Personal Tax Relocation


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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.

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)
Flat Tax Italy
Art. 24-bis
EUR 100K Regime
Interpello
New Residents

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
Impatriates
50% Exemption
Lavoratori Impatriati
5-Year Regime

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
Non-Dom UK
FIG Relief
TRF Planning
UK IHT
2025 Reform

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
Florida Domicile
No State Tax
Pre-Immigration
Nexus Severance
PFIC Planning

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
Exit Tax Italy
Section 877A US
UK CGT Departure
Form 8854
Pre-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
SRT UK
AIRE
Day-Count
Substance Test
Annual Review

Which Regime Fits You?

IT

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

UK

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

FL

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.

Schedule a Confidential Consultation

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