Key takeaways
- The costliest relocation mistakes are made before you arrive, and most cannot be undone.
- Italy has no split year: you are resident for the whole year or not at all.
- The date of arrival decides when your regime starts and whether pre-move income becomes taxable in Italy.
- We compare the regimes you qualify for on your own numbers and give you a written roadmap.
- Where needed, an advance ruling confirms your position in writing before you move.
6–24months ahead: the ideal window
183days that decide residence
90days for a ruling reply
3follow-up calls included
Plan Your Tax Residency, Immigration and Timing Before Relocating
Most of the costly mistakes we see in cross-border relocations are not made in Italy. They are made before the client arrives. A capital gain realised one month too late, a pension restructured at the wrong moment, a residence triggered before the best regime was planned: these are irreversible decisions that shape your tax position for years.
Entry Strategy exists to prevent exactly that. We work with you in the months before your move, while every option is still open and every choice can still be timed correctly.
Good to know
Relocation is full of one-way doors
Once you have crossed the residence line, many of the best options are gone. A short piece of planning beforehand routinely saves many times its cost.
What Entry Strategy Is
Entry Strategy is our pre-relocation advisory service for individuals and families planning a move to Italy, ideally 6 to 24 months ahead, though it is just as valuable if you have only recently arrived.
Before you become an Italian tax resident, we give you a clear picture of what moving to Italy means for your money: which tax regime to aim for, what it will cost, how to set up if you will work for yourself, and the consequences of each decision. You leave with a written roadmap you can act on, and that your advisors abroad can coordinate with.
A good fit if you- Are a high-net-worth individual or family considering Italy
- Are a retiree weighing the 7% pensioners regime
- Are moving to work under the impatriati regime
- Run a business or freelance across borders
- Hold significant capital gains, real estate or pensions that need timing
Probably not if you- Have already been resident for several years with a settled regime (see our tax return service)
- Only need a payslip estimate for an Italian salary
Why Timing Is Everything: The 183-Day Rule
Italy has no formal split year. For any calendar year you are either an Italian tax resident for the whole year, or not at all. You are resident if, for the greater part of the year (more than 183 days), you are registered with the Anagrafe, have your domicile or habitual abode in Italy, or are physically present in the country. We explain the four tests that decide residence in a dedicated guide.
That single line drives most of the planning. Deciding which side of it to land on, and sequencing the sale of a business, the realisation of a capital gain or a pension drawdown around it, is the heart of Entry Strategy.
| Arrive in the first half of the year | Arrive in the second half |
|---|
| Residence for that year | Resident for the whole year | Usually not resident that year |
|---|
| Income earned abroad before arrival | Taxable in Italy, with a foreign tax credit (Art. 165 TUIR) | Not taxable in Italy |
|---|
| When your regime starts | From that year | Cleanly from 1 January of the following year |
|---|
General rule under Article 2 TUIR; a double tax treaty can change the outcome in specific cases.
Choosing the Right Regime Before You Are Locked In
Italy offers several favourable regimes, but they are not interchangeable and, for the same person, they generally cannot be combined. Part of Entry Strategy is establishing which one fits you, and in what order to act. We compare them on your actual numbers, so you get a recommendation backed by figures, not an opinion.
Watch out
Some combinations are closing
A household splitting the lump sum tax and the impatriati regime between spouses can do so only for transfers of residence before 2027. The date of the move becomes decisive.
Planning a move to Italy in the next 6 to 24 months?
Let us map the right regime and the right date before you commit.
How We Help
Entry Strategy brings together everything that has to be decided before the move, so that nothing is triggered in the wrong order.
What we cover
- Fiscal residency analysis: your current jurisdiction against Italy, and exactly when the switch occurs
- Regime eligibility and comparison: which regimes you qualify for, quantified side by side
- Pre-relocation tax planning: capital gains, exit taxes, asset and pension restructuring, trust arrangements
- Coordination with your advisors abroad: your home-country accountant and wealth manager, kept aligned
- A relocation timeline: milestones and deadlines in the right order
- The administrative map: codice fiscale, partita IVA, AIRE, residence registration and, where needed, the right visa
For the details of trust arrangements, estate structures and visas we work alongside our dedicated services, so the plan covers tax, family and immigration in one place.
Certainty Before You Commit: The Advance Ruling
For anything material, you do not have to move on hope. Where your situation is complex (trusts, shareholdings, an unusual pension), we can file an advance ruling (interpello) with the Italian Revenue Agency before you transfer your residence, so your eligibility and treatment are confirmed in writing.
