Tax residence in Italy for Pakistani taxpayers

Since 2024 Italy treats you as resident if, for most of the calendar year, you are physically present there (part-days count), have your domicilio (main personal and family relationships) or residenza there, or are registered in the anagrafe. Pakistan counts its own tax year of 1 July – 30 June, and a Pakistani citizen can stay resident under s. 82(d) with fewer than 183 days. Where both countries claim you, Art. 4(2) of the 1984 Pakistan–Italy Convention decides.

Check your status: Pakistan and Italy

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, compared with the law of Italy and the tax treaty.

When Italy treats you as a tax resident

Since 2024 Italy treats you as resident if any one criterion is met for most of the year: physical presence (a part of a day counts as a full day), domicilio (main personal and family relationships in Italy), residenza (habitual abode), or registration in the anagrafe.

You were in Italy for 183 days or more (counting parts of days) — you are an Italian resident, including if you worked remotely from there.
Your main personal and family relationships are in Italy: that is domicilio, and since 2024 it makes you an Italian resident even without days of presence.
You are registered in the anagrafe — Italian residence is presumed. You can rebut the presumption only by showing that none of the criteria (presence, domicilio, residenza) is met.

When you are a nonresident

Fewer than 183 days, no family and no registration in Italy — you are not an Italian resident. Pay for work done in Italy is still taxable there.

Where the rules of Italy clash with Pakistani tax rules

Collision: 183 days in Italy while Pakistan also treats you as resident. Italy treats you as resident because you were present for most of the calendar year; Pakistan treats you as resident with 183 days in its tax year, as a government employee posted abroad (s. 82(c)) or, if you are a citizen, under s. 82(d). Art. 4(2) of the Pakistan–Italy Convention decides: a permanent home in only one country — that country; a home in both — the centre of vital interests; if that cannot be determined or you have no permanent home in either country — habitual abode; then nationality; then mutual agreement. Under s. 107 the treaty prevails over the Ordinance.
Collision: Pakistani citizen resident in both countries. Since tax year 2023, s. 82(d) of the Income Tax Ordinance treats a Pakistani citizen as resident in Pakistan if he or she was not present in any other country for more than 182 days in the Pakistani tax year, or is not a resident taxpayer of any other country. Italy can treat you as resident through domicilio or anagrafe registration without 183 days. If both apply, Art. 4(2) of the treaty decides; if the treaty makes you a resident of Italy, Pakistan may tax you only on Pakistan-source income as the treaty allows. Keep an Italian certificate of residence and a day count for both tax years.
Collision: family in Italy — resident without a single day there. Since 2024 Italy treats as resident anyone whose main personal and family relationships are in Italy, even without being there. Pakistan may treat you as resident at the same time. Under the treaty, with a permanent home in both countries the centre of vital interests is judged on personal and economic ties together; if it cannot be determined — habitual abode, then nationality. Before 2024 the Court of Cassation gave priority to economic interests and counted family only with other criteria; the new rules are not retroactive (Cass. 19843/2024).
Collision: registration in the anagrafe. Registration in the Italian population register for most of the year creates a presumption of Italian residence; Pakistani law does not look at it. The conflict is resolved by Art. 4(2) of the Convention — the Agenzia delle Entrate expressly accepts that treaty rules apply even where Italian residence follows only from anagrafe registration. If you have left Italy, deregister (or register with AIRE if you are an Italian citizen) so the presumption does not follow you.

