian resident, unless you were posted here temporarily by a home employer with a certificate of coverage. Income still coming from home can still be taxed there: UK rent, for example, and UK government service pensions, which the UK–Italy tax treaty (article 19) leaves to the UK unless you are an Italian national living in Italy. The US is the exception, because it taxes its citizens wherever they live, which is why Americans get their own pies.
| Consultant, €100,000 revenue | Italian or any non-American, in Lecce | American in the US | American in Lecce, Italian or American clients | American in Lecce, impatriati |
|---|---|---|---|---|
| IRPEF | €23,990 | – | €29,124 | €9,037 |
| Puglia regional surcharge | €1,984 | – | €2,381 | €731 |
| Lecce municipal surcharge | €775 | – | €918 | €318 |
| INPS gestione separata (26.07%) | €26,070 | – | – | – |
| US federal income tax | – | €9,101 | €0 after credit | €2,471 after credit |
| US self-employment tax: Social Security / Medicare | – | €11,451 / €2,678 | €11,451 / €2,678 | €11,451 / €2,678 |
| Left over | €47,181 | €76,770 | €53,448 | €73,314 |
Why the American consultant pays US Social Security and not INPS: US self-employment tax applies to US citizens wherever they live, and neither the foreign earned income exclusion nor the foreign tax credit reduces it (IRS Publication 54). Without an agreement, an American consultant in Italy would pay both it and INPS. The US-Italy totalization agreement assigns self-employed US nationals who would otherwise be covered by both countries to the US system only (SSA, Totalization Agreement with Italy), so they pay US self-employment tax instead of INPS. It counts toward US Social Security benefits and costs less: 15.3% on 92.35% of net earnings (IRS), against 26.07% for gestione separata. You ask the SSA for a certificate of coverage to show INPS. Dual US-Italian nationals can generally choose. We deducted the US self-employment tax from Italian taxable income. Article 10(1)(e) of the TUIR allows the deduction of social security contributions paid under a legal obligation, and the Agenzia delle Entrate has confirmed that this covers mandatory contributions paid abroad under foreign law (ruling no. 5 of 2026, on an employee). We found no ruling specific to US self-employment tax, so keep the SSA certificate of coverage and the payment records. The impatriati regime applies to income from arts and professions as well as salaries, with the same conditions (Legislative Decree 209/2023, art. 5; Agenzia delle Entrate).
Social security contributions: how INPS works and how we calculated it
INPS (Istituto Nazionale della Previdenza Sociale) is Italy’s social security agency: it pays pensions and sickness and maternity benefits, roughly the Italian counterpart of US Social Security and Medicare. The impatriati exemption does not touch it: contributions are charged on full pay or full profit.
Employees pay 9.19% of gross pay, plus 1% on pay above €56,224, up to a ceiling of €122,295 for people first insured after 1995. The employer pays a larger share on top, which is not shown in our charts. Freelancers with a partita IVA and no professional pension fund pay the gestione separata at 26.07% of net profit, up to €122,295 in 2026.
INPS is deducted from income before IRPEF is calculated (TUIR art. 10(1)(e), applied to foreign mandatory contributions in ruling no. 5 of 2026). Under the old regime, INPS circular 52 of 2023 confirmed that artisans and traders paid contributions on the reduced income; for employees and the new regime, contributions are calculated on full income.
Worked example, employee on €100,000 under the impatriati regime (Puglia Everyday analysis):
| Gross salary | €100,000 |
| INPS, employee share (9.19% to €56,224, 10.19% above) | − €9,628 |
| Income after INPS | €90,372 |
| Impatriati: 50% exempt (art. 5) | − €45,186 |
| Taxable income | €45,186 |
| IRPEF: 23% to €28,000, 33% to €50,000 (2026 brackets) | €12,111 |
| Puglia regional surcharge (1.33% to 3.33%) | €1,032 |
| Lecce municipal surcharge (0.8% to €28,000, 1.2% above) | €430 |
| US tax left after the foreign tax credit (Form 1116) | €538 |
| Left over | €76,261 |
American freelancers: under the US-Italy totalization agreement, self-employed US citizens are covered by US Social Security only, so they pay US self-employment tax instead of gestione separata, not on top of it (SSA, Totalization Agreement with Italy). Employees hired locally pay INPS, not FICA; workers sent by a US employer for a limited period usually stay on FICA (IRS). For the full US picture see our guide to US taxes for Americans living in Puglia.
