24 October 2023
Employment Tax
Italy | Government 2024 budget bill
Impact: High
Summary
On October 16th, 2023 the Council of Ministers approved its 2024 budget bill, along with a draft Legislative Decree. Several measures could have a huge impact on the Italian individual tax system if approved. Indeed, all proposed measures will have to go through the Parliamentary/Government technical committees debates and could be amended or cancelled.
The final Legislative Decree is expected by the end of December 2023. In the meantime, companies and international employees should consider the below Government proposals which could impact the employment and global mobility strategies.
The Detail
Special inbound tax regime
The Budget bill provides an important reorganization of the Italian special tax regime applicable on salaries of inbound employees. The proposed changes would have impact on following areas:
● The percentage of tax exempted employment income to be reduced from 70% or 90% to 50%, introducing a threshold of 600.000€. Employment income above this limit should be taxed according to the standard tax rules.
● Proposed amendments to the current qualifying conditions as follows:
o The individual must be non-tax resident in Italy in the three tax years preceding the transfer to Italy (the current law requires two years non-tax residency).
o The individual must become a tax resident in Italy and commit to maintain this condition for a minimum of five years (the current law requires a minimum of two years of tax residence). The failure to respect this condition shall result in paying back the benefit obtained from the tax relief with additional interests.
o Carry out work activities mainly in Italy.
● The following two conditions have been added:
o The employee shall relocate to Italy to start a new employment relationship
and the new employer should not be a part of the same group of companies as the previous employer. These restrictions, if approved, will prevent this benefit to all employees on international secondment to Italy or to international hires within the same Group.
o The applicant shall meet the requirements to be regarded as a highly qualified or specialized professional.
● It will no longer be possible to extend the special tax regime for a further 5 years.
Based on some comments provided by government representatives during specialized press interviews, the above-mentioned changes should not apply to the taxpayers who will be registered with the Italian record of resident population (i.e. anagrafe) by December 31st, 2023. This potential clause, even if not guaranteed, will see a rush in the following few months of this year to secure the registration with Anagrafe offices for those individuals whose intention was to begin the employment in early 2024, in an effort to avoid being impacted by the new and more restrictive conditions.
Amendment of Personal income Tax rates
Current Personal tax rates are set as follows:
● 23% for incomes of up to 15.000 €
● 25% for earnings between 15.000 and 28.000 €
● 35% for earnings between 28.000 and 35.000 €
● 43% for earnings above 50.000 €.
The bill proposal cuts the number of income-tax bands from four to three by merging the two lower ones. As a result, from next year taxpayers’ incomes of up to 28.000 € shall be taxed at 23%.
Taxation of Fringe benefits
For benefits offered to employees, tax exemption shall apply up to the threshold of 1.000 € per year. The tax-exempt threshold shall increase to 2.000€ if granted to employees with dependent children.
The Government press release is available here for reference.
How we can help
Given the important impact that this tax reform will have on employment incomes, on the special inbound tax regime and on company global mobility and talent acquisition strategies, we would be more than glad to offer our assistance with specific case-by-case evaluations and guidance to secure the benefits offered by the current and the future laws.
Contact us
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Nicla Cimmino
Partner
nicla.cimmino@vialto.com
Suzana Branilovic
Partner
suzana.branilovic@vialto.com
Valentina Siciliani
Director
valentina.siciliani@vialto.com
Ciro Eligiato
Senior Manager
ciro.eligiato@vialto.com
Edoardo Plescia
Senior Associate
edoardo.plescia@vialto.com