SERVICES
Incentives
New impatriate regime: access also granted to cross-border workers returning to Italy
Italian Revenue Agency
A worker resident abroad, employed by an Italian company and registered with AIRE since 2018, asked the Italian Revenue Agency whether, upon returning to Italy in 2026, he could benefit from the new tax incentive regime for impatriate workers introduced by Legislative Decree No. 209/2023. Although he had maintained residence abroad, the individual had continued to travel daily to Italy to perform his work as a cross-border worker (frontaliero).
The Agency clarified that the legislation does not impose any limitation based on where the work activity was carried out during the period of foreign residence. Accordingly, individuals who worked in Italy as cross-border workers may also access the benefit, provided that all other statutory requirements are met, including possession of high qualifications or specialisation and foreign tax residence for at least seven tax periods where the employment relationship continues with the same employer.
It was, however, specified that verification of the “high qualification or specialisation” requirement cannot be the subject of a tax ruling request, as it constitutes a technical assessment reserved to other authorities. Access to the regime therefore remains conditional upon the actual fulfilment of all substantive requirements set out in the incentive legislation.