Could different tax regimes for individuals moving to Italy be combined?
Roberto M. Cagnazzo
by Roberto M. Cagnazzo
In ruling No. 16/2025 of 28 January 2025, the Italian tax authorities introduced a significant development regarding the compatibility of different tax-favourable regimes for individuals relocating to Italy. They confirmed that individuals can simultaneously benefit from both the new inbound workers' regime and the professors' regime within the same tax period, provided the income derives from different sources.
As a reminder:
The new inbound workers' regime provides a 50% exemption on employment and self-employment income for individuals transferring their residence to Italy and committing to reside there for at least four years.
The professors' regime grants a 90% exemption on employment and self-employment income for individuals transferring their residence to Italy to engage in teaching or research activities.
Previously, the cumulation of tax benefits was strictly regulated under the previous inbound workers' regime (applicable to individuals relocating to Italy by 31 December 2023), which prohibited the simultaneous use of the professors' regime. The Italian tax authorities confirmed the impossibility of applying two benefits within the same tax period, though they allowed for their application in different years.
The new inbound workers' regime is now governed by Legislative Decree No. 209/2023, replacing the previous Legislative Decree No. 147/2015. In this new context, ruling No. 16/2025 clarifies that, in the absence of an explicit regulatory exclusion, the new inbound workers' regime may be enjoyed in conjunction with other favourable regimes for those transferring their residence to Italy. Consequently, a taxpayer can benefit from multiple incentives within the same tax period.
This interpretation has been applied to the case of a taxpayer who moved to Italy in 2025 to simultaneously engage in:
Self-employment as a dental surgeon, benefiting from the new inbound workers' regime (50% tax exemption); and
Employment as a professor at an Italian university, benefiting from the professors' regime (90% tax exemption).
The principle expressed by Italian tax authorities appears to have a general scope, and, as such, could also apply to the relationship between the new inbound workers’ regime and the new residents’ regime, which provides for an annual substitute tax of EUR 200,000 on income produced abroad by individuals who transfer their residence to Italy. In this case, there would be no overlap, as the two tax benefits apply to income from different sources – Italian-source income for inbound workers, and foreign-source income for new residents.
However, the situation differs when considering the relationship between the new residents' regime and the incentives for professors, as the law continues to expressly prohibit the accumulation of these benefits.
This broad interpretation could be relevant not only for individuals planning to return to Italy but also for those who moved back in 2024 and engage in two different activities. These individuals, not anticipating such an interpretation from the tax authorities, may have applied for only one tax relief within the same period, possibly opting for the inbound workers' regime due to its broader scope. However, they may now also be eligible for the parallel tax incentive on income derived from teaching and research activities.
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Three & Partners is a boutique firm based in Turin and deep-rooted in the north-west of Italy, with a clear European identity and a strong international vocation. The firm provides integrated tax, corporate, legal, and business advice, and assistance all over Italy on a wide range of domestic, European, and international matters.
Roberto M. Cagnazzo, Founding Partner, is a chartered accountant and statutory auditor with considerable experience in domestic and international taxation acquired as Head of Tax in some of Italy’s leading multinational groups, and as Professor of Comparative Tax Systems and of Tax Law at the University of Turin. Contact Roberto.
