Italy is joining the growing investment migration movement. The Government of Italy amends its immigration and tax laws, paving the way for the development of a residence-by-investment program in one of the largest countries in Europe.

In recent years the need to develop a diverse residence and citizenship portfolio alongside the traditional investment portfolio is being seen as an increasingly important part of the growth and sustainability strategies of wealthy families and individuals. This has posed interesting new challenges and opportunities for governments, with the concepts of immigration, citizenship, and statehood being debated and contested. Countries are finding themselves not only competing for international talent, but also for investors, entrepreneurs, and high-net-worth individuals and families, and having to find new ways of generating growth based on this new and global trend of investment migration.

The general immigration rules have been amended to facilitate the immigration process for non-European nationals, particularly business people and entrepreneurs, who would invest:

•  A minimum of EUR 2 million in Italian government bonds
• A minimum of EUR 2 million in Italian corporation bonds or shares (reduced to EUR 500,000 for investment in innovation start-ups)
• A minimum of EUR 1 million in ‘projects of public interest’ (culture, education, immigration management, research and development, arts and heritage)

The investment needs to be held for a minimum of two years. An ‘investor visa’ is granted for two years and renewable for a further three-year period provided the investment is maintained. A ‘family visa’ is also granted to other members of the investor’s family.

New rules have been introduced to the current income tax legislation to facilitate the return to Italy of researchers and qualified workers currently living outside of the country.

A substitutive tax regime has been introduced for income produced outside of the country for those persons who have not been Italian tax payers during nine of the previous 10 years and are transferring their fiscal residence to Italy. Under the new regime:

Taxpayers are liable to progressive tax rates on income produced in Italy

An annual lump sum tax payment of EUR 100,000 is due on income from foreign investment, foreign financial assets and any other foreign-source income (extended to family members for an additional EUR 25,000 per person annually)

The option is granted for a maximum of 15 years.