What else to know

Different tax years: 1 July – 30 June and the calendar year. Pakistan counts days in its tax year (1 July – 30 June); Italy counts the calendar year and treats any part of a day in Italy as a full day. The same stay can therefore give different totals: for example, October to May can be more than 182 days in one Pakistani tax year but split between two Italian years. The treaty's 183-day employment test (Art. 15(2)) refers to «the fiscal year concerned»; check your days in the Italian calendar year as well as in the Pakistani tax year.
Working in Italy while resident in Pakistan. Pay for work physically done in Italy — including remote work — is Italian-source income. If you are resident in Pakistan under the treaty, Art. 15(2) keeps the pay taxable only in Pakistan when you were in Italy for no more than 183 days in the fiscal year concerned and the employer is not Italian-resident or the pay is not borne by an Italian permanent establishment (the FBR text joins the last two conditions with «either … or»; confirm the wording before relying on only one of them). Otherwise Italy taxes the pay for the Italian work days. In Pakistan, salary earned abroad is exempt if Italian tax on it was withheld and paid to the Italian tax authority (s. 102); otherwise Pakistan gives a credit (Art. 23(1), s. 103).
How double tax is relieved between Pakistan and Italy. If you are resident in Pakistan, Italian tax on income Italy may tax is deducted from Pakistani tax, up to the Pakistani tax on that income at your average rate (Art. 23(1)); under s. 103 the limit is computed separately for each head of income and unused credit is lost. If you are resident in Italy, Pakistan tax is credited up to the proportion of Italian tax attributable to the Pakistani income (Art. 23(2), art. 165 TUIR); there is no credit for income you chose to have taxed in Italy by final withholding. Tax holidays granted to promote economic development on business profits, dividends and interest count as tax paid up to 25% (Art. 23(3)).
Italy counts a part of a day as a full day. The days you arrive in and leave Italy count as days in Italy. The same travel days can also count as days of presence in Pakistan, so you can end up with a high day count in both countries. Keep boarding passes or passport stamps for both countries' tax years.
Italian flat tax for new residents (art. 24-bis TUIR). If you were not an Italian resident for at least nine of the ten previous tax years, you can opt to pay a fixed substitute tax on all foreign income: EUR 300,000 a year for people moving to Italy from the entry into force of Law 199/2025 (earlier movers keep the amount applicable when they moved), EUR 50,000 per family member, for up to 15 years. You can exclude income from specific countries — for example Pakistan — and have it taxed ordinarily with a credit for Pakistani tax. Pakistan continues to tax Pakistan-source income (s. 101) within the treaty limits.
Italian impatriate regime (art. 5 D.Lgs. 209/2023). Workers moving to Italy who were not Italian residents in the three previous tax years (six or seven if they worked for the same employer or group before), work mostly in Italy, meet high-qualification requirements and stay resident for five tax years pay Italian tax on only 50% of their employment or self-employment income (60% exempt with a minor child), within EUR 600,000 a year. From 2027 the regime is art. 225 of the new Testo unico. It applies only while you are an Italian resident; if Pakistan also treats you as resident, the treaty tie-breaker decides first.
Pakistani government posting to Italy. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c). Under Art. 19 of the treaty their government salary is taxable only in Pakistan; Italy may tax it only if the services are rendered in Italy by an Italian resident who is an Italian national or did not become resident in Italy solely to render the services — for example locally engaged Italian staff of a Pakistani mission.
Social security: no Pakistan–Italy agreement. Pakistan is not among the non-EU countries with which Italy has a bilateral social security agreement (Ministry of Labour list). Work in Italy is generally subject to Italian social security (INPS) under Italian rules, with no certificate of coverage based on Pakistani coverage. Social security contributions are outside the income tax treaty.
New Italian tax code from 2027. From 1 January 2027 the TUIR is replaced by a new code (D.Lgs. 117/2026). The residence rules are unchanged; other articles are renumbered (non-residents' income — art. 25; foreign tax credit — art. 185).

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Republic of Italy and the Islamic Republic of Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed 22 June 1984). The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

Terms you will come across in Italy

residenza fiscale: Italian tax residence under art. 2 TUIR — presence, domicilio, residenza or anagrafe registration for most of the year
domicilio: since 2024: the place of your main personal and family relationships
anagrafe: the municipal population register; registration creates a rebuttable presumption of residence
IRPEF: Italian personal income tax, plus regional and municipal surcharges
regime impatriati: the impatriate regime: 50% (or 60%) exemption of work income for qualifying newcomers
Agenzia delle Entrate: the Italian tax authority; it issues Italian certificates of residence

Questions

Which tax treaty applies between Pakistan and Italy?

The Convention signed on 22 June 1984, in force since 1992. The tie-breaker for individuals is Art. 4(2): permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement.

I work in Italy for a few months. Does Italy tax my salary?

If you are resident in Pakistan under the treaty, Art. 15(2) protects the salary from Italian tax only if you were in Italy no more than 183 days in the fiscal year concerned and the employer conditions are met. Otherwise Italy taxes the pay for Italian work days and Pakistan exempts it (s. 102) or credits the Italian tax (Art. 23(1)).