The Agency generally replies within 90 days; if it asks for further documents, a further 60 days run from when they are provided. It is the difference between planning on certainty and planning on assumption.
Certainty in writing
A ruling before the move
Filed before you transfer residence, the ruling confirms your eligibility and how your trusts, shareholdings or pensions will be treated. Reply generally within 90 days.
How the Service Works
Entry Strategy follows a clear, structured path, from a review of your figures to support during the move itself.
Preliminary analysisBefore we speak, we review your income, capital gains exposure, real estate, pensions, business interests and family situation.
A 60 to 90 minute strategy callWe walk through your situation, identify the best regime and map the timing and the trade-offs.
A written final reportThe recommended regime with a quantitative comparison, a personalised timeline and checklist, and the administrative steps in order.
Follow-up during the moveUp to three follow-up consultations through the relocation phase, so the plan holds as circumstances evolve.
What is included
- Review
- Preliminary review of your assets and income
- Call
- Intake and strategy call, 60 to 90 minutes
- Report
- Written fiscal positioning report tailored to you
- Comparison
- Regime recommendation with figures
- Timeline
- Personalised relocation timeline and checklist
- Follow-up
- Up to three consultations during the move
Once you have moved, we can follow you through the first Italian tax return, where the regime is formally elected.
Why Work with Us
Avv. Marco Mesina, a member of the Milan Bar (Ordine degli Avvocati di Milano) and formerly of Deloitte and Withers, has guided individuals, families and entrepreneurs through the move to Italy, coordinating tax, residence and, where needed, immigration and estate planning in a single strategy. Entry Strategy is where that experience is worth the most: the decisions taken before you arrive are the ones you cannot take back.
The best tax planning for Italy happens before the first night you spend here as a resident.
Avv. Marco Mesina, Founder of Move to Dolce Vita
Frequently Asked Questions
How early should I start planning my relocation?
Ideally 6 to 24 months before the move, and at least 12 months if you hold significant gains, pensions or trusts. Some optimisations need time to be set up under both home-country and Italian rules. Even a recent arrival benefits: some choices are still open in the first months.
Do you coordinate with my existing tax advisor abroad?
Yes. Entry Strategy is designed to sit alongside your home-country accountant and wealth manager, not replace them. We give them a clear Italian roadmap to align with.
What if I decide not to relocate after the analysis?
That is a perfectly good outcome. The point of the service is a clear, quantified picture before you commit, including the option of not moving, or moving later. You keep the report either way.
Can you confirm my regime with the tax authorities in advance?
In many cases, yes, through an advance ruling (interpello) filed before you move. It confirms your eligibility and treatment in writing, which is especially valuable for complex assets.
Does the date I arrive really matter?
Yes. Italy has no split year: arriving in the first half usually makes you resident for the whole year, while arriving in the second half usually starts your residence, and your regime, from the following 1 January.
Avv. Marco Mesina
Founder, Move to Dolce Vita · Avvocato, Milan Bar (Ordine degli Avvocati di Milano)
Marco is an Italian tax lawyer who advises individuals and families relocating to Italy on tax regimes, residency, citizenship, real estate and succession planning. Before founding Move to Dolce Vita he worked at Watson Farley & Williams, Withers and Deloitte in Milan.
- Milan Bar
- Citywealth Top 50 Italian Advisors 2025 & 2026
- Profiled by Forbes (2024)
- English · Italian · Spanish
About MarcoLinkedIn
Ready to plan your move to Italy?
We can help you with:
- Tax residency and the timing of your move
- Special regimes: €300,000 flat tax, 7% pensioners, impatriati
- Foreign assets, IVIE, IVAFE and RW reporting
- Double taxation and your home country
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Legal basis and review
- Article 2 TUIR (Presidential Decree 917/1986), as amended by Legislative Decree 209/2023: tax residence of individuals
- Article 165 TUIR: credit for taxes paid abroad
- Article 11 of Law 212/2000 and Legislative Decree 156/2015: advance rulings (interpello)
- Articles 24-bis and 24-ter TUIR; Article 5 of Legislative Decree 209/2023; Article 44 of Decree-Law 78/2010; Law 190/2014 (forfettario)
- Reviewed by Avv. Marco Mesina. Figures stated as at 2026.
