The Italian Revenue Agency has issued an important clarification through Interpello n. 55/2025 regarding the qualification requirements for accessing the new impatriate regime. This ruling addresses a specific case involving a maritime professional and establishes crucial precedents for foreign workers considering relocation to Italy under the regime for impatriati (expatriate workers returning to Italy).

The Maritime Professional’s Question to the Revenue Agency

In this significant case, a maritime professional submitted a detailed query to the Italian Revenue Agency (Agenzia delle Entrate) seeking clarification on whether he could access the new impatriate regime. The taxpayer specifically asked whether the requirements for “high qualification or specialization” must be met jointly or if professional qualification alone could suffice for accessing the tax benefits. The applicant’s professional profile included:

• Graduation from a nautical institute in 2008
• International work experience from 2019 to 2024 (registered with AIRE – Registry of Italians Residing Abroad)
• Employment with Italian maritime companies starting May 2024
• 7th level Quadro Super classification under the national collective agreement
• Company Security Officer (CSO) responsibilities
• Ship Commander License for vessels of 3000 GT or higher
• Specialized ISPS Code certification for CSO activities
• Advanced competency certifications according to STCW 78 international maritime standards

Key Question Posed in Interpello n. 55/2025

The maritime professional posed a crucial interpretative question to the Revenue Agency: “Must the requirement for possessing a higher education degree that certifies completion of at least three years of higher education and the related qualification be understood as joint conditions that must both be respected? Is performing a role with superior qualifications falling within levels 1, 2, and 3 of the ISTAT CP 2011 professional classification sufficient for accessing the benefit?”

This question goes to the heart of how Italy interprets professional qualifications for the rientro dei cervelli (brain gain) program, particularly for professionals whose expertise is internationally recognized but may not align with traditional academic pathways.

Revenue Agency’s Response and New Interpretation

Scope Limitations for Interpello Requests

The Revenue Agency clarified an important procedural point that affects all potential applicants to the impatriate regime. The agency stated that requests for evaluation of specific qualification titles fall outside the scope of tax interpretation services (interpello) because they require technical assessments that are the competence of other administrations. This means the Revenue Agency cannot directly evaluate whether specific professional qualifications meet the regime’s requirements. Instead, applicants must ensure their credentials align with the criteria established in the referenced legislation.

Legal Framework for Qualification Requirements

The new impatriate regime, introduced by Article 5 of Legislative Decree 209/2023, requires workers to possess “high qualification or specialization requirements as defined by Legislative Decree 108/2012 and Legislative Decree 206/2007.”

Understanding how these requirements impact your net income is crucial, and you can use the italy tax calculator to estimate your potential earnings under the regime.

These requirements include workers who are alternatively in possession of:

Educational Qualifications:

• Higher education degree of tertiary level certifying completion of at least three years of higher education
• Post-secondary professional qualification of at least three years duration
• Qualification corresponding to at least level 6 of the National Qualifications Framework

Professional Experience Alternatives:

• Superior professional qualification certified by at least five years of relevant professional experience
• For ICT managers and specialists: superior professional qualification certified by at least three years of relevant experience acquired in the seven years preceding the application

Regulated Professions:

• Requirements established by Legislative Decree 206/2007 for regulated professions

Implications for Maritime and Other Professionals

The Maritime Sector Challenge

The case highlights a specific challenge for maritime professionals. The applicant noted that while the Ship Commander License is “subject to stringent regulations regarding access requirements and maintenance of qualification,” Italy does not recognize the equivalence between such qualifications and higher education degrees, unlike many other countries. This creates potential barriers for highly qualified maritime professionals who possess internationally recognized certifications but lack traditional academic credentials.

Professional Classification Focus

The applicant argued that his role and contractual classification are “undoubtedly classifiable among superior professional qualifications, falling within levels 1, 2, and 3 of the ISTAT CP 2011 professional classification.” This approach emphasizes the actual professional level and responsibilities rather than educational background.

Revenue Agency’s Final Decision

The Revenue Agency concluded that the applicant can access the new regime, subject to meeting all other required conditions, provided he possesses one of the requirements indicated in Article 27-quater of the Immigration Code (T.U.I.). However, the agency emphasized that the evaluation of whether specific qualifications meet these requirements cannot be performed through the interpello process, as it requires technical assessments beyond the agency’s fiscal competence.

Practical Implications for Foreign Workers

Application Strategy

For foreign workers considering the impatriate regime:

• Document all qualifications comprehensively: Include both educational credentials and professional certifications
• Focus on internationally recognized standards: Emphasize qualifications that meet EU or international standards
• Consider professional experience pathways: The regime offers multiple routes to qualification beyond traditional education
• Prepare for individual assessment: Each case requires specific evaluation of how qualifications align with Italian standards

Sectoral Considerations

The maritime case establishes precedent for other sectors where:

• International certifications are standard
• Professional competence is demonstrated through licensing rather than degrees
• Industry-specific qualifications may not have direct academic equivalents

Key Takeaways from Interpello n. 55/2025

For Applicants:
✅ Multiple pathways exist for meeting qualification requirements
✅ Professional experience can substitute for formal education in specific circumstances
✅ International certifications and licenses are considered within the framework
⚠️ Individual assessment is required for each case
⚠️ The Revenue Agency cannot pre-evaluate specific qualifications through interpello

For Employers:

• Understanding employee qualification pathways helps in recruitment planning
• Documentation requirements are extensive and must be thoroughly prepared
• Professional classifications (ISTAT levels 1-3) play a crucial role in eligibility

The complete text of Interpello n. 55/2025 is available at: https://www.agenziaentrate.gov.it/portale/documents/20143/8473268/Risposta+55_2025.pdf/e40ff4ed-fc8c-8d4e-2615-bf2347773f6b?t=1740748817718

Looking Forward

This ruling clarifies that while the impatriate regime offers flexibility in recognizing professional qualifications, applicants must carefully document how their specific credentials align with the established criteria. The regime’s €600,000 annual income limit ensures accessibility for high-level professionals while maintaining the program’s focus on attracting qualified talent to Italy.

For maritime professionals and others in specialized sectors, the key is demonstrating that professional qualifications and experience meet the standards established in the Immigration Code, even when traditional educational pathways weren’t followed.

Given the complexity of these requirements, consulting with a specialized tax advisor in Italy can help ensure your qualifications are properly documented and presented.