Article 24-ter allows a person who moves their tax residence to Italy, holding a pension paid by a foreign entity, to apply a substitute tax of 7% in place of ordinary Italian taxation.
The detail that surprises people: it does not apply only to the pension. It covers all income of foreign source โ pensions, dividends, interest, royalties, rents, capital gains, and proceeds from the liquidation of foreign companies. One flat rate, across the whole foreign side of your affairs.
It runs for ten consecutive tax years, and it also removes the foreign asset reporting obligation and the IVIE and IVAFE charges on the assets it covers.
For a retiree drawing 60,000 euro a year from abroad, ordinary Italian taxation would take a substantial progressive bite. Seven per cent takes 4,200 euro. Across ten years the difference is not marginal โ it is the difference between two standards of living.