Flat Tax for “New Residents”: A Comparison between the Italian and Portuguese Regimes

Italy recently introduced a lump-sum substitute tax in lieu of progressive tax rates on foreign-sourced income received by “high net worth individuals” and pensioners transferring their tax residence to Italy. These favourable regimes share common elements with the Portuguese regime for “non-habitual residents”. The aim of this article is to ascertain whether the Portuguese regime for “non-habitual residents” could be implemented in Italy in respect of the taxation of “new residents”.