Exclusion of NASpI from the special regime for impatriate workers: clarification from the Revenue Agency

With ruling no. 228 of September 1, 2025, the Revenue Agency clarified the applicability of the special regime for impatriate workers, under Art. 16 of Legislative Decree 147/2015, to amounts received as NASpI. The case concerned a taxpayer who, after six years abroad, transferred residency to Italy in April 2022, returning from Ireland. From then until September 2023, he was employed under the favorable impatriate regime. Following termination, he received NASpI from October 2023 to August 2024, before relocating abroad again. He asked whether the unemployment benefit could be considered eligible income as it derived from a previous job and thus benefit from the impatriate regime reduction.

The special regime for impatriate workers

Legislative Decree 209/2023 introduced, effective 2024, a new favorable regime for workers transferring tax residency to Italy. However, for those who transferred residency by December 31, 2023 – as in this case – the previous regime under Art. 16 of Legislative Decree 147/2015 still applies. That regime provides that, under specific subjective and objective requirements, employment income, equivalent income, self-employment, and business income produced in Italy count toward taxable income at only 30% of their amount, starting from the transfer year and for four subsequent tax years.

The Agency also recalled its previous practice (Circulars no. 17/E of 2017 and no. 33/E of 2020), stressing that the measure aims to incentivize individuals transferring residence to Italy to work, granting more favorable taxation on earned income. In this sense, replacement income may also qualify, provided it is strictly linked to actual work performed in Italy.

NASpI classification

NASpI, under Legislative Decree 22/2015, is an income support benefit paid by INPS to employees who involuntarily lost their jobs. While fiscally classified as employment income under Art. 6 TUIR, it is not paid for work performed but due to job termination. Its function is temporary income support while seeking new employment, not remuneration for work.

The Revenue Agency’s position

Given this, the Agency concluded that NASpI received in 2024 is not eligible under Art. 16 of Legislative Decree 147/2015. Though fiscally treated as employment income, it does not meet the substantive requirement of being derived from work performed in Italy. Thus, such amounts must be taxed ordinarily, without the impatriate regime reduction.

In conclusion, this clarification reaffirms an important principle: the impatriate regime applies only to income arising from actual work activity in Italy, excluding support benefits received without active work.