Tax residence in Italy for Singapore taxpayers

Italy treats you as resident if for most of the calendar year you are present in Italy, have your domicile there (main personal and family relationships) or your residence, or are registered in the anagrafe. Singapore decides your status for the same calendar year by 183 days of presence or employment, normal residence of a citizen or PR, or IRAS's two- and three-year rules. If both countries claim you, Art. 4(2) of the Singapore–Italy Convention of 1977 decides; it has no nationality step.

Check your status: Singapore and Italy

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of Italy and the tax treaty (DTA).

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 non-resident

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 Singapore tax rules

Collision: most of the year in Italy while still resident in Singapore. You cannot spend most of a calendar year in Italy and also 183 days in Singapore, but Singapore can still treat you as resident for that year: as a Singapore citizen or PR who normally lives in Singapore and is only temporarily absent, or under IRAS's two- or three-year rules (for example the first or last year of a three-year stay). Both countries then tax you as a resident. Art. 4(2) of the Singapore–Italy Convention decides: permanent home; with a home in both countries, centre of vital interests; if that cannot be determined, or you have a permanent home in neither, habitual abode; if the habitual abode does not decide, the competent authorities settle the case by mutual agreement — the Convention has no nationality test.
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 presence. If Singapore also treats you as resident, Art. 4(2) of the Convention applies: a permanent home only in Singapore makes you a resident of Singapore; with a permanent home in both countries, a family living in Italy weighs heavily for an Italian centre of vital interests. Before 2024 the Court of Cassation gave priority to economic interests; 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; Singapore law ignores it. The conflict is resolved by Art. 4(2) of the Convention — the Agenzia delle Entrate accepts that treaty rules apply even where Italian residence follows only from anagrafe registration. If you have moved to Singapore, cancel the registration (or register with AIRE if you are an Italian citizen) and keep a Singapore Certificate of Residence from IRAS.

What else to know

Calendar year in both countries, but Singapore's Year of Assessment is one year later. Italy decides residence for the calendar year — presence, domicilio or residenza for most of the year (183 days, 184 in a leap year), with any part of a day counted as a full day, or registration in the anagrafe. Singapore also decides for the calendar year (183 days of presence or employment, normal residence of a citizen or PR, or IRAS's two- and three-year rules) and taxes that year's income in the following Year of Assessment: income of 2026 is YA 2027. The 183-day test for pay in Art. 14 of the Singapore–Italy Convention counts days «in the fiscal year concerned».
Working in Italy while resident in Singapore: the 183-day rule (Art. 14). Days of remote work from Italy are days of presence in Italy, and pay for that work is Italian-source income (art. 23(1)(c) TUIR). If Singapore is your treaty residence, Italy does not tax that pay only if all conditions of Art. 14 of the Convention are met: not more than 183 days in Italy in the fiscal year concerned, an employer condition (the English text reads «an employer who is a resident of that State», understood in context as the State of residence) and pay not borne by a permanent establishment in Italy. Art. 14 also covers professional services. Otherwise Italy taxes the pay for Italian work days; Singapore credits the Italian tax subject to its law (Art. 22(3)), but foreign-sourced income received by a resident individual is generally exempt in Singapore anyway (s. 13(7A)).
How Singapore and Italy relieve double taxation. If Singapore is your state of residence, it credits the Italian tax on income from Italy subject to its own law (Art. 22(3)); as most foreign-sourced income of a resident individual is exempt in Singapore (s. 13(7A)), the Italian tax usually stays as the final tax. If Italy is your state of residence, Italy includes the Singapore income in its tax base and deducts the Singapore tax, up to the proportion of Italian tax that income bears to total income (Art. 22(2), art. 165 TUIR) — but gives no credit if the income is subject in Italy to a substitute tax or a final withholding tax, also at your request. The Convention has no remittance clause. Mutual agreement procedure: Art. 24, within three years of the first notification.
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 — e.g. Singapore — and have it taxed ordinarily with a foreign tax credit. Singapore continues to tax Singapore-source income; whether a flat-tax payer is a «resident of Italy» under Art. 4(1) of the Convention for treaty benefits in Singapore was not verified.
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 commit to keep Italian tax residence for at least four 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. The regime applies in the year of the move and the next four tax years; if residence is not kept for four years, the relief is recovered with interest. From 1 January 2027 the regime is art. 225 of the new Testo unico (D.Lgs. 117/2026). The relief lowers Italian tax only; Singapore-source income remains taxable in Singapore under its own rules.
Pensions and government service. Private pensions for past employment are taxable only in the State of residence (Art. 17). Government salaries are as a rule taxable only in the paying State; the other State may tax them if the services are rendered there by its resident who did not become resident solely to render them (Art. 18(1); the first alternative condition, on nationality, is worded in the English text the opposite way to the OECD Model). Government pensions are taxable only in the paying State, unless you are a national and resident of the other State (Art. 18(2)).
Treaty residence in Italy: an Italian certificate for Singapore payers. If the Convention makes Italy your State of residence, ask the Agenzia delle Entrate for a certificate of tax residence for treaty purposes and give it to Singapore payers; IRAS requires the payer to obtain the certificate of the non-resident payee. The Convention (Art. 27) also provides for refunds of excess withholding on request with a certificate of residence.
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.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Government of the Republic of Singapore and the Government of the Italian Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Singapore on 29 January 1977), with Protocol and Exchange of Notes, as amended by the Additional Protocol of 24 May 2011. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in Italy