Is there a social security agreement between Pakistan and Italy?

No. Pakistan is not on the Italian Ministry of Labour's list of countries with a bilateral social security agreement, so each country applies its own contribution rules.

Sources

Legislation and official guidance

art. 2(2) TUIR (DPR 917/1986, as amended from 2024) — Resident is anyone who for most of the tax year (counting parts of days) has in Italy his or her residenza (habitual abode), domicilio (main personal and family relationships) or is physically present there; registration in the anagrafe (population register) is a rebuttable presumption. The criteria are alternative.
Agenzia delle Entrate, circolare no. 20/E of 4 Nov 2024 — Criteria are alternative; threshold 183 days (184 in a leap year); any part of a day counts as a day; domicilio means primarily personal and family relationships, not economic ones; 183 days of remote work from Italy alone make you resident; anagrafe registration is a rebuttable presumption; rules apply from 1 Jan 2024; tax treaties prevail, including where Italian residence follows only from anagrafe registration.
D.Lgs. 19 June 2026, no. 117 (new Testo unico, from 1 Jan 2027) — From 2027 the TUIR is replaced by a new code: the residence article 2 is carried over word for word; non-residents' income — art. 25; foreign tax credit — art. 185.
art. 23(1)(c) TUIR — For a non-resident, pay for work performed in Italy is taxable in Italy.
Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Art. 15(2) Pakistan–Italy Convention (1984) — Pay of a resident of one State for employment exercised in the other State is taxable only in the residence State if (a) the employee is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, «and either» (b) the pay is paid by or on behalf of an employer who is not a resident of the other State, «or» (c) it is not borne by a permanent establishment or fixed base of the employer in the other State (wording of the FBR copy).
Art. 4(2) Pakistan–Italy Convention (1984) — Dual-resident individual: (a) resident of the State in which he has a permanent home available to him; if he has one in both States — the State with which his personal and economic relations are closer (centre of vital interests); (b) if that State cannot be determined, or if he has not a permanent home available to him in either State — the State in which he has an habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) national of both or of neither — the competent authorities settle the question by mutual agreement.
Income Tax Ordinance, 2001, s. 107(2) — Subject to s. 109, a double taxation agreement and its implementing notification have effect notwithstanding anything in any other law, so far as they provide relief from tax under the Ordinance, determine the Pakistan-source income of non-residents, or provide for exchange of information.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; consolidated text amended up to 30.06.2026 listed by FBR) — A citizen of Pakistan is also a resident individual if he or she is not present in any other country for more than 182 days during the tax year, or is not a resident taxpayer of any other country. Applies from tax year 2023.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
Art. 23 Pakistan–Italy Convention (1984) — (1) Pakistan may include income taxable in Italy in the tax base, but deducts the Italian tax paid, up to the amount found by applying the average Pakistani rate to the doubly taxed income. (2) Italy may include income taxable in Pakistan in the base and deducts the Pakistan tax paid, up to the proportion of Italian tax that this income bears to the entire income; no deduction where the item is subject in Italy to a final withholding tax at the recipient's request. (3) Tax on business profits, dividends and interest exempted or reduced for a limited period to promote economic development is deemed paid, up to 25%.
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
art. 165 TUIR — Foreign tax is credited up to the share of Italian tax attributable to the foreign income.
art. 24-bis TUIR (current text, Brocardi mirror) — Optional substitute tax on foreign income for people who become Italian residents and were not resident for at least nine of the ten previous tax years: EUR 300,000 per year, EUR 50,000 per extended family member; ends after 15 years; specific foreign States can be excluded (comma 5), their income then being taxed ordinarily with foreign tax credit.
Law 30 Dec 2025, no. 199, art. 1(25)–(26) (GU no. 301 of 30 Dec 2025, S.O. 42/L; copy on finanzaefisco.com) — Raises the art. 24-bis substitute tax from EUR 200,000 to EUR 300,000 and the family-member amount from EUR 25,000 to EUR 50,000, for people who transfer their residence to Italy from the entry into force of the law.
