Practice Area
Personal Tax Relocation
Strategic tax residency planning for entrepreneurs, executives and high-net-worth individuals relocating to Italy, the UK or the United States — minimising your global tax burden from day one.
Who We Help
Is your situation one of these?
Entrepreneur Moving Abroad
Business owner or founder planning to relocate internationally and optimise personal taxation through a recognised residency regime.
HNW Individual & Family
High-net-worth family seeking a flat-tax or non-dom regime to shelter foreign income, reduce inheritance exposure and protect intergenerational wealth.
Remote Worker & Digital Nomad
Location-independent professional looking to establish genuine tax residency in a favourable jurisdiction with legal certainty and banking stability.
Retiree & Passive-Income Recipient
Retiree or investor with passive income (dividends, royalties, pensions) seeking a jurisdiction with favourable flat-rate treatment on foreign income.
01
Italy Flat Tax Regime (Art. 24-bis TUIR)
Italy’s lump-sum substitute tax allows new tax residents to pay a flat €100,000 per year on all foreign-source income — regardless of amount — for up to 15 years. This regime is ideal for entrepreneurs, retirees and investors with significant non-Italian income. We manage the full onboarding process from eligibility analysis to Revenue Agency ruling.
- Eligibility assessment: residency history and compliance with the 9-out-of-10-years rule
- Advance ruling (interpello) with the Italian Revenue Agency (Agenzia delle Entrate)
- Transfer of tax residency to Italy — immigration coordination
- Family members extension: €25,000 per dependent (spouse, children)
- Annual compliance: filing of Italian Redditi PF with flat-tax election
- Interaction with US citizenship obligations (FEIE, FTC, FBAR)
02
Italy Impatriates Regime (Lavoratori Impatriati)
The Impatriates regime (formerly 70–90% income exemption, revised 2024) allows individuals transferring their tax residency to Italy to benefit from a reduced taxable base on employment and self-employment income for 5 years, extendable under specific conditions. We advise on qualification, compliance and maximum tax savings under the new rules in force from 2024.
- Eligibility check: residency abroad for at least 3 years (new 2024 rules)
- 50% income exemption on Italian employment and self-employment income
- Extended benefit: 5+5 years for families with children or property purchase
- Interaction with flat-tax regime and treaty residency rules
- Application to freelancers, executives and company directors
- Coordination with Italian social security (INPS) obligations
03
UK Non-Domiciled Residence Planning
The UK’s Non-Dom regime (significantly reformed from April 2025) historically allowed foreign domiciliaries to be taxed only on UK-source income. As the regime transitions to a residence-based system, careful planning is essential for individuals considering or currently in the UK. We advise on transitional provisions, Foreign Income and Gains (FIG) relief and the new 4-year FIG exemption.
- Non-Dom status assessment and domicile planning under English law
- New 4-year Foreign Income and Gains (FIG) exemption (2025 reform)
- Transitional rules: Temporary Repatriation Facility (TRF) planning
- Remittance basis vs arising basis analysis under transitional provisions
- UK – Italy tax treaty interaction for dual residents
- UK Inheritance Tax exposure and offshore trust planning
04
US Domicile & Florida Residency Planning
Florida has no state income tax, no inheritance tax and no capital gains tax — making it one of the most tax-efficient US states for relocation. For non-US persons acquiring US residency and for Americans relocating internally, we advise on establishing Florida domicile, severing prior state tax nexus and structuring assets for maximum efficiency.
- Florida domicile declaration and statutory residency test compliance
- Severance of prior-state nexus (New York, California, Illinois)
- Homestead Exemption and Save Our Homes cap election
- Federal tax position for new US residents: Green Card timing and PFIC exposure
- Pre-immigration tax planning for non-US nationals acquiring a Green Card
- Florida LLC and trust structuring for asset protection
05
Exit Tax & Pre-Departure Planning
Leaving a country is often as tax-sensitive as arriving. Italy, the UK, Germany and France impose exit taxes on unrealised capital gains when a tax resident departs. For Americans, renouncing citizenship triggers the Section 877A Exit Tax. We provide comprehensive pre-departure analysis and structuring to legally minimise the tax cost of relocation.
- Italian exit tax (Art. 166-bis TUIR) on corporate shareholdings and business assets
- US Section 877A Expatriation Tax — covered expatriate analysis and Form 8854
- UK CGT deemed disposal on departure (rebasing election)
- Asset restructuring and timing strategies to reduce exit tax exposure
- Coordination of departure date with treaty residency rules
- Pension and deferred compensation optimisation before departure
06
Ongoing Residency Compliance & Day-Count Management
Tax residency depends not only on formal registration but on physical presence, centre-of-life tests and day-counting rules that vary by country. We provide ongoing compliance support to ensure our clients maintain their chosen residency position, pass substance tests and avoid challenges from tax authorities.
- Day-count tracking and travel diary documentation
- UK Statutory Residence Test (SRT) compliance and case preparation
- Italian residency registration (AIRE cancellation and Anagrafe enrolment)
- Centre of vital interests documentation: family, business, social ties
- Response to residency challenges by Italian, UK or US tax authorities
- Annual review of residency position as circumstances evolve
Jurisdiction Comparison
Which Regime Fits You?
Italy — Flat Tax
- ✓ €100K flat tax on all foreign income
- ✓ Up to 15 years duration
- ✓ No wealth or inheritance tax on foreign assets
- ✓ Lifestyle, culture, EU access
- − Italian-source income taxed normally
Best for: HNW investors, retirees, families
United Kingdom — FIG
- ✓ 4-year FIG exemption on foreign income
- ✓ World-class financial centre & banking
- ✓ Strong treaty network (100+ countries)
- − 2025 reform: shorter window than old Non-Dom
- − High UK income and CGT rates apply after 4 years
Best for: finance professionals, short-medium term
Florida, USA
- ✓ Zero state income tax
- ✓ No state inheritance or estate tax
- ✓ USD-denominated assets and lifestyle
- ✓ Strong asset protection via homestead
- − Federal US tax still applies (20%+ on cap gains)
Best for: US citizens, pre-immigration planning
Ready to plan your tax relocation?
Our specialists will analyse your residency history, income profile and objectives to identify the most efficient relocation strategy — and manage the entire process.
