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Moving to Italy in 2026: When Do You Become an Italian Tax Resident—and What Happens to Your Foreign Income?

ANYEXPAT EDITORIAL DRAFT

Moving to Italy from the UK or Europe in 2026

When Do You Become an Italian Tax Resident – and What Happens to Your Foreign Income?

A practical guide for employees, remote workers, freelancers, business owners and international families.

Author: Dott.ssa Kristina Larkina – Dottore Commercialista and Revisore Legale in Italy

Legal review: 22 August 2026

Audience: British, EU/EEA and Swiss nationals moving to or living in Italy

Categories: Moving to Italy; Finance

Focus keyphrase: Italian tax residency for expats

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Excerpt: Moving to Italy can change the tax treatment of your salary, investments, property, pension and business income. This guide explains the Italian residence tests and the cross-border issues UK and European expats should review before their first Italian tax return.

Suggested tags: Italian tax residency; moving to Italy; UK expats in Italy; EU expats; foreign income; remote work; Partita IVA; Quadro RW

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Moving to Italy from the UK or Europe in 2026

When Do You Become an Italian Tax Resident – and What Happens to Your Foreign Income?

By Dott.ssa Kristina Larkina, Dottore Commercialista and Revisore Legale in Italy

A British consultant moves to Milan in February. Her employment contract remains with a UK company, her salary is paid into a British bank account, she keeps an ISA and a rental property in Manchester, and she assumes that Italy has no reason to tax income that never entered an Italian account.

That assumption can be expensive. Once Italy regards an individual as tax resident, the starting point is no longer where the money was paid. The analysis shifts to the nature of each income item, where the underlying activity was performed, which country has taxing rights under the applicable treaty, and whether foreign-asset reporting is required.

For expats, the most important tax question is therefore not simply, ‘How many days have I spent in Italy?’ It is: ‘For this tax year, where are my life, work and personal relationships actually centred – and what evidence supports that conclusion?’

Key point: A visa, residence permit, municipal registration, codice fiscale and Partita IVA are different legal concepts. None of them should be used alone as a shortcut for determining tax residence.

 

1. Immigration residence and tax residence are not the same

An EU, EEA or Swiss citizen may rely on freedom-of-movement rules and, when staying in Italy for more than three months, will normally have to meet the relevant residence conditions and register with the local Comune. A British citizen who moved after Brexit is generally treated as a non-EU national for immigration purposes and may need an appropriate visa and residence permit, unless protected by the Withdrawal Agreement or another specific rule.

Those immigration differences matter, but they do not create two different Italian income-tax tests. British and European nationals are examined under the same Italian domestic residence rules. Citizenship can become relevant under a double-tax treaty only at a later stage, if both countries claim the individual as resident and the treaty tie-breaker reaches the nationality test.

A codice fiscale is only an identification number. A Partita IVA concerns the exercise of business or professional activity. Registration with the Anagrafe is important evidence and creates a statutory presumption, but tax residence must still be analysed under Article 2 of the Italian Income Tax Code (TUIR).

2. The Italian residence test: why 183 days are not the whole story

Under the rules effective from 2024, an individual is considered resident in Italy if, for most of the tax period, at least one of the substantive connecting factors below is present. For a normal 365-day calendar year, this generally means at least 183 days.

  1. Civil-law residence. Italy is the person’s habitual place of living – the place where day-to-day life is established with sufficient continuity.
  2. Tax domicile. For this purpose, domicile is the place where the person’s personal and family relationships are mainly developed. The assessment is factual; family life, relationships, routine and the overall pattern of life can be decisive.
  3. Physical presence. Being physically present in Italy for most of the tax period is an autonomous test. Fractions of a day count, so arrival and departure records must be handled carefully.

In addition, a person registered for most of the year in the Anagrafe della popolazione residente is presumed to be resident, although the post-2024 presumption can be rebutted with appropriate evidence.

