this is a key condition. i repeat, those who were not resident tax payers in italy for the last two tax periods can only apply these reduced rates.
de ligt and llorente will benefit from the new rules, ronaldo and chiellini won't.
Ronaldo would have different tax rates
The 2017 Budget Law, approved by the Italian Parliament, provided for a privileged tax scheme for natural persons residing abroad who decide to transfer their residence to Italy.
The favorable scheme consists in the possibility of taxing all income from foreign sources by paying a flat-rate substitute tax equal to €100,000 for each tax period (a so-called flat tax) regardless of the amount of taxable foreign income. This tax must be paid by 30 June each year.
The types of foreign income that comes under the Italian flat tax scheme for “res non dom” subjects are the following:
• income from land and buildings located abroad;
• capital gains paid from foreign countries or by non-residents;
• employment income earned abroad;
• income from self-employment arising from activities carried out abroad on a continuous basis;
• business income deriving from activities carried out by permanent organisations abroad;
• capital gains achieved as a result of the sale for consideration of investments in resident companies;
• other income deriving from activities carried out abroad and from assets located abroad.
The only exception relates to capital gains deriving from the sale of shareholdings equal to or greater than 25% in Italian or foreign companies; these are taxed with a substitute tax equal to 26%.
Besides the exemption of all the income produced abroad, as listed above, the person transferring their residence to Italy and requesting the application of the flat tax enjoys additional tax savings:
• no obligation to pay the IVIE levy (a tax which the Italian residents usually pay on real estate property held abroad);
• no obligation to pay the IVAFE levy (a tax which Italian residents pay on foreign financial assets);
• no obligation to indicate in the Italian tax declaration all the assets owned abroad (the Italian tax return form provides a special section where Italian residents indicate which assets they own abroad, the so-called RW field, new residents are not obliged to compile it).The flat tax includes the taxation of all foreign income produced in any state of the world; if the taxpayer wants to exclude some State from this tax scheme, they can inform the Italian Revenue Agency of this intention at the moment in which he/she will request the application of the tax benefit scheme