-
Business consulting services
Our business consulting services can help you improve your operational performance and productivity, adding value throughout your growth life cycle.
-
Business process solutions
We can help you identify, understand and manage potential risks to safeguard your business and comply with regulatory requirements.
-
Business risk services
The relationship between a company and its auditor has changed. Organisations must understand and manage risk and seek an appropriate balance between risk and opportunities.
-
Cybersecurity
As organisations become increasingly dependent on digital technology, the opportunities for cyber criminals continue to grow.
-
Forensic and investigation services
At Grant Thornton, we have a wealth of knowledge in forensic services and can support you with issues such as dispute resolution, fraud and insurance claims.
-
Mergers and acquisitions
Globalisation and company growth ambitions are driving an increase in M&A activity worldwide. We work with entrepreneurial businesses in the mid-market to help them assess the true commercial potential of their planned acquisition and understand how the purchase might serve their longer- term strategic goals.
-
Recovery and reorganisation
Workable solutions to maximise your value and deliver sustainable recovery
-
Transactional advisory services
We can support you throughout the transaction process – helping achieve the best possible outcome at the point of the transaction and in the longer term.
-
Valuations
We provide a wide range of services to recovery and reorganisation professionals, companies and their stakeholders.

-
IFRS
The International Financial Reporting Standards (IFRS) are a set of global accounting standards developed by the International Accounting Standards Board (IASB) for the preparation of public company financial statements. At Grant Thornton, our IFRS advisers can help you navigate the complexity of financial reporting from IFRS 1 to IFRS 17 and IAS 1 to IAS 41.
-
Audit quality monitoring
Having a robust process of quality control is one of the most effective ways to guarantee we deliver high-quality services to our clients.
-
Global audit technology
We apply our global audit methodology through an integrated set of software tools known as the Voyager suite.

-
Corporate and business tax
Our trusted teams can prepare corporate tax files and ruling requests, support you with deferrals, accounting procedures and legitimate tax benefits.
-
Direct international tax
Our teams have in-depth knowledge of the relationship between domestic and international tax laws.
-
Global mobility services
Through our global organisation of member firms, we support both companies and individuals, providing insightful solutions to minimise the tax burden for both parties.
-
Indirect international tax
Using our finely tuned local knowledge, teams from our global organisation of member firms help you understand and comply with often complex and time-consuming regulations.
-
Transfer pricing
The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators and the public

-
Outsourcing Changes to the Outsourcing legislation, specifically when offshoringSignificant changes to the dynamic of the financial services sector in recent years have shifted the paradigms in how we work. The increased digitisation of the workforce, changes in business models, globalisation, and remote working capabilities have led to a new approach to the delivery of services.
-
Asset management Inflation and tax planningThe recent onset of rapid inflation is an unwelcome development that is having a widespread impact on US businesses and tax planning.
Individuals becoming a tax resident of Italy can opt for the Special Tax Regime (STR) for High-Net-Worth Individuals (HNWI) only if, during the ten years before their relocation, they did not qualify as tax residents of Italy for at least nine years.
In a nutshell, this grants a flat taxation - amounting to 100,000 euro (per year) - on income from foreign (non-Italian) sources, regardless of their amount and/or nature. The only foreseen exception to this general rule is for capital gains realized during the first five years of application of the STR and arising from the sale of qualified shareholdings. Those gains, even though deriving from foreign entities, are subject to ordinary Italian taxation at 26% (a rate that can be reduced to 16% under certain circumstances).
In addition, the qualification under the STR provides an opportunity to avoid the following taxes, and tax filing obligations, on income subject to the flat tax:
- filing of the declaration of investments held abroad (the so-called 'RW form')
- wealth tax on investment held abroad, saving 0.2% per year on the value of financial investment and 0.76% per year on the original cost of real estate properties held abroad
- inheritance and donation tax.
Under the STR, any Italian-sourced income is subject to ordinary taxation.
The regime can be applied for fifteen consecutive years from the first year of tax residency, and the same benefit can be extended to family members whose foreign income is subject to an annual flat tax of 25,000 euro.

Italy updates special tax regime for HNWIs and Inbound individuals
Convenience of the STR regime to test
It is important to bear in mind that an income is considered “from a foreign source” – and therefore falls within the scope of application of the 100k€ flat tax – if it is defined as such by the Italian tax law.
Even if the Italian tax law is substantially aligned with international principles, the country of source can be defined only after determining the nature of a given income; this factor, in turn, depends on the Italian tax law and practice, which may lead to unexpected results.
Depending on specific elements, carried interests under Italian law may be considered financial income or employment income. While financial income is usually considered produced in the country where it comes from (as this is generally the country where the investment is located), employment income is considered produced in the country where the related working activity is performed, no matter where the payment of such income comes from. The implications of this difference are easy to imagine if the carried interests at issue are paid from abroad to an individual working in Italy.
This is just one example which demonstrates how easy it is to face situations where the source of a given income can be different to the one initially imagined and, consequently, would impact how attractiven the STR would be when it comes to HNWIs and their individual specific case. Other common challenging cases are those related to director’s fees; income indirectly related to immovable properties located in Italy (for which a new provision has just come into force), etc.
In our example above, if the carried interests are considered employment income, the individual may find it more convenient to opt for the STR for inbound workers, providing an exemption from taxation on Italian sourced employment and self-employment income up to 90%.
Planning in advance
Once the nature and the country of source of an individual’s main income are clarified, the implications of the STR for HNWI are also clear. Another element, however, which must also be considered is timing.
In our experience, the first months of a new Italian tax year (from January to March) would be a good time to move to Italy. The central months of the year are probably the trickiest.
This is mainly due to the way the fiscal year is conceived under the Italian tax law. Generally, a fiscal year, which matches with the calendar year (Jan – Dec), cannot be split. As a result, when individuals move to Italy during the first quarter of a given year, they are likely to acquire tax residency for the entire year, starting from Jan 1. If they move later and, after their relocation, they travel abroad frequently, they may be unable to qualify as tax resident of Italy. This factor may have a strong impact over tax planning.
In addition, in determining when to move, it is advisable to take into account some further practical – but not less relevant – aspects, such as:
- receiving adequate advice about STR for HNWI and its actual application in each individual’s specific case
- (for non-EU citizens) defining the right approach to immigration and how its handled, as this may represent a significant obstacle if not managed properly from the beginning
- evaluating the opportunity to obtain an official ruling from the Italian Tax Authorities (ITA) about eligibility for STR for HNWI.
In relation to the last factor listed above, it is crucial to obtain an answer from the ITA when the individual is still in the position to define his/her tax residence.
Under Italian tax law, a special ruling request can be filed by individuals wanting to get certainty on their eligibility with the STR for HNWI. From the date of application, the ITA have 120 days to respond with their official answer. For example, by filing an application by the end of February, an individual should receive the ruling by the end of June, just in time to determine his/her own tax residence under Italian rules.
It is important to highlight, if the case is complex and/or the application does not include all the elements that the ITA need to make their decision, it may take much longer. As the ITA are entitled to ask for additional documentation to clarify the case (under such circumstances, the procedure is likely to take no less than additional 60 days).
Get in touch
Should you wish to discuss any of the insights raised in this article please contact, Lorenzo Carminati or Michele Lauriola for more guidance.