Social security contributions under “lavoratori impatriati” regime - Italy

[European]

The “lavoratori impatriati” regime in Italy allows, under certain circumstances, for a tax exemption of up to 90% of your income.
If you make €200K a year as a freelance, for instance, you are liable for income tax on only €20K. There are several threads about this in the forum.

My question is regarding social security contributions. Generally, as a freelance you will pay around 25% of your income for social security, with an income cap of €113K.

There seems to be no clarity on how much SS must be paid under the “lavoratori impatriati” regime. Two theories:

T1: Some people claim that the 25% will be calculated on your full income and that the 90% exemption only applies to income tax.

T2: Other people claim that the 25% is calculated on 10% of your full income, i.e., the 90% exemption also applies to SS contributions.

There are accounting websites to back up both theories. I have spoken to several tax advisors and have also heard both. Additionally, I have also heard stories about people currently in the regime that pay SS on all income and about others paying on only 10%.

As far as I know, the INPS (gov body in charge of SS) has not provided official guidance/clarification on this.

Does anybody have reliable or official information to confirm/refute any of the theories?

 

[JohnnyDoe]

You might be able to obtain an official ruling on request. I can suggest a good advisor if you need one.

 

[Mr Gus]

Yes I believe there never was an official statement about the lavoratori impatriati also being applicable to SS. If it is the case it can be a great way to pay very little tax in Italy.

Here is a video from an accountant explaining it if you haven't seen that already. Depending on the type of income you will be eligible according to the tax software, so still nothing official.

 

[European]

You might be able to obtain an official ruling on request. I can suggest a good advisor if you need one.

The suggestion for the good advisor would be much appreciated. Thanks.
What is the procedure to obtain an official ruling?

 

[JohnnyDoe]

The suggestion for the good advisor would be much appreciated. Thanks.
What is the procedure to obtain an official ruling?

I sent you a pm

 

[marioIT]

As others say, don't handle this kind of stuff by yourself in italy.
It's already hard and confusing enough even for a lawyer...
laws are so badly written that even when you think you're right you still can get a fine like 5 years later, even with a lawyer helping you.
if you can get a ruling in advance as Johnny said, that's great. If you get an answer from them, double check that's not only an advice but that it has legal validity (in court).
Don't remember if you can get a ruling from INPS, you can for sure get one from the tax agency but they're 2 different entities.

FYI INPS IIRC is likely one of the worst italian entities to deal with. They're not going to listen unless you take them to court and prove them wrong.
Even after a sentence they'll try everything they can to not pay.
I mean they've got 1/5 stars on trustpilot... ask yourself why people call it the Italian National Ponzi Scheme lol
https://www.trustpilot.com/review/www.inps.it

 

[European]

FYI
This gentleman says the issue has been officially clarified and that the INPS contributions for freelancers are calculated on the reduced amount, same as the income tax:

referring to this document:
https://www.consulentidellavoro.it/files/PDF/2023/CNO/Riunione_TavoloTecnico_AdE_Inps_CNO.pdf