San Marino: AIRE Registration Mandatory for Stays Abroad Exceeding 12 Months

Effective from late 2026, Italian citizens residing abroad for more than 12 months must enroll in the Registry of Italians Resident Abroad (AIRE – Anagrafe degli Italiani Residenti all’Estero), as highlighted in Il Sole 24 Ore on 31 August 2026. This requirement stems from Law No. 470/1988 and recent implementing decrees linking AIRE registration to tax residence determination. Failure to register can result in the presumption of Italian tax residence, exposing worldwide income to Italian taxation. The registration must be completed within 90 days of establishing habitual residence abroad through the local Italian consulate. The measure affects expatriates, digital nomads, and seconded employees who maintain Italian citizenship.

Key Takeaways

  • Tax Residence Presumption: Non-registration in AIRE creates a legal presumption of Italian tax residence under Article 2 TUIR, triggering worldwide income taxation and wealth tax (IVIE/IVAFE) obligations on foreign assets.
  • Consular Procedure: Registration requires proof of foreign residence (lease, utility bills, local registration) and identity documents. The consulate issues an AIRE certificate essential for accessing consular services and voting abroad.
  • Coordination with Host Country: Expatriates must also comply with host country registration requirements. Dual reporting obligations necessitate careful calendar management to avoid gaps that could be exploited by Italian tax authorities.

Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.

Source: Read Official Announcement