Taxes & Finances

Italian Tax Residency: The 183-Day Rule and Why It's Not That Simple

Spend more than 183 days in Italy and you're tax resident. Simple, right? Not quite. Italy looks at multiple factors,domicile, centre of interests, registration,and any one of them can make you tax resident even if you're not here half the year. This guide explains how Italian tax residency actually works, so you can plan properly instead of discovering your obligations after the fact.

The 183-Day Rule

You've probably heard the 183-day rule: spend more than half the year in Italy, become Italian tax resident. It sounds simple, and many people plan their time around it. The problem is that physical presence is only one of three tests,and you only need to meet one.

Important: Italian tax residency can be triggered even if you spend less than 183 days in Italy. The other tests,registered residency and domicile,operate independently.

The Three Tests

You are Italian tax resident if you meet any one of these tests for the majority of the tax year (more than 183 days):

1. Registered in the Anagrafe

If you're registered as a resident in an Italian comune's civil registry (anagrafe), you're considered tax resident,regardless of where you actually spend your time. Registration is an objective fact that the tax authority can easily verify.

2. Domiciled in Italy

If Italy is where your principal business and personal interests are centred,your "centre of vital interests",you may be domiciled in Italy. This is a factual assessment based on where your family lives, where your economic activities are, where your social connections are.

3. Physical Presence (183 Days)

If you're physically present in Italy for more than 183 days in a calendar year, you meet this test. Days don't need to be consecutive. Partial days count as full days.

Meeting any single test makes you tax resident. You don't need to meet all three. This is why people who carefully count their days can still become tax resident if they're registered at the comune or have their domicile in Italy.

Worldwide Income

Italian tax residents pay tax on their worldwide income. This means:

Income from Italian sources (obvious)
Income from sources outside Italy (less obvious)
Foreign pensions
Foreign rental income
Foreign investments and capital gains
Interest on foreign bank accounts

Non-residents, by contrast, pay Italian tax only on Italian-source income. This is why the determination of tax residency matters so much,it determines what income Italy can tax.

When Tax Residency Starts

Italian tax residency is assessed on a calendar-year basis (1 January to 31 December). If you meet any of the three tests for the majority of the year, you're tax resident for that entire year.

This means:

Moving to Italy in July and staying through December could make you tax resident for that year (if you establish domicile or register)
The 183-day physical presence test is counted within the calendar year
There's no pro-rating of tax residency,you're either resident for the whole year or not at all

Planning tip: If you're moving to Italy and want to avoid being tax resident for your first partial year, be careful about registering residency and establishing domicile before you've been in the country long enough for the 183-day test to apply. Consult a tax professional about timing.

Double Taxation

If you're tax resident in Italy but also have income from (or ties to) another country, double taxation treaties come into play. Italy has treaties with most developed countries that determine:

Which country has primary taxing rights on different types of income
How to credit taxes paid in one country against obligations in another
Tie-breaker rules when both countries claim you as resident

Key points:

Government pensions: Often taxed only in the source country
Private pensions: Often taxed in the residence country (Italy)
Real estate income: Typically taxed where the property is located
Employment income: Complex rules based on where work is performed

This is where professional advice is essential. The interactions between Italian tax law, your home country's laws, and the applicable treaty are specific to your situation.

Common Scenarios

"I'll only spend 180 days"

Counting days carefully only addresses one test. If you're registered at the comune or have your domicile in Italy, you may still be tax resident. Physical presence alone doesn't determine tax status.

"I have a house but I'm not registered"

Owning property doesn't automatically make you tax resident. But if your family lives there, your main bank accounts are Italian, and your social life is centred in Italy, you may have Italian domicile,even without registering.

"I work remotely for a foreign company"

If you're tax resident in Italy, your remote work income is Italian taxable income,even if your employer is foreign and pays you in a foreign currency. The source of the work doesn't change where you're taxed as a resident.

"I'm retired with a UK pension"

UK government pensions are typically taxed in the UK. UK private pensions may be taxed in Italy if you're Italian tax resident. Some retirees may qualify for Italy's flat-tax regime for new residents. Treaty rules and individual circumstances matter enormously.

The Bottom Line

Italian tax residency isn't as simple as counting days. Three independent tests can trigger it, and meeting any one makes you liable for Italian tax on worldwide income. Before moving,or while planning how much time to spend in Italy,get professional advice specific to your situation. The cost of good advice is far less than the cost of discovering you owe taxes you didn't expect.

Want help getting your finances set up properly?

Tax advisors and bank managers join the retreat to walk you through codice fiscale, bank accounts, and tax residency in person. No guesswork, no Google Translate.

Learn about the retreat

Or book a free call to discuss your situation.