Italy Tax Agency Clarifies Application of New Tax Relief Regime for Repatriated Workers

The Italian Revenue Agency Feb. 27 issued Letter No. 54/2026, clarifying the application of the new tax relief regime for repatriated workers. The taxpayer, an Italian citizen, was tax resident in Switzerland for work, then started working for a U.S. employer and had a Swiss employer of record (EoR), then moved to Italy and worked for another U.S. company and had an Italian EoR. The taxpayer inquired whether under the regime’s employer continuity requirement, the minimum period abroad would increase from the ordinary three tax periods. Upon review, the Tax Agency clarified that the EoRs belonging to the same group ...