Article 24-bis entered the Italian Consolidated Income Tax Code through Law 232/2016 (the 2017 Budget Law, in force from 1 January 2017), permitting new tax residents who had not been Italian tax resident in nine of the previous ten years to opt for a flat 100,000 euro annual substitute tax on all foreign-sourced income, for up to fifteen years. Family members joined at 25,000 euros each. When the legislation was first promoted by the Renzi government, the projected uptake was modest. Observers expected a small annual flow of high-income relocators and a moderate effect on Italian fiscal residence patterns. Eight years in, the picture is different.

By 2022, the Italian Ministry of Finance reported 2,730 enrolled individuals. Maisto e Associati, one of Italy’s leading international tax law firms, estimated a further 1,200 UHNWI enrolments in 2023, bringing the cumulative total to roughly 4,000 principal taxpayers plus dependants (Maisto e Associati, 2024). Henley projects an additional 3,600 millionaire net inflow to Italy in 2025 alone, with the flat-tax regime cited as the primary fiscal driver alongside lifestyle (Henley and Partners, 2025). I am not fully convinced by the 3,600 figure (it exceeds recent average annual enrolment by a substantial margin), but the underlying flow is real.

The Italian government has twice tightened the regime since 2022. Decree-Law 113 of 9 August 2024 doubled the lump-sum tax from 100,000 to 200,000 euros for new residents establishing Italian tax residency after 10 August 2024 (Italian Ministry of Finance, 2024). The 2026 Budget Law, in force from 1 January 2026, raised it again to 300,000 euros for new residents from that date (PricewaterhouseCoopers, 2026). Existing participants retain their original entry rate for the remainder of their fifteen-year eligibility. Each new cohort of entrants faces a higher entry price. The trajectory tells you what the Italian Treasury has concluded: the regime works well enough that the government can extract more revenue per participant without losing the underlying flow.

Direct effects on Italian wealth concentration are visible. Milan, particularly, has become a genuine European wealth hub rather than a cultural destination. The Quadrilatero della Moda, Brera, and the newer Porta Nuova developments absorbed the bulk of the financially-driven inflow. Rome’s traditional ultra-prime markets, around the Aventino and Parioli, attract older relocators. Lake Como and the Costa Smeralda benefited from secondary residence acquisition accompanying primary fiscal relocation. Florence, Tuscany more broadly, and the Amalfi coast saw lifestyle-driven secondary acquisition layered onto the primary fiscal-residence allocation.

Indirect effects are more interesting. Monaco’s quasi-monopoly position as the default European fiscal residence for mobile UHNWIs has weakened. Younger UHNWI principals, particularly those with net worth in the 30 million to 500 million dollar range, increasingly select Italy over Monaco. The reasoning is qualitative. Italy offers a richer lifestyle, deeper cultural infrastructure, and significantly more space than Monaco’s two square kilometres. The fiscal calculation tilts the other way (Monaco’s zero personal income tax for non-French residents remains cheaper than 200,000 to 300,000 euros per year), but for principals with substantial foreign income and a preference for lifestyle alignment, the Italian regime is competitive enough to win the choice.

Geneva and Zurich have seen similar repositioning, less pronounced. The Swiss lump-sum tax regime (forfait fiscal) continues to attract a specific segment, particularly French and Belgian UHNWIs seeking proximity to home. The Italian regime competes on lifestyle dimensions Switzerland cannot replicate.

The most pronounced indirect effect has been London. Brexit (2020), the closure of the Tier 1 Investor Visa (February 2022), and the abolition of the non-dom regime (April 2025) collectively displaced a meaningful share of the UHNWI population historically anchored in London. Italy has been a primary recipient, alongside the UAE and Switzerland (Henley and Partners, 2025). The Italian flat-tax regime did not cause the London exodus, but it provided a credible alternative for principals seeking to retain European exposure while reducing UK fiscal exposure.

Service provider consequences are real. Italian advisors with credible international competence (English-language fluent, treaty-fluent, multi-jurisdictional network) command premium fees. Italian private banks have built dedicated international client teams. Major US private banks established or expanded their Italian presence specifically to serve inbound American principals taking the flat-tax option. Monaco-based wealth managers are restructuring their offerings to retain clients now spending half the year on Lake Como.

For brokerages, the flat-tax effect translated into measurable transaction volume changes. Milan ultra-prime transactions above 5 million euros increased substantially between 2017 and 2024, with multiple Italian brokerage reports documenting the trend. The market for villas on Lake Como at the 10 million dollar-plus threshold has more than doubled in transaction depth. The Sardinia summer market has shifted from a seasonal-rental economy to a substantial acquisition market, particularly along the Costa Smeralda.

A counterfactual worth flagging. The doubling and then tripling of the flat-tax entry price (100,000 to 200,000 to 300,000 euros) will reshape the regime’s selectivity. The 100,000 euro regime was attractive to principals with one million dollars-plus in annual foreign income. The 200,000 euro regime is meaningful for those with two million-plus. The 300,000 euro regime is relevant only for those with three million-plus or substantially more. The regime is becoming more selective and more concentrated at the very top. Whether this strengthens Italy’s position or narrows it depends on whether the next cohort of new entrants has the income concentration to justify the higher entry. Initial signals: demand remains strong, but the Italian Treasury is testing the demand curve.

The broader European fiscal cartography has shifted in ways the 2017 designers did not fully anticipate. The European UHNWI ecosystem is now more distributed, less concentrated, and more demanding for advisors who must operate across multiple jurisdictions simultaneously.

References

• Hay, I. and Beaverstock, J.V. (eds.) (2016) Handbook on Wealth and the Super-Rich. Cheltenham: Edward Elgar Publishing. ISBN 978-1-78347-403-5.

• Henley and Partners (2025) Henley Private Wealth Migration Report 2025. London: Henley and Partners and New World Wealth, June 2025.

• Italian Ministry of Finance (2016) Legge n. 232 dell’11 dicembre 2016 (Legge di Bilancio 2017). Gazzetta Ufficiale, Serie Generale n. 297, 21 December 2016.

• Italian Ministry of Finance (2024) Decreto-Legge n. 113 del 9 agosto 2024 (Decreto Omnibus). Gazzetta Ufficiale, 10 August 2024.

• Italian Ministry of Finance (2026) Legge di Bilancio 2026: Disposizioni in materia di imposizione sostitutiva sui redditi prodotti all’estero. Gazzetta Ufficiale, January 2026.

• Knight Frank (2026) The Wealth Report 2026. London: Knight Frank Research.

• Knowles, C. (2022) Serious Money: Walking Plutocratic London. London: Allen Lane (Penguin).

• Maisto e Associati (2024) Italian Flat Tax for New Residents: Practice Note. Milan: Maisto e Associati Studio Legale Tributario.

• Paris, C. (2016) ’The Residential Spaces of the Super-Rich’, in I. Hay and J.V. Beaverstock (eds.) Handbook on Wealth and the Super-Rich. Cheltenham: Edward Elgar Publishing, Chapter 12, pp. 244-263.

• PricewaterhouseCoopers (2026) Italy - Individual: Taxes on personal income. Worldwide Tax Summaries, February 2026.

• Withers Worldwide (2025) Italy’s Flat Tax Regime Explained. London: Withers LLP, April 2025.