Americans with a partita IVA: INPS or US Social Security?
On €85,000 of revenue, INPS gestione separata would take €22,160 at ordinary income (26.07% of €85,000), or €17,284 under the forfettario (26.07% of the €66,300 coefficient income). Under article 7(4)(a) of the US-Italy social security agreement, a US national whose work would be covered by both systems stays on US coverage only, so we pay the US self-employment tax instead: €12,010 (Social Security €9,734 + Medicare €2,276). Puglia Everyday analysis.
1. Request a certificate of coverage from the SSA (online Certificate of Coverage service, or by mail, fax or certificate@ssa.gov). 2. Give a copy to INPS. 3. Keep paying US self-employment tax on Schedule SE; the SSA says self-employed people attach a copy of the certificate to their US tax return every year.
The exemption takes effect only once it is certified (agreement art. 7(5) and Administrative Protocol art. 3). Without the certificate, INPS can bill you for gestione separata contributions.
The regime applies to employees too, including people on a fixed-term contract.
Investors who will not work as employees can compare it with the Italy golden visa.
Before you move
- Make sure you will actually be tax resident. Our guide to domicile and residence explains the tests.
- Keep evidence of your years abroad: foreign tax returns, residence certificates, employment contracts.
- Tell your employer in writing that you are applying the regime, or claim it in your tax return if your employer does not apply it through payroll.
- Plan for the four-year commitment before you sign a lease or a contract.
Most of the paperwork can be followed online: see our guide to filing through Fisconline.
Related: the 7% flat tax for retirees in Puglia’s smaller towns and forfettario and partita IVA questions.
Sources for this research
- Agenzia delle Entrate, “Aliquote e calcolo dell’Irpef” (2026 brackets, law no. 199/2025). https://www.agenziaentrate.gov.it/portale/imposta-sul-reddito-delle-persone-fisiche-irpef-/aliq…
- Regione Puglia, “Addizionale regionale Irpef: aliquote” (Decree no. 3 of 28 May 2026). https://www.regione.puglia.it/web/tributi/addizionale-regionale-irpef/aliquote
- Ministry of Economy and Finance (MEF), Dipartimento Finanze, regional Irpef surcharge, Puglia (published 29 May 2026). https://www1.finanze.gov.it/finanze2/dipartimentopolitichefiscali/fiscalitalocale/addregirpef/a…
- MEF, Dipartimento Finanze, municipal Irpef surcharge, Lecce (no 2026 resolution; 2025 rates, resolution no. 184/2022). https://www1.finanze.gov.it/finanze2/dipartimentopolitichefiscali/fiscalitalocale/nuova_addcomi…
- INPS, circular no. 6 of 30 January 2026 (employee contributions, €56,224 band, €122,295 ceiling). https://www.inps.it/content/dam/inps-site/it/scorporati/circolari-e-messaggi/2026/01/Circolare_…
- INPS, circular no. 8 of 3 February 2026 (gestione separata rates 2026: 26.07%). https://www.inps.it/content/dam/inps-site/it/scorporati/circolari-e-messaggi/2026/02/Circolare_…
- Gazzetta Ufficiale, Legislative Decree no. 209 of 27 December 2023, art. 5 (impatriati). https://www.gazzettaufficiale.it/atto/serie_generale/caricaArticolo?art.codiceRedazionale=23G00…
- Agenzia delle Entrate, “Lavoratori impatriati – Professionisti: che cos’è”. https://www.agenziaentrate.gov.it/portale/lavoratori-impatriati-209-2023/infogen-lavoratori-imp…
- Agenzia delle Entrate, ruling (risposta) no. 5 of 2026 on deducting mandatory contributions paid abroad, TUIR art. 10(1)(e). https://www.agenziaentrate.gov.it/portale/documents/20143/9570465/Risposta+n.+5_2026/8ee6437a-f…
- IRS, Revenue Procedure 2025-32 (2026 brackets and standard deduction). https://www.irs.gov/pub/irs-drop/rp-25-32.pdf
- IRS, Topic no. 751, Social Security and Medicare withholding rates. https://www.irs.gov/taxtopics/tc751
