Extraordinary transactions, such as winding up corporate vehicles abroad, may also benefit from the lump-sum substitute tax regime.
The reply to ruling request 292/2025 issued by the Agenzia delle Entrate again addresses the preferential regime under Article 24-ter of the TUIR for foreign pensioners who transfer their residence to a municipality in Southern Italy with no more than 20,000 inhabitants (or one affected by the 2009 earthquake).