First home tax relief and taxpayers transferred abroad

The Italian Revenue Agency, in Ruling No. 28/2025, has provided key clarifications regarding the eligibility for first home tax relief for taxpayers who have relocated abroad for work purposes. These clarifications reflect the legislative changes introduced by Decree-Law No. 69/2023.

Specifically, the Agency’s interpretation concerns Note II-bis, paragraph 1, of Article 1 of the Tariff, Part I, attached to the Consolidated Law on Registration Tax (Presidential Decree No. 131/1986), which governs the conditions for accessing the reduced 2% registration tax rate on the purchase of a first home.

Eligibility criteria for the first home tax relief

The legislation requires the simultaneous fulfillment of three conditions, even in the case of purchases made by individuals residing abroad for work reasons:

1. Location of the property: It must be located in the taxpayer’s municipality of birth, or in a municipality where the taxpayer had residence or carried out professional activity before moving abroad.
2. Absence of other property rights: The taxpayer must not hold ownership, usufruct, use, or habitation rights over other properties located in the same municipality.
3. No prior use of the relief: The taxpayer must not have previously claimed the first home tax relief on other property purchases.

The interpretative issue: what does “before the transfer” mean?

The case under review involved a taxpayer who had moved abroad for work and intended to purchase a property in a municipality other than the one of last residence or employment in Italy—but still one where the individual had lived in the past.

The interpretative question concerned the phrase before the transfer: does it refer solely to the last residence or workplace in Italy, or does it include any municipality where the taxpayer had previously lived or worked before moving abroad?

The Revenue Agency’s interpretation

In its response, the Agency adopted a broad and taxpayer-friendly interpretation. It noted that, following the amendment introduced by Article 2, paragraph 1, of Decree-Law No. 69/2023, the legislator intended to expand the connection between expatriate taxpayers and Italian territory, giving weight to previous personal, familial, or professional ties.

Within this framework, it is not necessary for the property to be located in the last municipality of residence or employment before the move abroad. It is sufficient that it be located in any municipality where the taxpayer lived or worked prior to relocation.

Thus, the Agency confirmed that the relief also applies to properties located:

• in the municipality of birth, even if the taxpayer never lived there;
• in previous places of residence or employment, even if not immediately preceding the transfer abroad.

A coherent interpretation aligned with the purpose of the law

This interpretation is consistent with the aim of the relief, which is to encourage Italian citizens living abroad for work to maintain or re-establish a connection with their homeland—through personal roots or places of past residence.

The approach adopted by the Agency therefore:

• adheres to the literal wording of the revised provision;
• aligns with the legislator’s intent to extend the benefit to expatriate workers;
• ensures equal treatment with taxpayers residing in Italy.