Special cases

Latest update: 12/12/2020

Persons resident abroad are subject to taxation in their country of residence. For pensions received in Italy by a resident abroad:

  • pensions paid by the Italian State or by a political or administrative subdivision of the State or a local authority are generally taxable only in Italy
  • private pensions paid by Italian welfare entities, institutions or bodies responsible for pension provision are taxable only in the country of residence of the beneficiary.

In general, most international double taxation conventions provide for exclusive taxation in the country of residence. However, the agreements may provide for specific exemption thresholds or shared taxation in both Contracting Countries for pensions under social security arrangements for private workers. Some examples are given in the table:


Country of residence		 Taxation of Italian source pension

Argentina
United Kingdom
Spain
United States
Venezuela

Italian public pensions are normally taxed only in Italy. However, they are not subject to taxation in Italy if the taxpayer has the nationality of another State in which they reside.
Private pensions received by residents of these countries are not taxed in Italy.

Belgium

Italian public pensions are normally taxed only in Italy. However, they are not subject to taxation in Italy if the beneficiary, resident in Belgium, has Belgian nationality and not Italian nationality.
Private pensions received by residents of Belgium are not taxed in Italy .

France

Italian public pensions are normally taxed only in Italy. However, they are not subject to taxation in Italy if the taxpayer has French nationality and not Italian nationality. As a general rule, Italian private pensions are taxed only in France.
However, pensions which the current Convention between Italy and France regards as pensions paid under ‘social security’ legislation are taxable in both States.

Germany

Italian public pensions are normally taxed only in Italy. However, they are not taxed in Italy if the taxpayer has the nationality and residence of another State and not that of Italy.
Private pensions received by residents of Germany are normally not subject to taxation in Italy.

Australia

Both public and private pensions are not taxed in Italy.

Canada

Private pensions from Italian sources are not taxed in Italy if the amount does not exceed the higher of the following amounts: 12 000 Canadian dollars or the equivalent in euro. Above this limit, pensions are also taxable in Italy. Public pensions are taxable only in Italy.

Switzerland

Private pensions are taxed only in Switzerland. Italian public pensions are taxed only in Italy if the taxpayer has Italian nationality, so they are not taxable in Italy if the taxpayer resident in Switzerland does not have Italian nationality.

Regional and municipal surcharges for non-national pensioners

For pensions paid to non-residents, the regional and municipal surcharges apply according to the place where the registered headquarters of the social security institution paying the pension is located (see Resolution No 261 of the Revenue Agency of 21 September 2007 (IT)).

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