Tax cluster
Forfettario 2026 - Double taxation - INPS and pension - Impatriati - Partita IVA - Crypto taxes - Tax deductions
Contents
- What happened to the Russia–Italy agreement
- When you become an Italian tax resident
- Salary from Russia: how much to pay
- Freelance and sole proprietorship: Russian clients
- Property in Russia
- What must be declared
- Banks, Revolut and the "letter of happiness"
- Automatic exchange of information (CRS)
- Practical strategies
- Real cases from the community
- Conclusions
What happened to the Russia–Italy agreement in 2026
Is it true that in 2026 you’ll have to pay taxes in Italy twice — and what does the suspension of the DTA mean for those receiving income from Russia?
Taxes in Italy for Russian-speaking immigrants became a critical topic after the suspension of the DTA. Let’s break down how the rules on double taxation have changed and what to do in 2026.
The DTA has been suspended since August 2023
The agreement for the avoidance of double taxation between Russia and Italy has effectively stopped working (Presidential Decree of the Russian Federation No. 585 of 08.08.2023). Russia suspended the DTA with most "unfriendly" countries, including Italy.
What this means in practice: if you live in Italy and receive income from Russia, you risk paying tax twice — in Russia and in Italy. Previously the DTA allowed tax paid in one country to be credited against tax due in the other. That mechanism is not working now.
"Russia didn’t withdraw from the agreement — it suspended it. For Italy everything works 'by default' — as if the agreement is still in force. When the Italians realize it hasn’t been effective for a couple of years, they will send tax assessments demanding additional payments."
Asymmetry of the situation
Russia suspended the agreement, but Italy formally does not acknowledge that suspension — it considers the DTA to still be in force. This creates legal uncertainty: Russia withholds tax as for a non-resident (without applying the DTA), while Italy may not grant credit in the same way because it treats the agreement as active and the credit mechanism no longer works as before.
When you become an Italian tax resident
Is 183 days in 2026 enough to become a tax resident — or is it more complicated?
Under current 2026 rules, a person is considered an Italian tax resident if they meet at least one of three conditions (art. 2 TUIR, 2024 edition):
Physical presence - 183 days
183 days or more during the calendar year (184 in a leap year).
Center of vital interests
Family, children (especially if they start school), permanent housing, main business activities in Italy. Example: children start school in March but the parent arrived only in September — the parent may be considered resident from the start of the school year.
Official registration (residenza)
Registration at the place of residence for more than 183 days a year — regardless of the actual number of days physically spent in Italy.
"183 days and I'm free" — a dangerous simplification
Many think: "If I don’t stay 183 days — Italy won’t touch me." That’s not true. Center of vital interests, housing, family, work — these are also criteria. And if you have a residence permit, you are already under a presumption of tax residency, and the burden of proof is on you.
"183 days is primarily about tax residency, not about residency/permits as an immigration status. There is no single EU law — criteria are set out in each country's national law."
Strategic advice: move after July
If you arrive in Italy in the second half of the year — you won’t become a tax resident in the current year (you won’t reach 183 days). This gives you time to settle without tax obligations. If you left Italy in June in 2026 — you’re also not a resident. But the main thing is to deregister your residence when leaving.
"Based on the inputs, you will not be a tax resident in 2025 because you only arrived in September. In 2026 — because you left in June. And the main thing is to cancel your registration when leaving."
Salary from Russia: how much to pay in 2026
If I work remotely for a Russian company from Italy in 2026 — am I obliged to pay Italian taxes on top of the Russian 13%?
This is the most common and painful question in 2026. Short answer: yes, most likely you are obliged.
"I work for a Russian company that withholds 13–15% from my salary monthly. When I’m in Italy — do I have to additionally pay 23–43% on top of the Russian gross? Does the double taxation agreement actually work?"
Possible scenarios
| Scenario | Russia | Italy | Total |
|---|---|---|---|
| Worst: double tax | 13–15% PIT | 23–43% IRPEF on the full amount | 36–58% |
| Medium: credit | 13–15% PIT | Difference up to the Italian rate | 23–43% |
| Best: only Italy | 0% (non-resident of Russia) | 23–43% or forfettario 5% | 5–43% |
"Options are possible: 1) 13% + 26% fully; 2) 26% on the difference between income and the 13% paid; 3) the desirable option — pay the difference up to 26%. This is if you can convince the tax office. The process is not automated."
