Italy's Tax Treaties: Who Taxes Your Income and How to Claim Relief

Last reviewed: November 2026 · Reviewed by Stéphane Gombauld, tax expert, technologist and digital nomad

You live in Italy with foreign clients, an employer or investments abroad, or you left Italy and still earn Italian income. Two countries may want the same euro. This page explains Italy's treaty network in 2026, the withholding rates, how to claim relief, and where to go next for every other Italian tax question.

Italy international tax treaties in 2026: the key figures

Is this guide for you?

Read on if you…

• are Italian tax resident with foreign salary, freelance clients, dividends or a pension;
• split your year between Italy and another country and could be resident in both;
• are non-resident and receive Italian dividends, rent, fees or a pension.

Probably not your case if you…

• earn only Italian income from Italian payers and never leave: start with the tax landscape overview of Italy;
• only want the residence tests themselves: see tax residency in Italy.

How does the Italian tax system treat cross-border income?

Italy taxes residents on worldwide income and non-residents only on Italian-source income. You are resident if, for more than 183 days of the year, you are present, have your habitual residence or have your domicile (your main personal and family ties) in Italy. There is no split year. Treaties sit on top of these domestic rules and can only reduce Italian tax, never increase it.

A double tax treaty (DTT) is an agreement between two countries that splits the right to tax each type of income. Italy's treaties follow the OECD Model, so four mechanisms come up again and again:

1. Tie-breaker. If both countries call you resident, the treaty picks one: permanent home first, then centre of vital interests (where your life is: family, home, business), then habitual abode, then nationality.
2. Allocation. Salary is taxed where the work is done, unless you stay under 183 days and a foreign employer pays you. Business profits are taxed only where you have a permanent establishment, a fixed place of business.
3. Reduced withholding on dividends, interest and royalties.
4. Relief for the tax still paid twice, through a credit in Italy.

Which countries have a tax treaty with Italy?

Coverage in 2026 includes:

• All EU and EEA states, plus the UK and Switzerland. The Italy–Switzerland frontier workers agreement has applied since 2024.
• The Americas: the United States, Canada, Mexico, Brazil, Argentina, Chile and others.
• Asia and the Middle East: China, Hong Kong, India, Japan, South Korea, Singapore, Israel, Turkey, the UAE, Qatar, Saudi Arabia.
• Popular nomad bases: Portugal, Spain, Malta, Cyprus, Georgia, Thailand, Malaysia, Vietnam.

Notable gaps: Monaco, the Bahamas, Bermuda and the Cayman Islands have no income tax treaty with Italy. If you move to a jurisdiction on Italy's tax-haven list, you are presumed to remain Italian resident unless you prove otherwise. That rule is explained in ceasing your tax residency in Italy.

Withholding rates under common treaties

Inside the EU, directives often beat the treaty: payments between associated EU companies can be free of withholding.

How do you claim treaty relief?

As an Italian resident earning abroad

1. Confirm your Italian residence and, if another country also claims you, run the tie-breaker. Keep proof: lease, family location, day counts.
2. Request a certificato di residenza fiscale from the Agenzia delle Entrate. You can apply online and receive it electronically.
3. Give it to the foreign employer, client, broker or pension fund so they apply the treaty rate at source.
4. Declare the foreign income in your Redditi PF return.
5. Claim the foreign tax credit. It covers only foreign tax that is final, and only up to the Italian tax on that income. Excess foreign tax is lost.

Dividends and interest kept abroad also go in the RW section of your return, where you pay IVAFE or IVIE (Italy's wealth taxes on foreign assets). See specific taxes in Italy and, for crypto, cryptocurrency taxes in Italy.

As a non-resident earning in Italy

Give the Italian payer the treaty form published by the Agenzia delle Entrate, stamped by your home tax office. The payer then withholds the treaty rate. If 26% was already withheld, file a refund claim within 48 months of the payment. Individuals can alternatively claim back up to 11/26 of dividend withholding by proving the dividend was taxed at home.

Social security is separate. Treaties do not cover contributions. Inside the EU, Regulation 883/2004 decides where you pay, proven by an A1 certificate. Italy also has bilateral agreements with the US, Canada, Australia, Brazil, Argentina and others.

What anti-abuse rules apply?

Italy denies treaty benefits to artificial arrangements under its general anti-abuse rule and the beneficial owner test in its treaties. Controlled foreign company rules tax a low-taxed foreign company you control on a current basis. A foreign company effectively managed from Italy is Italian resident since the 2024 reform. Founders should read corporate income taxes in Italy.