residenza fiscale: Italian tax residence — taxable on worldwide income
domicilio: where your main personal and family relationships are
anagrafe: population register; registration presumes residence
AIRE: register of Italian citizens living abroad
flat tax (art. 24-bis TUIR): fixed annual substitute tax on foreign income for new residents
credito d'imposta estero: credit for foreign tax under art. 165 TUIR

Questions

Which treaty applies between Singapore and Italy?

The Convention signed at Singapore on 29 January 1977, in force since 12 January 1979, as amended by the Additional Protocol of 24 May 2011 (in force 19 October 2012); it is not modified by the MLI. Art. 4(2): permanent home, centre of vital interests, habitual abode, then mutual agreement — no nationality test.

How many days can I work in Italy before Italy taxes my salary?

Under Art. 14 Italy cannot tax it if you are there no more than 183 days in the fiscal year concerned, the employer condition is met and no Italian permanent establishment bears the pay; the same article covers professional services. Days of remote work from Italy count as days in Italy.

Does Singapore tax my Italian income?

Singapore credits Italian tax subject to its law (Art. 22(3)), but foreign-sourced income received by a resident individual is generally exempt, so Italian tax usually stays final. As an Italian resident you get a credit for Singapore tax up to the Italian tax on that income (Art. 22(2); art. 165 TUIR).