This is why ‘I stayed fewer than 183 full days’ is not always a complete defence. Someone may fail the physical-presence test but still have maintained a habitual residence or tax domicile in Italy for most of the year. Conversely, owning a holiday home in Italy does not, by itself, establish tax residence if the statutory tests are not met.

3. Moving during the year: do not assume Italy automatically applies a split year

Italy uses the calendar year as the tax period for individuals. Under domestic law, residence is generally assessed by reference to most of that period, which can produce a resident or non-resident result for the year as a whole. A move date is therefore essential evidence, but it does not automatically mean that Italian taxation starts only on that date.

This point is particularly important for British expats because the UK tax year runs from 6 April to 5 April and UK domestic rules may grant split-year treatment when their conditions are met. UK split-year treatment does not, by itself, divide the Italian tax year.

The UK-Italy Double Taxation Convention contains the standard dual-residence tie-breaker – permanent home, centre of vital interests, habitual abode, nationality and, if necessary, mutual agreement – but it does not provide a general automatic split-year rule. Other European treaties may contain different wording, so the relevant convention must be checked rather than assumed.

4. What changes when you become Italian tax resident

Italian residents are generally taxed on worldwide income. Non-residents, by contrast, are generally taxed only on income treated as arising in Italy. Worldwide taxation does not mean that every foreign item is taxed in the same way, or that the same income should ultimately be taxed twice. It means that each item must enter the Italian analysis.

  1. Employment income, including salary paid by a foreign employer.
  2. Professional or business income from foreign clients.
  3. Foreign dividends, interest and investment gains.
  4. Rental income and gains connected with property outside Italy.
  5. Private and public pensions, whose treaty treatment can differ materially.
  6. Interests in foreign companies, partnerships or trusts.
  7. Foreign bank, brokerage and digital-asset positions, including crypto-assets.

The place of payment is not decisive. Receiving a UK salary in sterling, keeping funds in a French account or leaving investment proceeds on a foreign platform does not remove the need to determine the Italian tax and reporting treatment.

5. Remote employees: the employer’s country is not the workplace

A remote employee may continue to have a foreign contract, foreign payroll and foreign manager while physically performing the work from an Italian home. For tax-treaty purposes, employment income is normally connected to the place where the employment duties are physically exercised.

Under Article 15 of the UK-Italy Convention, remuneration for employment exercised in Italy may be taxed in Italy. The familiar 183-day exception protects taxation exclusively in the other state only when all treaty conditions are satisfied: the employee does not exceed the treaty day limit, the employer is not resident in Italy, and the remuneration is not borne by an Italian permanent establishment or fixed base.

Accordingly, ‘my employer is British’ and ‘I am paid through UK PAYE’ are not complete answers. The employee’s Italian filing position, the availability of treaty relief or a refund, and the employer’s potential Italian payroll, social-security or permanent-establishment exposure must be reviewed together.

Separate analysis required: Income tax and social security do not necessarily follow the same connecting rules. EU coordination rules, or the UK-EU Social Security Coordination Protocol, may keep a worker in a home-country system only when the applicable conditions are met and the required A1 or certificate of coverage has been obtained.

 

6. Freelancers and consultants: foreign clients do not remove the Italian activity

A freelancer who lives and works habitually from Italy may need an Italian Partita IVA even if every client is located in the UK, France, Germany or another country. The relevant question is whether the professional activity is organised and carried on habitually, not whether the annual receipts exceed a universal EUR 5,000 threshold.

The widely repeated EUR 5,000 figure is not a general exemption from opening a Partita IVA. It is associated with specific social-security rules for occasional activity and should not be used to reclassify a continuous professional business as occasional.

Client location remains important for invoicing, VAT place-of-supply rules, VIES/Intrastat obligations and treaty analysis. It does not, however, prevent a tax resident from being taxed in Italy on professional income. The choice between the ordinary regime, the regime forfettario and a company structure requires a separate eligibility and cost analysis.

7. Foreign assets: reporting can apply even when no money is transferred to Italy

Italian residents may have to report foreign investments and financial or patrimonial assets in Quadro RW, or in the corresponding section of Form 730 where available. Depending on the asset, IVAFE, IVIE or the tax applicable to crypto-assets may also arise.