Moving in, moving out and running a business

• Newcomers can combine treaty protection with the impatriate regime or the flat tax on foreign income: see tax incentives for expats and digital nomads in Italy.
• Leavers should time the move: a treaty can split the year for treaty purposes, but Italian residence is decided for the whole year.

Italy tax guides

Every Italian guide we publish, in one place:

• Tax landscape overview of Italy – the whole system on one page.
• Tax residency in Italy – the four residence tests and what they mean for you.
• Obtaining your tax residency in Italy – the move-in plan, step by step.
• Ceasing your tax residency in Italy – AIRE, dates and the tax-haven presumption.
• Tax incentives for expats and digital nomads in Italy – impatriate regime, flat tax, 7% pensioners regime.
• Personal tax deductions and benefits in Italy – what lowers your IRPEF bill.
• Capital gains tax in Italy – the 26% rate on shares, funds and property.
• Cryptocurrency taxes in Italy – gains, reporting and the wealth tax on crypto.
• Specific taxes in Italy – VAT, IVAFE, IVIE and other levies.
• Legal forms of business in Italy – SRL, partnerships and freelancing compared.
• Corporate income taxes in Italy – IRES, IRAP and dividends.
• Business expenses in Italy – what you can deduct, and the caps.
• Tax fraud regulations of Italy – penalties and how to stay compliant.

Common mistakes (and what they cost)

• Relying on "183 days" alone → Italian residence can follow your family or registered address, and the treaty looks at your permanent home first.
• Not giving your foreign broker or employer a residence certificate → full foreign withholding, and the excess over Italian tax is lost.
• Claiming the foreign credit late → the credit must be claimed in the return for the year the income is taxed; miss it and you pay twice.
• Forgetting the RW section on foreign accounts → penalties of 3% to 15% of undeclared foreign assets, on top of any unpaid tax.

Frequently asked questions

How many tax treaties does Italy have?

Italy has close to 100 comprehensive income tax treaties in force, covering all EU and EEA states, the UK, Switzerland, the United States, Canada, most of Latin America and Asia, and the Gulf states. The Department of Finance publishes the full list and texts. Monaco and most Caribbean financial centres have no treaty.

Does Italy have a tax treaty with the United States?

Yes. The Italy–US treaty signed in 1999 has been in force since 2009. It caps dividend withholding at 5% or 15%, interest at 10% and royalties at 0% to 8%. US citizens living in Italy are still taxed by the US on citizenship, so they rely on credits in both countries to avoid double tax.

How does Italy avoid double taxation on foreign income?

Italy uses the foreign tax credit of article 165 TUIR. You declare the foreign income, and the foreign tax that is final and paid is credited against the Italian tax on that income, up to the Italian amount. Some treaties exempt certain income instead, such as public-sector pensions taxed only by the paying state.

What is the withholding tax on dividends paid from Italy to non-residents?

The domestic rate is 26%. Companies resident in the EU or EEA pay 1.2%, and EU parents holding at least 10% for a year are exempt. Individuals and other companies can claim the treaty rate, often 15%, by filing the treaty form, or recover up to 11/26 of the withholding by proving the dividend was taxed at home.

How do I get an Italian tax residence certificate?

Request a certificato di residenza fiscale from the Agenzia delle Entrate, online through its services or at a local office. You need your Italian tax code and, usually, the purpose and the treaty country. Certificates for treaty purposes are generally issued free of stamp duty and accepted by most foreign tax authorities.

Do treaties cover social security contributions?

No. Income tax treaties cover only taxes on income. Within the EU, EEA and Switzerland, Regulation 883/2004 decides where contributions are due, proven by an A1 certificate. Italy also has bilateral social security agreements with several non-EU countries. Without one, you may owe contributions in two countries.

Related guides

• Tax landscape overview of Italy
• Tax residency in Italy: the four tests
• Capital gains tax in Italy
• Corporate income taxes in Italy
• International tax treaties of Portugal
• Tax treaties of Spain
• All country tax guides

Sources

• Ministry of Economy and Finance, Department of Finance – double tax treaties
• Agenzia delle Entrate – Italian Revenue Agency
• Normattiva – TUIR, Presidential Decree 917/1986 (articles 2, 73, 165)
• OECD – Tax treaties and the Multilateral Instrument
• European Commission – Taxation and Customs Union

This guide is general information, not personalised tax advice. See how we research and review.