The UK has announced a farewell to the tax-advantaged regime provided for“res non dom” which, according to HMRC data, would number nearly 60,000 adherents. According to estimates, a non-marginal portion of these, in view of the future loss of tax benefits, may decide to settle in Italy to take advantage of the “neo-residents” scheme under Art. 24-bis of the TUIR, which provides for a flat-rate taxation, amounting to 100 thousand euros per year, on foreign-source income, which can also be extended to family members upon payment of an additional substitute tax of 25 thousand euros, as well as exemption from gift and inheritance tax on all assets and rights existing abroad.
Foglia & Partners analyzed the potential impacts of the novelty in terms of revenue for Italy, highlighting how the attraction of HNWIs and UHNWIs, now resident in the United Kingdom, could also lead to a significant increase in indirect taxation, especially in real estate, as well as in taxes ordinarily due on income originated in Italy.
In fact, as said to Carlotta Scozzari, whom we thank for the space, “the decision to abolish the ‘res non dom’ regime will lead investors, shareholders and top managers to also reconsider individual geographies and move to other jurisdictions,” thus creating additional revenue. For example,“‘luxury’ properties do not benefit from exemptions for Imu purposes and, in purchase and sale transactions,the maximum rates apply for both VAT (22 percent) and registration tax (9 percent), without the chance of invoking the benefits related to the first home.”
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