  1. Foreign current and savings accounts.
  2. Brokerage accounts, shares, funds and other investments.
  3. Foreign property and related ownership rights.
  4. Certain foreign insurance, pension, trust or company interests, depending on their legal classification.
  5. Crypto-assets held through foreign platforms, wallets, digital accounts or other arrangements.

Reporting to HMRC or another European tax authority does not replace the Italian return. Likewise, a tax-advantaged wrapper in the country of origin does not automatically retain the same treatment after the holder becomes resident in Italy. A UK ISA, for example, requires an Italian classification of the underlying income and assets rather than an assumption that its UK exemption travels with the owner.

8. Double-tax treaties prevent double taxation – but not by letting you choose

A double-tax treaty does not allow an individual to select the country with the lower tax rate. It determines residence for treaty purposes, allocates or limits taxing rights for specific income categories and sets out the method of relief.

The UK-Italy Convention, for example, uses different provisions for employment, independent professional services, pensions, property income, dividends, interest and capital gains. Article 24 generally allows Italy, when Italy is the residence state, to include UK-source income in the Italian tax base and grant a credit for qualifying UK tax, within the treaty and domestic limits.

The Italian foreign-tax credit under Article 165 TUIR is not always automatic. Among other matters, the foreign tax must generally be final, the relevant foreign income must contribute to the Italian taxable base, the credit is capped, and the income and tax must be declared within the applicable procedural rules. If the foreign country withheld more tax than the treaty allows, the excess may need to be reclaimed there rather than credited in Italy.

For EU nationals, EU free-movement rules do not replace bilateral income-tax treaties. Each country pair must be checked separately, because pension articles, employment day-count wording, capital-gains provisions and methods of relief can differ.

9. Three practical examples

Example 1 – A UK employee working remotely from Italy

Sarah moves from London to Bologna in February 2026 and works from her Italian home for a UK employer. Her salary continues to be paid in the UK. Because she is physically present in Italy for most of the year and establishes her ordinary life there, Italian tax residence is likely under domestic law. The salary connected with duties performed in Italy must be analysed under Article 15 of the treaty. Continuing UK PAYE does not settle the Italian result; payroll, foreign-tax credit or refund, social-security coverage and employer risk must be coordinated.

Example 2 – An EU freelancer with clients in several countries

Thomas, a French web designer, moves to Florence in March and provides recurring services to French, Belgian and Dutch businesses. Payment into a French bank account does not make the activity French for Italian income-tax purposes. If the work is habitual and carried on from Italy, he will normally need an Italian tax and VAT setup, including an appropriate Partita IVA, invoicing analysis and social-security position. His right to reside in Italy as an EU citizen is a separate question.

Example 3 – A European company owner moving the management function

Eva owns and manages a company incorporated in the Netherlands. After moving to Italy, she continues negotiating contracts, directing staff and making strategic decisions from her Italian home. Her personal tax residence, salary and dividends are only the first layer. The facts may also raise questions about the company’s place of effective management, an Italian permanent establishment, controlled foreign company rules and transfer pricing. Incorporation abroad does not freeze the company’s tax position abroad when real management moves.

10. A pre-move tax checklist

  1. Build an exact travel calendar, including partial arrival and departure days.
  2. Record when an Italian home became available and where your family and ordinary life are based.
  3. List every income source: employment, freelance work, companies, property, investments, pensions, trusts and crypto-assets.
  4. Identify where each employment duty or professional activity is physically performed.
  5. Review the relevant double-tax treaty before relying on a 183-day rule or foreign withholding.
  6. Check whether an A1 or certificate of coverage is available for social security.
  7. Map foreign accounts and assets for Quadro RW, IVAFE, IVIE and crypto reporting.
  8. Assess any special Italian regime before the move; eligibility, covered income and procedural choices differ.
  9. Coordinate the Italian calendar year with the UK or other foreign tax year and retain evidence of final foreign taxes paid.
  10. Complete the correct Italian registrations – including Partita IVA where required – rather than waiting for the first tax return.