Income Tax Ordinance, 2001, s. 101 — Salary is Pakistan-source to the extent it is received from employment exercised in Pakistan (wherever paid) or is paid by or on behalf of the Federal, a Provincial or a Local Government in Pakistan (wherever the employment is exercised). Dividends of resident companies, profit on debt and royalties paid by residents, rent and gains on immovable property in Pakistan, gains on shares of resident companies and pensions paid by residents are Pakistan-source; everything else is foreign-source.
art. 5 D.Lgs. 27 Dec 2023, no. 209 — as restated in Agenzia delle Entrate ruling (risposta) no. 2/2026 (copy on fiscoetasse.com) — Employment and self-employment income of workers moving to Italy counts at 50% within EUR 600,000 a year, if they were not Italian residents in the three previous tax years, work mostly in Italy, meet high-qualification requirements and stay resident for the year of transfer and the four following years.
art. 225 of the new Testo unico (D.Lgs. 19 June 2026, no. 117), derived from art. 5 D.Lgs. 209/2023 (miolegale.it mirror) — Same regime in the new code: 50% within EUR 600,000; prior non-residence of 3 tax years (6 or 7 if you worked for the same employer or group before); 60% exempt if you move with a minor child or a child is born or adopted during the regime.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
Art. 19 Pakistan–Italy Convention (1984) — Remuneration (other than pensions) paid by a State, its subdivision or local authority for services rendered to it is taxable only in that State; it is taxable only in the other State if the services are rendered there by a resident of that other State who is its national or did not become resident there solely to render the services. Government pensions are taxable only in the paying State, with a similar exception.
Ministero del Lavoro e delle Politiche Sociali — «Trattamento previdenziale dei lavoratori migranti inviati all'estero o provenienti dall'estero» — Lists the non-EU countries with which Italy has bilateral social security agreements (Argentina, Australia, Brazil, Canada/Québec, Cape Verde, the former Yugoslav states, Jersey and the Channel Islands, Israel, Monaco, South Korea, San Marino, the Holy See, the United States, Tunisia, Turkey, Uruguay, Venezuela); Pakistan is not among them.
Agenzia delle Entrate, circolare no. 9/E of 5 Mar 2015 (art. 165 TUIR) — Creditable are foreign taxes on income or of a similar nature, paid definitively; taxes covered by a tax treaty need no further check; in case of doubt a ruling request (interpello) can be filed.
Art. 30 Pakistan–Italy Convention (1984); FBR copy header — The Convention enters into force on the exchange of instruments of ratification (FBR copy: signed 22 June 1984, in force 27 February 1992) and has effect for taxable periods (Italy) and income years (Pakistan) beginning on or after 1 January of the calendar year in which the instruments are exchanged; the 1978 air and shipping agreement ceased to have effect.
Art. 4(2)(b) Pakistan–Italy Convention (1984) — If you have no permanent home available in either State, the treaty goes straight to habitual abode (the centre of vital interests step applies only where there is a home in both States).
Art. 4(2)(a) Pakistan–Italy Convention (1984) — Centre of vital interests: the State with which your personal and economic relations are closer.
Art. 4(2)(c), (d) Pakistan–Italy Convention (1984) — Habitual abode in both States or in neither — resident of the State of which you are a national; national of both or of neither — the competent authorities settle the question by mutual agreement.

Case law

Corte di Cassazione, Sez. 5 (tax), sentenza n. 19843 (Rv. 671648-02), 18/07/2024 — The new residence rules (D.Lgs. 209/2023) are not retroactive — they apply to facts from 1 Jan 2024. For earlier years domicilio means the centre of business and vital interests, and family ties count only together with other criteria. The taxpayer's appeal (tax year 2009) was declared inadmissible.
Corte di Cassazione, Sez. 5 (tax), ordinanza n. 18009, 06/06/2022 — The presumption of Italian residence for citizens who moved to low-tax States (here Switzerland) can be rebutted; the centre of vital interests was found to be in Switzerland although home and work were close to the border. Pre-2024 rules.
Corte di Cassazione, ordinanza n. 18702, 01/07/2021 — Registration in AIRE (Monaco) did not exclude Italian residence: the centre of business and vital interests — family and a directorship of an Italian company — was decisive. Pre-2024 rules.
Corte di Cassazione, ordinanza n. 8286, 15/03/2022 — A citizen whose domicilio (main place of business and economic interests) is in Italy is an Italian resident regardless of AIRE registration; case remanded. Pre-2024 rules.

Updated 04/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

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