As a quick google search will show, there are several articles online about setting up a Representative Office in Italy. They typically say you need an Italian accountant or notary to register the RO and to then apply for the nulla osta. The accountant submits the papers on behalf of the RO for the RO to apply for a
Certificate of No Impediment and a nulla osta for a foreign non-eu national to be able to apply for a visa to go to Italy as the official representative working in the RO. So it seems professional assistance in Italy is required for the first steps. (Registering the RO, obtaining
Certificate of No Impediment, submitting documents on behalf of the RO so it can apply for and obtain the nulla osta and perhaps other steps as well that can only be done by a rep already within Italy.)
In the online articles you will find conflicting information about the number of documents you require to be able to open the RO, and about what visa the non-eu national must apply for.
Most articles say the visa is for an intra-company transfer.
Nicolo Bolla raises the option of a self employed visa and in the case of it being for the representative of the RO it in this specific case falls outside the quota that normally applies to self employed visas.
I have directly confirmed from my local Italian embassy that yes the self employed visa is eligible when the nulla osta is obtained through a RO, and yes it falls outside the annual quota flow. So that's very good news.
Since the self employed visa approach is for self employed, that means the contract appointing that person as the Representative must state they can work without supervision (i.e. as a self employed agent so to speak) and they _cannot_ be an employee who must report back to the HQ and be supervised directly by HQ.
As for paying zero tax, this might be possible depending on your types of income and sources, but to renew the self employed visa you need to show for a single person about 6.5k euros income FROM ANY SOURCE and pay tax and social charges on that minimum amount. (About 8.5k euros minimum if there is a dependent spouse.)
That raise the question... how to pay tax and social charges if you are claiming a 0% tax regime and if all your income falls into eligibility for the 0% regime?
Nicolo Bolla says you _must_ pay the tax and socials on that minimum amount to be able to renew the self employed residency permit.
Now, when lawyers say you "must", sometimes it only means its going to be much easier to renew the residency permit if you do that... and other times they really mean you must or you simply cannot renew the permit. I don't know which category of 'must' this minimum income and payment of tax and social charges falls into.
Also, Nicolo, (as the OP says) claims there is no minimum annual stay required to renew the permit. This is worth checking deeper because the normal requirement to renew the self employed residency permit _does_ have a minimum stay requirement.
Also on the subject of what you _must_ do... some online articles say there must be more documents supplied to open a RO etc than those listed in other articles.
So far, some lawyers have told me you do not need to provide company financials at all. My local Italian embassy also did not ask for company financials in their list of required documents to open a RO.
In the end, you might find you can supply less documents if registering your RO in one prefecture and more documents might be required in a different prefecture. Perhaps a company in Africa might face a higher hurdle to register their RO than a company from a more western country. In any case, Nicolo says company financials must be supplied when applying to register the RO, but other lawyers and my local Italy embassy do not include financials in the list.
So, like a lot of 'advice' from Italian sources about Italian residency options, the information obtainable from free online sources does vary a lot and each 'lawyer' or accountant tends to just ask for and do what works for them in their prefecture/s where they work. Other routes and options will also probably work since other lawyers specifically recommend different models to reach the same ROV destination.
To summarise:
Certainly there seems to be a simple enough process to register an RO in Italy (in fact it seems a simple route in many countries not just Italy ).
It seems like there are at least 2 options for the visa to enter Italy. Both the self employed visa and the Intra-company Transfer (ICT) visa are eligible- NOTE: there are actually 2 different types of ICT visa in Italy (the EU version and the national version both with different issues) so care must be taken choosing which one to apply for if you go the ICT visa route).
The good news is both visa route options fall outside any quote restrictions when the nulla osta is applied for through the RO.
The self employed route is a much easier process to qualify and to renew the residency permit. The self employed permit can lead to permanent residency (presumably if the minimum stay in Italy and minimum tax and social payments each year are met). The ICT residency generally does not lead to permanent residency and might also not be renewable beyond a certain number of years. It's a much more complicated process.
In his online article PERHAPS Nicolo tends to necessarily gloss over some issues such as being able to apply for permanent residency. His article seems to suggest you do not need to satisfy any stay requirements to either renew the residency permit OR to apply for permanent residency... but those details should be double checked for confirmation. It's possible Nicolo is just mixing together various possibilities but due to the shortness of the article he cannot provide deeper text about exactly the requirements to satisfy either goal. Or maybe he knows his subject perfectly and what we read in his article is in fact correct. You would want to get the green light from some offical source any way. To put this another way:
You really should double check with office source/s if you can pay no tax and renew the residency permit.
You really should double check with official sources if you can apply to renew the residency permit and eventually apply for permanent residency after 5 years IF you do not spend the minimum stay each year in Italy. (As I said above, if you go the ICT visa route then it will NOT lead to permanent residency. The self employed visa can lead to permanent residency but does the RO route wave a magic wand and remove the normal requirements for annual stay?
If I was going the RO route through Nicolo or any other accountant or lawyer specifically promoting this model then I would ask for contacts details for their other clients who have gone this route with them and check with them that everything works as advertised
. The ideal reference would be from a client who has gone all the way through 5 years and obtained their permanent residency according to the advertised model.
One other comment about the self employed visa route via a RO... self employed pay less social taxes and can enjoy 5% tax for 5 years then 15% after that on only 78% (maybe less) of their total revenue - this is a standard taxation model up to I think now 85k euro annual income and is not some special tax regime like Impatriate. It's not a bad tax rate.