The practical conclusion

For most expats, the first Italian tax return is too late to start asking these questions. By then, the move has already happened, work has been performed, dividends or gains may have been realised, payroll may have continued in the wrong country and foreign accounts may already fall within Italian reporting.

The most effective approach is a pre-arrival or early-arrival review that fixes the residence timeline, classifies each income source, checks the relevant treaty, maps foreign assets and aligns tax with social security and immigration status.

Moving to Italy does not necessarily mean paying tax twice. It does mean that the structure which worked in the UK or another European country must be re-examined under Italian law before it is assumed to remain compliant.

Planning a move to Italy? A pre-move tax review can identify your likely residence year, foreign-income exposure, reporting obligations, treaty relief and the correct setup for employment, freelancing or business activity.

 

About the author

Dott.ssa Kristina Larkina is a Dottore Commercialista and Revisore Legale in Italy and a partner at Studio Rizza & Vassallo. She advises international individuals, remote workers, freelancers and foreign entrepreneurs on Italian tax residence, foreign income, Partita IVA, company structures and compliance. She works online across Italy in English, Italian and Russian.

AnyExpat profile: Studio Rizza Vassallo

Official legal references

Italian tax residence: Agenzia delle Entrate, Circular 20/E of 4 November 2024 (English)

Italian Revenue Agency: general rules for individual tax residence

Italian Revenue Agency: IRPEF and worldwide income for residents

UK-Italy Double Taxation Convention: Articles 4, 15 and 24

HMRC: UK Statutory Residence Test and split-year treatment

Italian Revenue Agency: Quadro RW – foreign investments and financial assets

EU guidance: social-security coverage when living or working in another EU country

UK guidance: National Insurance when working in the EU

Disclaimer

This article provides general information as at 22 August 2026. It does not constitute individual tax, legal, immigration, social-security or investment advice. The correct treatment depends on the facts, the applicable treaty, the classification and timing of each income item, foreign taxes paid and the taxpayer’s documentation. Professional advice should be obtained before acting.

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The obligations and liabilities of the parties incurred prior to the termination date shall survive the termination of this agreement for all purposes.

These Terms of Service are effective unless and until terminated by either you or us. You may terminate these Terms of Service at any time by notifying us that you no longer wish to use our Services, or when you cease using our site.

If in our sole judgment you fail, or we suspect that you have failed, to comply with any term or provision of these Terms of Service, we also may terminate this agreement at any time without notice and you will remain liable for all amounts due up to and including the date of termination; and/or accordingly may deny you access to our Services (or any part thereof).

SECTION 17 – ENTIRE AGREEMENT

The failure of us to exercise or enforce any right or provision of these Terms of Service shall not constitute a waiver of such right or provision.

These Terms of Service and any policies or operating rules posted by us on this site or in respect to The Service constitutes the entire agreement and understanding between you and us and govern your use of the Service, superseding any prior or contemporaneous agreements, communications and proposals, whether oral or written, between you and us (including, but not limited to, any prior versions of the Terms of Service).

Any ambiguities in the interpretation of these Terms of Service shall not be construed against the drafting party.

SECTION 18 – GOVERNING LAW

These Terms of Service and any separate agreements whereby we provide you Services shall be governed by and construed in accordance with the laws of Clyde Offices, 2nd Floor, 48 West George Street, Glasgow, BFP, G21BP, United Kingdom.

SECTION 19 – CHANGES TO TERMS OF SERVICE

You can review the most current version of the Terms of Service at any time at this page.

We reserve the right, at our sole discretion, to update, change or replace any part of these Terms of Service by posting updates and changes to our website. It is your responsibility to check our website periodically for changes. Your continued use of or access to our website or the Service following the posting of any changes to these Terms of Service constitutes acceptance of those changes.

SECTION 20 – CONTACT INFORMATION

Questions about the Terms of Service should be sent to us at [email protected].

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