Can Italians residing abroad for work reasons access the tax breaks for the purchase of the “first home” in Italy? This is a question of great interest for those who, while living outside the national territory, want to buy a home in the country of origin.
Recently, the Revenue Agency has provided a fundamental clarification on the matter, specifying in which cases it is possible to benefit from the facilities envisaged.
Let’s see in detail what the legislation provides and what are the conditions to take advantage of it.
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The question posed by the taxpayer
An Italian citizen, residing abroad for work reasons and enrolled in AIRE since 2013, asked the Revenue Agency if it was possible to take advantage of the “first home” facility for the purchase of a property in Italy.
I have been residing abroad for several years for work reasons and should buy a house in Italy. Is it possible to enjoy the first home facilities?
In particular, the taxpayer said he wanted to buy a house located in a municipality in which he had resided before moving abroad, but which does not correspond to the last municipality of residence before the transfer.
The doubt was born from the interpretation of current legislation, which provides for concessions for those who buy a property in the municipality of birth or previous residence or activity.
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The opinion of the Revenue Agency
The Revenue Agency, with the Answer n. 28/2025provided a clear and favorable interpretation for Italians residing abroad who intend to buy a property in Italy with the “first home” concessions. In particular, the clarification concerns a crucial aspect of the legislation: the possibility of benefiting from the facilities even if the property purchased is in a municipality other than that of the last residence in Italy before transferring abroad.
The question was born from the interpretation of the Note II-bis, paragraph 1, letter a) of article 1 of the tariff, first, of Presidential Decree 131/1986which establishes that the taxpayer moved abroad for work can benefit from the “first home” facilities if the property is:
- In the municipality of birth
- In the municipality where he had a residence before the transfer
- In the municipality in which he carried out his work before the transfer
The doubt raised by the taxpayer concerned the sentence “Before transfer”asking if this were to refer exclusively to the last municipality of residence or if it could include any municipality in which she had lived or worked before moving abroad.
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The interpretation of the Revenue Agency
The agency clarified that It is not necessary that the Municipality of purchase coincides with the last residence of the taxpayer in Italy before the transfer abroad. The criterion to consider is wider and includes any municipality in which the taxpayer resided or worked before leaving the country.
This interpretation is based on two fundamental aspects:
- The literal data of the standard: the choice of the property to the latest municipality of residence is not expressly limited.
- The ratio legis of the regulatory modification of 2023: the legislator wanted free the benefit from citizenship and anchor it to a Objective bond criterion with the Italian territorywhich can derive from birth, residence or previous work.
Therefore, even if the last municipality of residence before departure was different from that chosen for the purchase, However, the facility is applicableAs long as there has been an effective connection in the past, in the form of residence or work activity.
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A principle of territorial continuity
The interpretation of the agency is based on the concept of Historical connection of the taxpayer with the Italian territory. In other words, What matters is not the Municipality of residence immediately preceding the transfer, but the link with any municipality in which the subject has lived or worked in the past.
This approach is consistent with the possibility, already recognized, to purchase a property with “first home” facilities in the municipality of birth, even if the taxpayer has never resided there.
In the specific case analyzed by response no. 28/2025, the taxpayer had lived in the municipality Y For several years before moving to the Municipality Wfrom which he then moved abroad. His intention was to buy a house right in the municipality Ywhere he had resided in the past. According to the agency, this choice is completely legitimate for the purpose of the facility, because the Municipality Y is among those in which the taxpayer had actually resided before the final transfer abroad.
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The importance of clarification for Italians abroad
This interpretation is of great importance for Italians residing abroad, because it eliminates a possible restriction in accessing tax breaks. If the agency had interpreted the legislation in a restrictive sense, taxpayers could only buy in A very limited number of municipalities (that of the last residence in Italy or that of birth)drastically reducing the possibility of choosing a property suitable for your needs.
Now, however, the taxpayer has greater flexibility and can choose a municipality with which he has had a link in the past, without having to respect the constraint of the last residence. This is particularly advantageous for those who have moved several times within Italy before expatriation and could have an interest in buying a property in a municipality other than the last of residence.
In summary, the answer n. 28/2025 sanctions a principle of greater opening and flexibility For Italians abroad who want to buy a house in Italy, confirming that the tax benefit can also be requested for a property located in a municipality where the taxpayer has lived or worked in the past, and not only in the last municipality of residence before the expatriation.
