One of the most significant issues emerging in the application of the new inbound workers regime concerns the extended foreign tax residence requirement applicable where the transfer to Italy takes place in continuity with the work performed abroad.

The foreign residence period, ordinarily equal to three tax periods, may increase to six or seven tax periods where the individual returns to Italy to work for the same entity or for an entity belonging to the same group.

The Italian Revenue Agency’s guidance appears to consider transfers to secondary establishments relevant as well (Ruling No. 53/2025), while Ruling No. 41/2025 provides useful insights into the definition of a group, with reference to the control relationships set out in Article 2359 of the Italian Civil Code.

These are particularly sensitive issues for multinational groups, especially where foreign companies, permanent establishments or corporate structures with no exact equivalent under Italian law are involved.

The correct classification of the relationship between the entities involved may therefore have a direct impact on access to the regime and on the foreign residence period that must be demonstrated.

Companies and individuals planning a transfer to Italy in 2026 or 2027 should therefore review the corporate structure, employment relationship and tax residence history well in advance.

In cross-border cases, this analysis may make the difference between eligibility for the relief and a significantly longer foreign residence requirement.