By reply to request for clarification No. 190/2026, the Italian Revenue Agency addressed the special tax regime applicable to lecturers and researchers transferring their tax residence to Italy, providing clarifications on the conditions under which they may benefit from an extension of the period ordinarily provided for the application of the tax incentive.
Tax relief for lecturers and researchers
Art. 44, para. 1, of Decree-Law No. 78/2010, converted, with amendments, into Law No. 122/2010, provides that lecturers and researchers who have transferred their tax residence to Italy from 1 January 2020 onwards may benefit from a special tax regime under which only 10% of the remuneration received for teaching and research activities contributes to the determination of taxable employment or self-employment income, including for the purposes of the regional tax on productive activities (IRAP).
This preferential tax regime applies in the tax year in which the lecturer or researcher transfers their tax residence to Italy and for the following five tax years, provided that they:
– hold a university qualification or equivalent;
– have been habitually resident abroad;
– have carried out documented research or teaching activities abroad for at least two consecutive years at public or private research centres or universities;
– maintain their tax residence in Italy throughout the period covered by the tax relief.
Extension of the period covered by the tax relief
Lecturers and researchers who have already benefited from the preferential tax regime as a result of transferring their tax residence to Italy may extend its application for up to seven tax years following the transfer of tax residence (art. 44, para. 3-ter, of Decree-Law No. 78/2010, converted, with amendments, into Law No. 122/2010), where they:
– have a dependent minor child (including a child in pre-adoptive foster care);
and/or
– become the owners of at least one residential property in Italy following their transfer to the country or during the 12 months preceding that transfer. This extension is also granted where the residential property is purchased, including under joint ownership, by i) the spouse, ii) the cohabiting partner or iii) the children.
With specific reference to the above requirement concerning ownership of residential property, in the reply to request for clarification in question, the Revenue Agency specifies that the extension of the period during which the tax relief may be claimed is recognised provided that full ownership of the property – understood as a newly purchased property acquired in its entirety (100%) upon execution of the purchase deed – is acquired directly by the worker for consideration. This is because the ratio of the incentive requires ‘active conduct on the part of the taxpayer intending to establish their residence permanently within the territory of the State’.
Consequently, an extension of the period during which the special tax regime may be applied is not granted where, following the transfer of their tax residence to Italy, the lecturer or researcher establishes their habitual residence in a residential property in Italy acquired by way of gift.
This interpretation by the Revenue Agency, originally formulated with reference to the scope of application of the special tax regime for ‘inpatriates’ (Revenue Agency, circular message No. 33/2020), also applies to extensions of the special tax regime for lecturers and researchers, given the ‘substantial similarity of the relevant provisions’.
We remain available for any further clarification.