Relocating abroad is often the beginning of a new chapter. Those who hold investments in Italy, however, soon encounter a crucial question:

“Can I retain the administered regime on my securities portfolio, or must I switch to the declaratory regime?”

The answer — clear, yet surprisingly little known — was recently provided by the Italian Revenue Agency (Agenzia delle Entrate).

Clarification from the Italian Revenue Agency

With Ruling No. 208/2025, the tax authority reaffirmed three key points:

  • Continuity of the administered regime – Even those who become fiscally non-resident may retain the administered regime on their securities account held with Italian banks or SIMs without any impediment.
  • No obligation to switch to the declaratory regime – There is no requirement to navigate the complexity of filing an income tax return for each individual transaction.
  • Neutral revocation – Should one decide to revoke the administered regime, no taxation is triggered on unrealised capital gains.

These indications confirm that the applicable rules may differ from the practices still prevalent among certain market operators.

A Principle Long Established

This is not a new development. The Ministry of Finance Circular No. 165/1998 had already clarified that, for non-residents, the administered regime is the “natural regime”.

The legislative reference remains Legislative Decree No. 461/1997, which governs the taxation of financial income without restriction for those residing abroad.

Nevertheless, the erroneous belief that the administered regime is reserved exclusively for Italian residents persists in many banking and advisory circles. This misconception has led numerous investors to suboptimal decisions, resulting in unnecessary administrative burden and higher compliance costs.

The Administered Regime: Advantages and Limitations

For a saver living abroad, the administered regime remains a practical option because:

  • It simplifies tax management: the Italian bank acts as a withholding agent and deducts taxes directly on interest, dividends, and capital gains.
  • It reduces the risk of errors and penalties: there is no need to complete the RW section of the tax return or file Italian tax declarations for income already taxed at source.

This efficiency reduces bureaucracy and compliance obligations, yet it is not always the most tax-efficient choice.

When the Declaratory Regime May Be More Advantageous

If the country of residence applies a rate on financial income lower than the Italian rate (26% on capital gains and interest, 12.5% on government securities), the declaratory regime may prove more beneficial:

  • it allows financial income to be subject to taxation in the foreign country, which may be more favourable;
  • it permits more flexible management of tax credits or set-offs provided under double taxation treaties.

The choice, therefore, is not merely between simplicity and complexity, but between convenience and tax optimisation.

Conclusion: The Right Strategy Is Personal

In an interconnected world, knowing the rules is essential to avoid detrimental decisions.

Those who relocate abroad do not lose access to the administered regime: the legislation expressly permits it.

The real question is a different one: what is the most advantageous regime for my individual profile and for the country in which I reside?

Answering that question requires:

  • an analysis of the tax rates in the country of residence,
  • a review of the applicable double taxation treaty,
  • an assessment of wealth planning and succession objectives.

Next Step

Before making any decision, carry out a personalised tax health check. Comparing the rates of your country of residence with those applicable in Italy and modelling both regimes can transform a simple “regulatory confirmation” into a winning wealth management strategy.