Tax Regime for Incoming Workers: Clarifications from the Italian Revenue Agency

Since the beginning of the year, the Italian Revenue Agency has issued several clarifications regarding the eligibility requirements for the new tax incentive for incoming workers, introduced by Legislative Decree 209/2023.

Specifically, the agency has provided insights on:

• The required duration of residence abroad before relocating to Italy (ruling no. 72 of 2025).
• The criteria for high qualification and specialization (responses to rulings no. 55, 66, 71, and 74 of 2025).
• The eligibility of foreign individuals transferring their tax residence to Italy for the first time (ruling no. 70 of 2025).

The New Tax Regime for Incoming Workers

Since 2024, a new tax relief scheme has been in place for employees and self-employed workers who move their tax residence to Italy starting from the 2024 tax year. Eligible individuals can benefit from a 50% exemption on their taxable income—up to an annual limit of €600,000—for five tax years, provided they meet the conditions set out in Article 5 of Legislative Decree 209/2023, including:

• Moving their tax residence to Italy no earlier than January 1, 2024.
• Committing to residing in Italy for at least four years.
• Not having been a tax resident in Italy for the previous three tax years.
• Carrying out their work activity mainly within Italy.
• Holding a qualification or specialization as defined by Legislative Decrees 108/2012 and 206/2007.

If the worker’s Italian employer is the same company (or part of the same corporate group) they worked for abroad, the required period of prior residence abroad increases to six years—or seven years if they were previously employed in Italy by the same employer or a related entity before relocating abroad.

Additionally, the scheme provides an enhanced benefit, increasing the exempt portion of income to 60%, in cases where:

• The worker relocates to Italy with a minor child.
• A child is born or adopted during the period in which the tax relief applies.

High Qualification and Specialization Requirements

The Italian Revenue Agency has frequently been asked to clarify the qualifications needed to access the new tax relief for incoming workers.

In ruling no. 55 (February 28, 2025), the agency addressed a taxpayer’s query regarding whether their academic degree and professional qualifications met the necessary criteria. The taxpayer held a diploma and a license as a “Master on vessels of 3,000 gross tonnage or more,” along with certification as a Company Security Officer. They had been hired in Italy in 2024 with a senior managerial qualification (Quadro Super).

The query asked whether these credentials satisfied the high qualification and specialization requirement, given that the license was not officially recognized in Italy as equivalent to a university degree. The taxpayer also sought clarification on whether both an advanced degree and a high-level qualification were required, or if merely holding a high-ranking professional position (falling within levels 1, 2, or 3 of ISTAT’s CP 2011 classification) was sufficient for eligibility.

While the Revenue Agency stated that such technical assessments fall outside its competence, it pointed to Article 5 of Legislative Decree 209/2023, which refers to Article 27-quater of the Immigration Code (introduced by Legislative Decree 108/2012) for defining qualification criteria. The agency indicated that the taxpayer could benefit from the scheme, provided they meet at least one of the specified qualification requirements, but stressed that it is not responsible for assessing these qualifications in ruling procedures.