Italy tax haven for 1,136 super rich. But another 500 could have arrived by 2023.
The Court of Auditorsin the Report on the general financial statement of the State for the year 2023, returns to the question of thesubstitutive tax from 100,000 euros for the big boys, a very important topic in view of the imminent millionaires fleeing the UKafter the announced abolition of the res non dom regime, expected for 2025.
The ever-increasing numbers had already been shed light on latest statistics on Irpef declarations for the 2022 tax year, as ItaliaOggi had anticipated.
In 2022, the Court adds, 818 main taxpayers and 318 family members joined the scheme: a real boom considering that in 2018 there were only 196 main taxpayers and 67 family members. In the five-year period 2018-2022, the scheme therefore generated payments of approximately 254 million euros, of which 232 for main taxpayers and just under 22 million for family members.
The figure is then destined to grow if we consider that the Agency responded, in 2023, to 576 requests that are presented on an optional basis before exercising the option, to express interest in transferring to the Bel Paese.
Criticisms from accounting judges
As already noted in previous reports on the General Budget, the Revenue Agency is not aware of either the amount of foreign income on which the substitute tax applies, or the ordinary taxes that would have actually been levied on such income in the absence of the substitute tax regime. Nor have specific surveys been prepared to assess the real correspondence of the measure to the purpose declared in the explanatory report to the 2017 budget law, which introduced the regime, according to which the purpose would have been “to encourage investments in Italy by non-resident entities”.
The discipline of the regime: “appears mainly aimed at favoring subjects who can draw sources of income from multiple countries and who transfer their residence to Italy for work, residential or other reasons”, as in the “probably frequent” case of professional athletes, without however requiring “as one would have expected” an effective and tangible connection with the realization of productive investments in Italy. The tax regime allows individuals who transfer their residence to Italy to opt for a substitute tax on income produced abroad. The tax amounts to 100,000 euros per year and 25,000 euros for each family member to whom the option is extended, which can have a maximum duration of 15 years.
Checks on residents in low-tax countries
The Court of Auditors also sheds light on those Italians who enjoy a favorable regime in a tax haven. In 2021, approximately 32,778 Italian citizens residents of states or territories in privileged tax regime have declared the availability of sources of income subject to declaration in Italy. Between 2019 and 2023, the Revenue Agency has therefore carried out 917 checks on these subjectswith a positive outcome in 77.1% of cases. Most of them involved taxpayers resident in Switzerland (69.9%).
In 2023 the country was eliminated from the tax haven blacklist for Irpef purposes following an agreement signed between Rome and Bern. In addition to the more traditional tax havens, the Revenue Agency is also directing its attention towards those Italian citizens who enjoy preferential tax regimes in Cyprus, Portugal, Tunisia, Greece, Montenegro, Romania, Slovakia and Albania.
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