- IRS, “Self-employment tax (Social Security and Medicare taxes)”. https://www.irs.gov/businesses/small-businesses-self-employed/self-employment-tax-social-securi…
- IRS, “Qualified business income deduction”. https://www.irs.gov/newsroom/qualified-business-income-deduction
- IRS, “About Form 1116, Foreign Tax Credit”. https://www.irs.gov/forms-pubs/about-form-1116
- IRS, “Foreign earned income exclusion”. https://www.irs.gov/individuals/international-taxpayers/foreign-earned-income-exclusion
- IRS, “About Form 673, Statement for Claiming Exemption from Withholding on Foreign Earned Income”. https://www.irs.gov/forms-pubs/about-form-673
- IRS, “About Form W-4, Employee’s Withholding Certificate”. https://www.irs.gov/forms-pubs/about-form-w-4
- IRS, Publication 54, Tax Guide for U.S. Citizens and Resident Aliens Abroad. https://www.irs.gov/publications/p54
- SSA, “Contribution and benefit base” (2026: $184,500). https://www.ssa.gov/oact/cola/cbb.html
- SSA, “Totalization Agreement with Italy”. https://www.ssa.gov/international/Agreement_Pamphlets/italy.html
- US Treasury, US-Italy income tax convention (1999). https://home.treasury.gov/system/files/131/Treaty-Italy-8-24-1999.pdf
- European Central Bank, euro reference rates, US dollar (23 October 2026: 1.1193). https://www.ecb.europa.eu/stats/policy_and_exchange_rates/euro_reference_exchange_rates/html/eu…
- Agenzia delle Entrate, “Regime forfetario – Professionisti: che cos’è” (€85,000 limit; updated 21 July 2026). https://www.agenziaentrate.gov.it/portale/regime-forfetario-le-regole-2020-/infogen-regime-forf…
- IRS, “Totalization agreements”. https://www.irs.gov/individuals/international-taxpayers/totalization-agreements
- Agenzia delle Entrate, “Lavoratori impatriati – nuovo regime (dal periodo d’imposta 2024): che cos’è”. https://www.agenziaentrate.gov.it/portale/lavoratori-impatriati-209-2023/infogen-lavoratori-imp…
- Agenzia delle Entrate, ruling (risposta) no. 190 of 2023 (forfettario and impatriati). https://www.agenziaentrate.gov.it/portale/documents/20143/4988698/Risposta+n.+190_2023.pdf/eb10…
- INPS, circular no. 52 of 7 June 2023 (contributions under the old impatriati regime). https://www.inps.it/it/it/inps-comunica/atti/circolari-messaggi-e-normativa/dettaglio.circolari…
- INPS, circular no. 6 of 30 January 2026 (web page). https://www.inps.it/it/it/inps-comunica/atti/circolari-messaggi-e-normativa/dettaglio.circolari…
- Social Security Administration, “U.S.-Italian Social Security Agreement” (agreement text; article 7 and Administrative Protocol article 3). https://www.ssa.gov/international/Agreement_Texts/italy.html
- Social Security Administration, “Certificate of Coverage” (online request service; mail, fax or certificate@ssa.gov). https://www.ssa.gov/international/CoC_link.html
- HM Revenue & Customs, “RDR3: Statutory Residence Test (SRT)” (last updated 11 June 2026). https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt
- GOV.UK, “Tax on foreign income” (non-residents do not pay UK tax on foreign income). https://www.gov.uk/tax-foreign-income/non-residents
- HM Revenue & Customs, “Paying National Insurance if you’re going to work in the EU…” (UK–EU social security coordination: contributions where you work; certificate of coverage for postings up to 2 years). https://www.gov.uk/guidance/national-insurance-for-workers-from-the-uk-working-in-the-eea-or-switzerland
- GOV.UK, “1988 UK–Italy Double Taxation Convention” (articles 18 and 19). https://www.gov.uk/government/publications/italy-tax-treaties/1988-uk-italy-double-taxation-convention-in-force
Figures marked “Puglia Everyday analysis” are our own arithmetic from these sources, checked 25 October 2026.
Part of our tax guide: Taxes in Italy for foreigners, every guide we publish on Italian taxes, with a section for Americans, in one place.
