An interpretation just out from the Agenzia delle Entrate has caught many people off guard — and the consequences could be expensive
Here’s what everyone assumed
Under the Impatriate Scheme, living in southern Italy meant only 10% of your income was taxable — a huge advantage over the 30% rate in the north. If you moved north mid-scheme, the general understanding was straightforward: you lose the extra benefit from that point on, and pay at 30% going forward. End of story.
Here’s what the Agenzia now says
According to this new interpretation, you are only entitled to the southern rate if you stay in the south for the entire qualifying period (5 or 10 years). Move north at any point, and the Agenzia’s position is that you were never properly entitled to the enhanced benefit in the first place.
That means repaying the difference — plus interest, plus penalties.
does this affect you?
If you registered as an impatriate in a southern comune and have since moved to central or northern Italy — at any point during your qualifying period — this ruling may apply to you.
The potential exposure depends on how long you benefited from the enhanced rate before moving, but for many people it won’t be a small number.
If this sounds like your situation, please get in touch as soon as possible. We’re watching this one closely.

