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Tax Advantages for Researchers and Lecturers Who Comes to Italy
Italian Parliament has recently improved the special tax advantages provided by article 44 of the decree law No 78 of 31 May 2010, converted into Law No 122 of 30 July 2010, in favor of researchers and lecturers. In order to encourage the scientific and technological development in Italy, the particular tax relief concerning IRPEF (Italian personal income tax) and IRAP (Italian regional income tax) will be granted also after the fiscal year 2017.
The tax relief concerns compensation of employees or self-employment income regarding research activities performed in Italy and provides a tax exemption, for IRPEF purposes, of 90% of the research and lecture income. In addition, the same activities are not taxable for IRAP purposes. However, the tax relief has a temporary nature because it applies for a maximum of 4 fiscal years: the fiscal year in which the researcher/lecturer becomes resident in Italy and the following 3 tax periods, if the beneficiary maintains the residence in Italy.
This decree is called in Italian “Rientro dei Cervelli” (return of brains) but the real purpose of this provision is to attract any “brain” to improve the research activities in Italy. The provision, therefore, applies not only to Italian researchers or lecturers who decide to move back to Italy but, also, to foreign people who would like to come to Italy for the first time.
In order to benefit from the above mentioned tax relief, the researchers or lecturers should meet the following conditions:
- being in possession of a university degree;
- being resident abroad permanently and not just occasionally;
- certifying documented research or teaching activity abroad at Universities or in public/private research entities for at least two years;
- moving and keeping the residence in Italy during the fiscal years for which they would like to benefit from the tax relief (with the maximum of 4 fiscal years).
No specific reliefs are provided for VAT and social security contribution purposes with reference to the above mentioned subjects.
Maurizio Bottoni is the senior partner of Interconsulting. As a consultant in one of the Big Four he has developed a deep knowledge of the Italian and International tax law, through the involvement in operations and reorganization of multinationals. Extraordinary transactions and international issues are his daily business.