Introduced by the 2017 Budget Law, the investor visa (art. 26-bis of Legislative Decree 286/1998) allows nationals of non-EU States to enter and reside in Italy in return for a qualifying investment or donation, outside the annual entry quotas.
The four types of investment
- €2,000,000 in bonds issued by the Italian Government, held for at least two years;
- €500,000 in the equity of a company incorporated and operating in Italy;
- €250,000 in the equity of an innovative start-up entered in the special section of the Companies Register;
- €1,000,000 as a philanthropic donation supporting a project of public interest (culture, education, immigration management, scientific research, cultural and landscape heritage).
The applicant must also show ownership of the funds and that they can be freely transferred to Italy, their lawful origin, and sufficient resources for their own maintenance, above the minimum level set for exemption from healthcare charges.
The procedure
- Application for clearance through the dedicated online platform, examined by an inter-ministerial Committee at the Ministry of Enterprises and Made in Italy, which normally decides within 30 days.
- Issue of the visa by the competent Italian diplomatic or consular mission.
- Entry and residence permit: within eight days of entry the applicant must apply for the two-year “investor” residence permit.
- Making the investment within three months of entry, and notifying the Committee.
- Renewal for further periods, subject to the investment being maintained.
The permit allows the holder to work and to be joined by family members. The period of lawful residence may later count towards citizenship by residence.
Tax planning: the new-resident regime
The Investor Visa is a residence document, not a tax regime; tax residence is determined under article 2 of the Income Tax Code and the double tax treaties. For individuals whose wealth and income are mainly foreign, article 24-bis of the Income Tax Code allows them to opt for a flat annual substitute tax on foreign income instead of ordinary personal income tax, for up to fifteen tax years, provided they were not resident in Italy for at least nine of the previous ten years. The option can be extended to family members at a reduced amount and exempts the holder from foreign-asset reporting and from the IVIE and IVAFE wealth taxes on foreign assets.
The amount of the substitute tax has been raised several times by the legislature, most recently with measures applying to those who move after they took effect, so it should be checked at the date of the move. For those who will work in Italy, the regime for inbound workers (art. 5 of Legislative Decree 209/2023) may be more favourable.
Points to watch
- evidence of the origin of the funds is the focus of the review and should be prepared early;
- the type of investment chosen affects the economic risk and the renewal;
- tax planning (rulings, treaties, the family’s position) should be set up before the move, not after.
This note is for information only and reflects the law at the date of publication; thresholds and amounts are subject to legislative change. It is not legal or tax advice.