In recent months, the debate over Italy’s tax attractiveness has intensified, particularly following the changes to the “non-dom” regime in the United Kingdom. An increasing number of high-net-worth individuals are considering relocating their residence to European countries that offer preferential tax regimes, including Italy with its flat tax for new residents equal to 300,000 euros per year on foreign income.
This phenomenon is part of a broader context of international tax competition, often critically referred to as “tax dumping” — the ability of certain countries to attract capital and taxpayers through particularly favorable fiscal regimes.
Italy: an attractive system, but with high costs
The Italian regime, introduced in 2017 and recently increased up to 300,000 euros per year, allows new residents to replace ordinary taxation on foreign income with a fixed tax. This is an effective tool for attracting large wealth, but it still presents a significant cost, sustainable only for taxpayers with extremely high financial resources.
San Marino: an even more efficient solution
In this scenario, the Republic of San Marino represents a particularly interesting and competitive alternative.
The Sammarinese system indeed provides for facilitated tax residence regimes with a lump-sum tax on foreign income that indicatively ranges:
- from a minimum of 10,000 euros
- up to a maximum of 100,000 euros per year
For the same wealth profile, this results in an extremely significant tax advantage compared to the Italian regime.
Beyond taxation: stability and quality of the system
In addition to the fiscal profile, San Marino offers further attractive elements:
- regulatory and institutional stability
- a secure and highly qualified environment
- geographic and operational proximity to Italy
- access to specialized professional services
An opportunity to evaluate from a strategic perspective
The growing international interest in alternative tax regimes demonstrates how the choice of residence is no longer just a personal matter, but a true strategic decision.
In this context, San Marino positions itself as one of the most efficient solutions in Europe for:
- entrepreneurs
- international investors
- managers and professionals with foreign income
The role of the advisor
Proper planning of tax residence requires an in-depth analysis of personal and financial situations, as well as careful management of international regulatory aspects.
Our firm assists Italian and foreign clients in the process of transferring residence, evaluating the best solutions in tax, legal, and operational terms.
