Italy now charges new residents a flat €300,000 a year on all foreign income, up from €200,000, for people who move on or after 1 January 2026. Greece still charges €100,000. Both last up to 15 years and both add a charge per family member, but the entry conditions, the investment test and the deadlines differ sharply.
What changed in Italy in 2026
Law No. 199 of 30 December 2025, the 2026 Budget Law, paragraph 25 of article 1, replaced €200,000 with €300,000 in the new-resident regime and €25,000 with €50,000 for each family member. Paragraph 26 limits the change to people who transfer residence to Italy from the date the law entered into force, which Normattiva records as 1 January 2026.
The law then moved. Legislative Decree No. 117 of 19 June 2026 consolidated Italy's income tax rules into a single code, in force from 4 July 2026. The regime now lives in article 246 of that code, and Normattiva shows the old article 24-bis of the 1986 code as repealed. The substance carried over; the citation did not. Rulings, adviser letters and bank onboarding files that cite article 24-bis now point to a repealed provision.
How Italy's flat tax works
Article 246 lets an individual who transfers tax residence to Italy pay a fixed substitute tax on income produced abroad, whatever its amount. The conditions:
- No Italian tax residence for at least 9 of the 10 tax years before the option starts.
- €300,000 per tax year for the main applicant, €50,000 per tax year for each family member the option is extended to.
- The option is exercised only after a favourable ruling on a specific request to the Agenzia delle Entrate, filed by the tax return deadline for the year of the move.
- It ends after 15 years at the latest, and ends immediately if the tax is not paid in full and on time. Revocation or loss bars a new option.
- Capital gains on qualifying shareholdings realised in the first 5 years of the option stay outside the flat tax.
- The taxpayer can carve out specific countries, taking ordinary taxation and a foreign tax credit for income from those countries instead.
The tax is paid in a single instalment by the balance payment date for income tax, and it cannot be combined with Italy's impatriate worker or returning researcher regimes. Italian source income stays taxed under the ordinary rules. At the national top rate of 43 percent above €50,000, set in article 11 of the new code, €300,000 equals the national income tax on roughly €716,000 of income, before regional and municipal surcharges. Below that level of foreign income the flat tax costs more than ordinary taxation would, on national rates alone.
How Greece's flat tax works
Greece's regime is article 5A of Law 4172/2013. The Independent Authority for Public Revenue (AADE) guide dated 12 November 2025 sets out the terms:
- €100,000 a year on income arising abroad, regardless of the amount, for 15 tax years starting from the year of the application.
- €20,000 a year for each family member the regime is extended to.
- No Greek tax residence in 7 of the 8 years before the move.
- An investment of at least €500,000 in Greek real estate, businesses, securities or shares, by the applicant, a relative or a majority-owned entity, completed within 3 years of the application.
- The application is due by 31 March of the tax year concerned.
- Movable property located abroad is exempt from Greek inheritance and gift tax.
If the flat amount is not paid in full in any year, the taxpayer leaves the regime from that year and is taxed on worldwide income under the general rules. The same AADE guide covers articles 5B and 5C, which run on separate terms.
How Italy compares to Greece
- Italy · €300,000 a year · family member €50,000 · non-resident 9 of the prior 10 years · no investment test · advance ruling required · up to 15 years
- Greece · €100,000 a year · family member €20,000 · non-resident 7 of the prior 8 years · €500,000 Greek investment within 3 years · apply by 31 March · 15 years
On the headline figure alone, Italy now costs three times Greece. Over a full 15 years that is €4.5 million against €1.5 million for a single applicant, before any family extension. Greece offsets part of the gap with its investment condition, which ties up €500,000 in Greek assets; Italy has none. See the Italy country guide and the Greece country guide for the wider rate picture.
Heed's reading: the Italian increase does not touch anyone who moved before 2026, but the relocation of the rule into article 246 touches everyone, because every document citing article 24-bis now cites repealed law.
Who is affected by the Italian increase
Only people who transfer residence to Italy on or after 1 January 2026. Paragraph 26 of the Budget Law applies the new amounts to transfers from that date. Someone comparing Italy against Portugal's regime for skilled workers, covered in our IFICI guide, or against the UK's four-year regime, covered in our foreign income and gains note, should use €300,000 as the Italian figure from now on. The residency tests that decide when a transfer actually happens are covered on our tax residency page.
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