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.
s. 2(1) Income Tax Act 1947 (definition of «resident in Singapore», para (a)) — An individual is resident in Singapore if, in the year preceding the year of assessment, he or she resides in Singapore except for such temporary absences as may be reasonable and not inconsistent with a claim to be resident; also resident is a person who in that year was physically present or exercised employment in Singapore (other than as a company director) for 183 days or more.
s. 2(1) ITA 1947 (definitions of «year of assessment» and «basis period»); IRAS — preceding-year basis of assessment — Tax is charged for a year of assessment (YA) on the income of the preceding calendar year: YA 2027 covers income from 1 January to 31 December 2026. Residence is determined for the same preceding calendar year, so the selected year 2026 is the basis year for YA 2027.
Art. 14 Singapore–Italy Convention (1977) (personal services) — Remuneration of a resident of one State for employment or personal (including professional) services exercised in the other State may be taxed there unless (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, (b) the remuneration is paid by, or on behalf of, an employer who is (in the English text) «a resident of that State», and (c) it is not borne by a permanent establishment in the other State.
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
Art. 4(2) Singapore–Italy Convention (1977) — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home in both States, of the State with which his personal and economic relations are closest (centre of vital interests); if that State cannot be determined, or if he has no permanent home in either State, of the State in which he has an habitual abode; if he has an habitual abode in both States or in neither of them, the competent authorities settle the question by mutual agreement. There is no nationality test. Not modified by the MLI, which Italy has not ratified.
IRAS — «Apply for Certificate of Residence» (updated 20 August 2026) — A Certificate of Residence (COR) for a state with which Singapore has a DTA is applied for through IRAS's online application; the form depends on the applicant's profile (Singapore citizen or PR employee, self-employed person, foreign employee with or without Singpass). Processing takes 2–3 weeks; the letter is available on myTax Portal if digital notices were chosen, otherwise it is mailed. A foreign tax authority's own form can be certified by IRAS on request (XLSX application and original form sent by post).
Art. 22 Singapore–Italy Convention (1977; para. 2 as replaced by the Additional Protocol of 2011) — Italy (para. 2): Italy may include in its tax base the items of income that may be taxed in Singapore and deducts the Singapore tax, up to the proportion of Italian tax attributable to those items in relation to total income; no deduction where the item is subjected in Italy to a substitute tax or a final withholding tax, also at the taxpayer's request. Singapore (para. 3): subject to its law, credits the Italian tax on income from Italy. The tax-sparing credit of para. 4 has ceased (para. 5). The Convention has no remittance clause.
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
art. 165 TUIR — Foreign tax is credited up to the share of Italian tax attributable to the foreign income.
Art. 24 Singapore–Italy Convention (mutual agreement procedure) — A person who considers that the actions of one or both States result in taxation not in accordance with the Convention may present the case to the competent authority of the State of which he is a resident within three years from the first notification of the action; under para. (e) of the 1977 Protocol domestic contentious proceedings must also be initiated where the claim concerns an assessment not in accordance with the Convention.
art. 24-bis TUIR (D.P.R. 22 dicembre 1986, n. 917), testo in vigore dal 1.1.2026 al 31.12.2026, commi 1–6 — Normattiva — 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.
Legge 30 dicembre 2025, n. 199, art. 1, commi 25–26 (GU n. 301 del 30.12.2025, S.O. n. 42) — Normattiva — 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.
art. 5, commi 1 e 3, D.Lgs. 27 dicembre 2023, n. 209 (testo vigente al 1° giugno 2026, Normattiva) — 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 commit to keep Italian tax residence for at least four years (if it is not kept for four years, the benefit is lost and recovered with interest); the regime applies in the year of transfer and the four following tax periods. From 1 January 2027 art. 5 is repealed and the same rules are in art. 225 of the new Testo unico (D.Lgs. 19 June 2026, no. 117).
D.Lgs. 19 giugno 2026, n. 117, Allegato — Testo unico imposte sui redditi, art. 225 (Regime per la determinazione del reddito dei lavoratori impatriati; GU n. 152 del 3.7.2026, S.O. n. 26) — Normattiva — 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.
Arts. 17–18 Singapore–Italy Convention (1977) — Art. 17: private pensions for past employment are taxable only in the State of residence. Art. 18(1): remuneration paid by a State for services rendered to it is as a rule taxable only in that State; it is taxable in the other State if the services are rendered there by a resident of that State who (in the English text) «is not a national» of it or did not become resident solely to render the services. Art. 18(2): government pensions are taxable only in the paying State, unless the recipient is a national and resident of the other State.
Agenzia delle Entrate — certificate of tax residence for treaty purposes: how to obtain it — The request on the official form is filed with any local office of the Agenzia delle Entrate: online in the reserved area («consegna documenti e istanze»), by PEC, in person or by registered post.
IRAS — «Claim of relief under the DTA» (withholding tax, updated 8 January 2026) — To apply a reduced treaty rate or an exemption, the Singapore payer obtains a certificate of residence of the non-resident payee from the other state's tax authority (in English or with an English translation, stating residence for treaty purposes and the years covered); non-resident professionals also sign Form IR586. The payer submits the certificate to IRAS by 31 March of the following year, otherwise the relief may be withdrawn.
Singapore–Italy Convention of 29 January 1977 with Protocol, as amended by the Additional Protocol of 24 May 2011 (IRAS text) — Signed at Singapore on 29 January 1977 (English and Italian equally authoritative), in force 12 January 1979; the Additional Protocol signed on 24 May 2011 entered into force on 19 October 2012 (taxes covered, PE period, Art. 22(2) relief, end of tax sparing, exchange of information). Not modified by the MLI, which Italy has not ratified.
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. 4(2)(a) of the Singapore–Italy Convention — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests).
Art. 4(2)(b) of the Singapore–Italy Convention — If the State of the centre of vital interests cannot be determined, or if he has no permanent home available in either State, he is deemed to be a resident of the State in which he has an habitual abode.
Art. 4(2)(c) of the Singapore–Italy Convention — If he has an habitual abode in both States or in neither of them, the competent authorities of the Contracting States settle the question by mutual agreement. There is no nationality test.

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.

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

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