20% withholding at source
With the suspension of the DTA: if you operate through a Russian sole proprietor (IP) for a Russian client while living in Italy — the client is obliged to withhold 20% from your invoice amount and transfer it to the Russian budget. Previously this could be avoided under the DTA. Now — it can’t.
Optimal path: stop being a Russian tax resident
If you are no longer a Russian resident (spent less than 183 days in Russia) and switch clients to payment via an Italian Partita IVA — you pay tax only in Italy. Under forfettario this is just 5% for the first 5 years. But the transition must be planned in advance.
Freelance and sole proprietorship: Russian clients
Can I continue working through a Russian sole proprietorship (IP) while living in Italy? What are the risks?
- Russian IP + Italian residency = double taxes — income is taxed in both Russia and Italy
- The client must withhold 20% when paying a non-resident (after the DTA suspension)
- SWIFT transfers from Russia — limited and expensive, many banks refuse
- Italian tax authorities see transfers — Revolut with an Italian IBAN transmits all data
"People try to live as an employee, pay as a contractor and register as a tourist. That doesn’t work. Only a clear link works: who you are, how you earn, where you live, and how that is documented."
Working model: Italian Partita IVA
- Open a Partita IVA under the forfettario regime — 5% tax for the first 5 years
- Move clients to payment via an Italian invoice
- Close or freeze the Russian IP
- Income taxed only in Italy
For foreign clients
Under forfettario you do not charge VAT (IVA) to clients — they pay the net amount. For foreign clients this is convenient: the invoice is the same amount as before, but issued via an Italian Partita IVA.
Property in Russia
Do I need to declare a Russian apartment in Italy? And if I sell it — what taxes apply?
Declaration
If you are an Italian tax resident — you are required to declare all foreign real estate annually in section RW of the tax return. Even if you do not sell it or receive income.
Penalty for non-declaration
The basic penalty for undeclared foreign assets: from 3% to 15% of the value (art. 4.5 D.L. 167/1990). If the tax office discovers the property upon sale — you will have to explain why it was not declared in previous years.
Sale of property
"When selling property: in Russia, after 5 years of ownership or 3 years inherited from close relatives you are exempt from PIT. Italy recognizes this. Present the sale agreement transfer to the bank with an apostille and certification — and the money becomes completely legal."
Trap: non-resident of Russia = 30% PIT
If you are already a non-resident of Russia (less than 183 days in Russia), when selling property Russia may withhold 30% PIT instead of 13%, even if you owned the property for more than 5 years. The community confirms: "Acquaintances sold property and, despite ownership over 5 years, they were asked to pay 30% as non-residents."
How to transfer sale proceeds to Italy
Prepare: the sale contract with an apostille, certified transfer, property ownership documents. An Italian bank will ask to confirm the origin of funds. Cash is highly discouraged (limit 5,000 EUR per operation, customs declaration at the border, hard to find a bank that will accept it).
What must be declared
Which Russian assets and incomes must be reported in the Italian tax return?
An Italian tax resident must declare worldwide income — everything, from any country.
-
✓All income from any country
Salary, freelance, business income — all is taxable in Italy
-
✓Foreign bank accounts
If the balance exceeded 5,000 EUR during the year — mandatory to report
-
✓Foreign real estate
Annually, in section RW of the Redditi PF return
-
✓Shares in foreign companies
LLCs, sole proprietorships, any stakes in businesses abroad
-
✓Cryptocurrency assets
Mandatory declaration since 2023. A 0.2% tax on value + 26–33% on gains at sale. More details in a separate article.
"If I become a resident of Italy in 2026, when must I file a tax return regarding property and accounts in Russia?" — Answer: already for the first year of residency, in the appropriate sections of the Redditi PF return (filing deadline — by November 30 of the following year).
Better to declare late than not at all
The ‘repentance’ system (ravvedimento operoso) allows correcting mistakes with a reduced penalty. The sooner you fix it — the smaller the fine (1/8 of the base in the first year, 1/6 after 2+ years). This is much cheaper than waiting for an audit.
Banks, Revolut and the “letter of happiness”
Is it true that Revolut passes data to the Italian tax authority — and what are the consequences?
