Tax cluster
Forfettario 2026 - Double taxation - INPS and pensions - Impatriati - Partita IVA - Crypto taxes - Tax deductions
Contents
- What happened to the Russia–Italy agreement
- When you become a tax resident of Italy
- 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 taxes in Italy will have to be paid twice — and what does the suspension of the DTA mean for those receiving income from Russia?
The Double Taxation Agreement (DTA) between Russia and Italy has been suspended since August 2023 (Decree of the President of the Russian Federation No. 585 of 08.08.2023). Income from Russia may be taxed twice: in Russia at 13–15% (personal income tax — NDFL) and in Italy at rates from 23% to 43% (IRPEF) depending on the amount.
Taxes in Italy for Russian-speaking immigrants became critically important after the DTA suspension. We explain how double-taxation rules changed and what to do in 2026.
DTA suspended since August 2023
The convention to avoid double taxation between Russia and Italy has effectively stopped working (Decree of the President 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 withholding tax paid in one country to be credited against tax due in the other. That mechanism is not functioning now.
"Russia did not withdraw from the agreement — it suspended it. For Italy everything works 'by default' — as if the agreement is in force. When the Italians realize it hasn’t been working for a couple of years, they will send tax demands for additional payments."
Asymmetry of the situation
Russia suspended the agreement, but Italy formally does not acknowledge that — it considers the DTA still in effect. This creates legal uncertainty: Russia withholds tax as from a non-resident (without applying the DTA), while Italy may not credit that tax because it assumes the agreement applies and the credit mechanism doesn’t work as before.
When you become a tax resident of Italy
Is 183 days in 2026 enough to become a tax resident — or is it more complicated?
Under the current rules for 2026 a tax resident of Italy is someone who meets at least one of three conditions (art. 2 TUIR, as amended 2024):
Physical presence — 183 days
183 days or more during the calendar year (184 in a leap year).
Centre of vital interests
Family, children (especially if they go to school), permanent housing, main business in Italy. Example: children start school in March, and a parent arrives only in September — they may be recognised as a resident from the start of the school year.
Official registration (residenza)
Registration of residence for more than 183 days a year — regardless of the actual number of days spent in Italy.
"183 days and I’m free" — a dangerous simplification
Many think: "If I don’t spend 183 days — Italy doesn’t concern me." That’s not true. Centre of vital interests, housing, family, work — all are criteria. And if you have a residence permit (permesso di soggiorno) — you are already under the presumption of tax residency, and the burden of proof is on you.
"183 days is primarily about tax residency, not about immigration status such as a residence permit/long-term stay. At the EU level there is no single law — the 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 will not become a tax resident in the current year (you won’t reach 183 days). This gives you time to settle without tax obligations. If in 2026 you left in June — you are also not a resident. But the main thing is to de-register your residence when leaving.
"Given the facts, 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 frequent and most 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 pay an additional 23–43% on the Russian gross? Does the DTA actually work?"
Possible scenarios
| Scenario | Russia | Italy | Total |
|---|---|---|---|
| Worst: double tax | 13–15% NDFL | 23–43% IRPEF on the full amount | 36–58% |
| Medium: tax credit | 13–15% NDFL | Credit for the amount up to the Italian rate | 23–43% |
| Best: only Italy | 0% (non-resident of Russia) | 23–43% or forfettario 5% | 5–43% |
"Possible variants: 1) 13% + 26% fully; 2) 26% on the difference between income and paid 13%; 3) the desired option — pay the difference up to 26%. That’s if you can convince the tax office. The process is not automated."
20% withholding at source
With the DTA suspension: if you operate via a Russian sole proprietorship (IP) for a Russian client while living in Italy — the client is required to withhold 20% from your invoice amount and transfer it to the Russian budget. Previously this could be avoided under the DTA. Now — it cannot.
Optimal route: cease being a Russian tax resident
If you are no longer a Russian resident (spent less than 183 days in Russia) and moved client payments to an Italian Partita IVA — you pay tax only in Italy. Under the forfettario regime that is only 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 taxation — 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
- The Italian tax office sees 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 this is documented."
Working model: Italian P.IVA
- Open a Partita IVA under the forfettario regime — 5% tax for the first 5 years
- Move clients to pay via Italian invoices
- 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 through an Italian P.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 a tax resident of Italy — you are obliged to declare all foreign real estate annually in the RW section of the tax return. Even if you do not sell it and do not receive income.
Penalty for non-declaration
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 at the time of sale — you will have to explain why it was not declared in previous years.
Sale of property
"On sale of property: in Russia after 5 years of ownership or 3 years in the case of inheritance from close relatives you are exempt from NDFL. Italy recognises that. You present the transfer of the sale contract with an apostille and certification — and the money becomes completely legal."
Trap: non-resident of Russia = 30% NDFL
If you are already a non-resident of Russia (less than 183 days in Russia), when selling property in Russia the authorities may charge you 30% NDFL instead of 13%, even if you owned the property for more than 5 years. The community confirms: "Acquaintances sold, and despite the property being more than 5 years old, they wanted to take 30% as from non-residents."
