“Inbound” workers regime

Maurizio Di Salvo, Partner, Lawyer and CPA, part of the Private Client Services team, critically analyzes the recent Ruling n. 407 of June 16th, 2021, regarding the possibility to access the favorable regime provided by art. 16 of the Legislative Decree n. 147 of September 14th, 2015 (“inbound” workers regime) for a non-resident family officer who intends to incorporate a newco, from which he would receive a salary for his administrator role.

The Italian Revenue Agency considers the described operation as abusive under art. 10 bis of Law n. 212/2000, broadening considerably (and dangerously) the scope of the anti-abusive provision and giving a very narrow interpretation of the “inbound” workers regime.