We have outlined some of the main changes introduced by the 2026 Budget Law affecting businesses and professionals, particularly in relation to the new IRPEF rates (personal income tax rates), the reduction of deductions for high incomes, and incentives for welfare and performance bonuses.
In this article, we address the new regime for new residents, the tightening of rules on short-term rentals, the taxation of crypto-assets, and the revised scope of exempt participations.
1. NEW BALANCE IN THE REGIME FOR NEW RESIDENTS ↑
Among the most important changes in the 2026 Budget Law for international taxation and high-net-worth individuals (HNWI) is the revision of the regime for new residents, known as “res non dom”. The legislator has chosen to increase the revenue generated by this scheme, significantly raising the substitute tax required from those transferring their civil residence to Italy. From transfers made on or after 1 January 2026, the annual flat-rate amount rises from €200,000 to €300,000, while the extension of the regime to family members now entails an additional tax of €50,000 per person, doubled compared to previous rules.
This change forms part of broader legislative updates aimed at rebalancing the relationship between fiscal attractiveness and the sustainability of public finances. For HNWIs, the regime remains a relevant planning tool, but now requires a more thorough assessment of overall convenience, especially in the presence of complex financial assets and significant foreign income streams. In this context, specialised advisory support becomes essential to evaluate the actual impact of the new tax threshold.
2. FLAT-RATE REGIME AND EMPLOYMENT INCOME ↑
Another area of interest among the Budget Law’s new provisions relates to the rules for access to and retention of the flat-rate regime for sole traders and professionals. The threshold for employment or similar income that determines exclusion from the preferential regime remains set at €35,000, extending into 2026 the limit already temporarily established for 2025.
This is operationally significant because exceeding the threshold is assessed with reference to income received in the previous year. Therefore, for the application of the flat-rate regime in 2026, the income situation in 2025 must be considered. This regulatory continuity responds to the need to provide greater certainty for taxpayers operating in hybrid professional contexts, characterised by the coexistence of self-employed and employed income.
For small and medium-sized sole traders and highly specialised professionals, confirmation of the threshold reinforces the need for proactive monitoring of income flows, to avoid unintended exclusion from the applicable tax regime.
3. CRYPTOCURRENCIES, STABLECOINS, AND NEW TAXATION RULES ↑
Within the new provisions, particular attention should be given to the rules governing crypto-assets, with a specific focus on euro-denominated stablecoins. While confirming the standard 33% rate for most income derived from crypto-assets, the legislator introduces a more favourable treatment for electronic money tokens pegged to the euro, providing for a substitute tax of 26%. The reduced rate applies to capital gains and other income generated from holding, disposing of, or using stablecoins that meet stringent requirements regarding reserves and custodians, located within the European Union.
It is also significant that the law explicitly excludes tax relevance for mere conversions between euros and euro-denominated tokens, as well as for redemption at nominal value. This regulatory approach helps to provide greater certainty for institutional and sophisticated private investors, supporting a clear distinction between speculative instruments and those used for payment or value preservation.
4. TOBIN TAX, EXTRAORDINARY TRANSACTIONS, AND MANAGEMENT OF CAPITAL GAINS ↑
The 2026 Budget Law also affects financial and corporate taxation. In particular, the doubling of Tobin tax (financial transaction tax) rates results in an increased fiscal cost for transfers of financial instruments, both on regulated and unregulated markets, as well as for high-frequency transactions. The measure aims to strengthen the levy on financial transactions without changing the fixed tax applied to derivatives.
On extraordinary transactions, the preferential regime for the allocation of assets to shareholders and transformation into a simple partnership is reintroduced until 30 September 2026, with a substitute tax of 8% on capital gains, rising to 10.5% for shell companies. The possibility of adopting the cadastral value of properties is one of the most significant elements, especially in the context of asset reorganisation.
At the same time, the reopening of the preferential exclusion for properties owned by sole traders and the removal of the instalment payment option for capital gains realised from 2026 mark a structural change in the fiscal management of divestments. Immediate taxation of capital gains, except in the case of business transfers, requires even more careful planning of such transactions.
