According to the ruling issued by the Revenue Agency Director, dated March 8, 2017, to gain access to the taxation ruled by the article 24 bis of TUIR, an option application has not needed, but it’s enough an option in the tax return.
This tax regime is an option for people who move to Italy if they were not already resident in Italy in the last 9 years.
This tax regime, already existing in other states such as the United Kingdom, provides for the payment, in Italy, of an annual substitute and flat tax of EUR 100,000 (EUR 25,000 more for each family member if he/she wishes) on foreign earnings; the income produced in Italy is subject to ordinary taxation.
The option, automatically renewed each year, can last up to 15 years. If you think the option is not convenient, you can opt out at any time (obviously before the expiry time of 15 years).
The option application, that lets you to be protected from possible notifications by the tax authorities, can be sent even before the occurrence of the requirements needed under the TUIR.
The ruling (i.e. flat tax application) can be useful, for example, to avoid that, a few years after the switch, the Revenue Agency claims that the person, who has taken up residence in Italy, in the last 9 years has had the center of his/her interests (emotional, personal and / or economic) so disregarding the option to flat tax for foreign income.
As for convenience it should be considered mainly that:
• income produced in Italy are taxed ordinarily so if the main income is the one produced in Italy convenience is "attenuated"
• according to the conventions against double taxation foreign income could be subject to taxation only in the foreign state. Opting in the flat tax regime, foreign taxes can not be deducted from the flat tax paid in Italy on foreign income; unless the foreign state (or some of the foreign states) is not excluded from ‘replacement’ imposition perimeter.
So, this tax regime, I repeat It’s already used in other states, is actually cheaper when:
• abroad income is (very) high
• Taxes paid abroad are very low (or they equal zero)