How to transfer proceeds from a sale to Italy
Prepare: the sale contract with an apostille, a certified transfer, property ownership documents. The Italian bank will ask you to prove the source of funds. Cash — strongly discouraged (limit 5,000 EUR per operation, declaration at the border; it’s hard to find a bank that will accept it).
What must be declared
Which Russian assets and incomes need to be listed in the Italian tax return?
A tax resident of Italy is obliged to declare their worldwide income — everything, from any country.
-
✓All income from any country
Salary, freelance, business income — all is subject to Italian tax
-
✓Foreign bank accounts
If the balance exceeded 5,000 EUR during the year — mandatory
-
✓Foreign real estate
Annually, in the RW section of the Redditi PF return
-
✓Shares in foreign companies
LLCs, IPs, any shares in businesses abroad
-
✓Cryptocurrency assets
Mandatory declaration since 2023. Tax 0.2% of value + 26–33% on capital gains upon sale. More details in a separate article.
"If I become a resident of Italy in 2026, when do I need to file a tax return for having property and accounts in Russia?" — Answer: already for the first year of residency, in the relevant sections of the Redditi PF return (deadline — by 30 November of the following year).
Better to declare late than not at all
The “ravvedimento operoso” remediation system 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 office — and what does that mean?
Revolut with an Italian IBAN = full transparency
If you have Revolut with an IT IBAN — all transfers, especially regular ones, are automatically reported to the Italian tax office. Sooner or later you will receive the “letter of happiness” — a request to explain the origin of funds.
"A client worked remotely. Freelance. Moved to Italy in 2023. 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 a letter arrived from the tax office."
"That’s how the mechanism works: the bank requests the reasons and origin of incoming funds, receives an answer and compiles information for the tax office. Everything works automatically."
How the mechanism works
Regular receipts to the account
The bank sees regular transfers and flags them as potential income.
The bank requests documents
Revolut, N26, Italian banks — all ask “where did the money come from?” on certain patterns.
Data is sent to the Agenzia delle Entrate
The bank compiles a report for the tax office. This is an automatic process.
"Letter of happiness"
The tax office compares receipts with your tax return. If they don’t match — you get a request to explain.
Automatic Exchange of Information (CRS)
Will the Italian tax office 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 update their records with an Italian tax ID and Italian residence."
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 information at Russian banks. Exchange of data between the FNS and the Agenzia delle Entrate is limited due to the geopolitical situation. This can change — and then the full history of transactions will become visible.
"A friend — a German citizen — is disputing with her tax office. The German tax office relies on statements from her cards and accounts by geolocation of transactions. She personally did not provide those statements."
European tax authorities can analyse the geography of transactions to determine residency.
Practical strategies for 2026
How to minimise tax burden when moving from Russia to Italy in 2026?
Close the Russian IP, open a Partita IVA under the forfettario. Move clients to Italian invoices. Tax 5% for the first 5 years + INPS ~26%. Total ~25% of turnover — less than 13% NDFL + Italian IRPEF.
Arrive after July — you will not become a tax resident in the current year. This gives time to settle, open P.IVA, move 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. Can be extended another 5 years if you buy a home or a child is born. Requires higher education or professional experience in the field.
Foreign accounts, real estate, crypto — everything in the RW section of the return. Better to declare with a small penalty (ravvedimento) than receive a full fine after an audit in 3–5 years.
"I suspect you haven’t dealt with the Italian tax office, let alone the Guardia di Finanza. They know perfectly well all the schemes with 'debt repayment' and the like and know how to handle them."
Real cases from the community
Worked remotely, received ~30,000 EUR/year on Revolut. In 2025 Revolut began to clarify the purpose of payments. At year-end a letter arrived from the Agenzia delle Entrate. Now they must explain the origin of all receipts and pay additional taxes for all years.
Sold property in Russia (owned more than 5 years, tax-exempt). Transported cash in parts with declarations at the border. 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." Bank transfers + apostilled documents — the only sensible route.
"I tried for 3 years to avoid taxes by operating online from abroad. After 3 years everything came back through payments. When you open a business form in Italy, the state tracks physical presence of at least 6 months — and you cannot live here while paying taxes in another country. Verified."
Conclusions
The agreement has been suspended by Russia since 2023. In 2026 the situation has not 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% NDFL + Italian IRPEF. And no double taxation.
Property, accounts, crypto. The ravvedimento fine is small compared to the penalty after an audit (3–15% of the amount).
The “letter of happiness” is a question of time — not if but when. Pay taxes or be ready to explain.
You will not become a tax resident in the current year. Time to settle without tax obligations. But don’t forget to deregister your residence when leaving.
Frequently Asked Questions (FAQ)
Is the Russia–Italy DTA working in 2026?
Russia suspended the agreement in 2023. In practice this means a risk of double taxation.
Do I need to declare foreign accounts?
Yes, an Italian tax resident must declare all worldwide income and accounts over 5,000 EUR.
Can Russian NDFL be credited?
Theoretically yes, but the process is not automated. You need to prove it through a commercialista.
The information in this article is based on community experience and public sources. This is not legal advice. For your specific situation consult a licensed specialist.
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