Rimpatriate Tax Relief
The Italian Revenue Agency, through rulings no. 53/E/2025 and no. 66/E/2025, has issued clarifications regarding the complex rimpatriate tax relief for returning workers.
Key points include:
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The minimum foreign residence period for accessing the new inbound regime is seven tax years, in cases where the employer abroad (company/group) is the same as the employer in Italy post-relocation. This applies even if, prior to their return, the worker performed freelance activities (ruling no. 53/E/2025);
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Under the new rimpatriate tax regime, it is no longer necessary to prove a functional link between the move to Italy and the start of a qualifying employment that generates income in Italy. Unlike the previous regime, the required conditions may now be met even after the return. The relief applies to each tax year in which the conditions are satisfied (ruling no. 66/E/2025).
Conversion into law of the 2025 Mille Proroghe Decree
We inform our Clients that Law no. 15 of 21 February 2025, converting with amendments Decree-Law no. 202/2024 (the “2025 Mille Proroghe Decree”), was published in the Official Gazette no. 45 of 24 February 2025. Below is a summary of the main labor-related provisions:
Reopening of the Rottamazione-Quater Program
(Article 3-bis, paragraphs 1–2)
Taxpayers excluded from the Rottamazione-quater program due to missed, partial, or late payments by 31 December 2024 may reapply, only for debts already included in previous applications. The new application must be submitted by 30 April 2025, exclusively online, via the public tax collection agency’s website. The procedure will be published within 20 days of the conversion law’s effective date.
2025 Fiscal Calendar Update
(Article 3-bis, paragraphs 3–5)
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17 March 2025: Deadline for approval and digital availability of income and IRAP tax forms;
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30 April 2025: Opening date for submission of tax returns;
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30 April 2025: Deadline for release of software tools related to fiscal reliability indexes (ISA) and pre-filled tax data (CPB).
Catastrophe Insurance Policies
(Article 13, paragraph 1 & Article 19, paragraph 1-quater)
The deadline to subscribe to catastrophe insurance policies is extended to 31 March 2025 for most businesses, and to 31 December 2025 for fisheries and aquaculture companies.
VAT and the Third Sector
(Article 3, paragraph 10)
The transition from VAT exclusion to the new VAT exemption regime for Third Sector entities is postponed to 1 January 2026.
Fixed-Term Contracts with Individual Justifications
(Article 14, paragraph 3)
The ability to extend fixed-term contracts beyond 12 months based on individual (non-collective) justifications of a technical, organizational, or productive nature is extended until 31 December 2025, pending sector-specific collective agreements.