Revolut with an Italian IBAN = full transparency
If you have Revolut with an IT IBAN — all transfers, especially regular ones, are automatically transmitted to the Italian tax authority. Sooner or later you will receive the "letter of happiness" — a request to explain the origin of funds.
"A client worked remotely as a freelancer. He left for Italy in 2023. He received regular payments to a Revolut account. Amounts were small — about 30,000 EUR/year. In 2025 Revolut repeatedly asked for clarification of payment purposes. At the end of 2025 he received a letter from the tax authority."
"This is how the mechanism works: the bank requests the basis and origin of incoming funds, receives an answer and forms information for the tax authority. Everything works automatically."
How the mechanism works
Regular incoming transfers
The bank sees regular transfers and flags them as potential income.
The bank requests documents
Revolut, N26, Italian banks — all ask "where are the funds from?" when they observe certain patterns.
Data goes to the Agenzia delle Entrate
The bank generates a report for the tax authority. This is an automatic process.
"Letter of happiness"
The tax authority compares incoming transfers with your tax return. If there is a mismatch — they request an explanation.
Automatic exchange of information (CRS)
Will the Italian tax authority find out about my accounts in Russian banks?
CRS (Common Reporting Standard) is the international system for automatic exchange of tax information between countries. But the situation with Russia is special.
"For Italy to 'directly' receive your data — your bank must report you as an Italian resident. It’s unlikely many people go to Sber/Tinkoff and declare their Italian tax number and Italian residence there."
In practice (for now)
Russian banks formally participate in CRS through the Federal Tax Service (FNS). But in practice: few people update their tax residency data in Russian banks. Data exchange between the FNS and the Agenzia delle Entrate is limited due to the geopolitical situation. However, this can change — and then the full transaction history could become visible.
"A friend who is a German citizen is in a dispute with the tax office. The German tax authority relied on card and account statements and the geography of transactions. She didn’t personally provide those statements."
European tax authorities can analyze the geography of transactions to determine residence.
Practical strategies for 2026
How to minimize tax burden when moving from Russia to Italy in 2026?
Close the Russian IP, open a Partita IVA under the forfettario regime. Move clients to Italian invoices. Tax 5% for the first 5 years + INPS ~26%. Total ~25% of turnover — less than 13% PIT + Italian IRPEF.
Arrive after July — you will not become a tax resident in the current year. This gives you time to settle, open a P.IVA, transfer clients — without double taxation for the first year.
For employed workers with high income: only 50% of income is taxed in Italy for 5 years. It can be extended another 5 years if you buy property or have a child. Requires a university degree or relevant professional experience.
Foreign accounts, property, crypto — all in section RW of the return. Better to declare with a small penalty (ravvedimento) than face a full penalty after an audit in 3–5 years.
"I suspect you haven’t dealt with the Italian tax authority, let alone the Guardia di Finanza. They know all the schemes with 'debt repayment' and so on and are perfectly capable of dealing with them."
Real cases from the community
Worked remotely, received ~30,000 EUR/year to Revolut. In 2025 Revolut started asking for clarification of payment purposes. At the end of the year a letter arrived from the Agenzia delle Entrate. Now they must explain the origin of all receipts and pay taxes for all years.
Sold property in Russia (ownership over 5 years, exemption from PIT). Transported cash in parts with customs declarations. Very hard to find a bank that accepts cash. Found one and explained the situation with documents. Conclusion: "If I were doing it now — I wouldn’t repeat that." Non-cash + apostille on documents is the only reasonable path.
"I tried for 3 years to avoid taxes by operating online from abroad. After 3 years everything came back around payments. When you register a business form in Italy, the state tracks physical presence of at least 6 months — and you can’t live here paying taxes to another country. Verified."
Conclusions
Since 2023 Russia has suspended the agreement. In 2026 the situation hasn’t changed. If you receive income from Russia and live in Italy — you risk paying tax twice.
Forfettario 5% + INPS = ~25% of turnover. This is less than 13% PIT + Italian IRPEF. And no double taxation.
Property, accounts, crypto. The ravvedimento penalty is peanuts compared to a penalty on audit (3–15% of the amount).
The "letter of happiness" is a matter of time — it’s not "if" but "when". Pay taxes or be ready to explain.
You won’t become a tax resident in the current year. Time to settle without tax obligations. But don’t forget to deregister your residency when leaving.
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