Italy: a flat fee on all your foreign income. But Spain will ask you to prove the 183 days.
Italy's new-residents regime lets high-net-worth individuals pay a fixed substitute tax on all their foreign income, regardless of its amount. It is one of Europe's most attractive regimes, but it requires effective residence in Italy — and, if you move from Spain, the Spanish Tax Agency will require you to prove you spent more than 183 days outside Spain. The Italian certificate alone is not enough.
GeoNotary produces that proof: a continuous, automatic expert record of your physical presence, with court validity.
Italy tax facts
| New-residents regime — foreign income | fixed annual fee |
| Amount of the fee | €200,000/year (€300,000 from 2026) |
| Requirement | not resident in Italy 9 of the last 10 years |
| Duration | up to 15 years |
| Family members | +€25,000/year each |
| Tax-residence threshold | 183 days/year |
Indicative figures as of 2026. The fixed fee rose to €300,000 for those opting in from 2026; consult an adviser.
The real risk: a Spanish tax inspection
Spain's Tax Agency applies the tests in article 9 of the Personal Income Tax Act (Law 35/2006), independent of each other — meeting just one is enough:
- 1
Permanence > 183 days: your sporadic absences count as days in Spain unless you prove tax residence in another country with a certificate valid under the tax treaty.
- 2
Centre of economic interests: if your business, income or main assets remain in Spain.
- 3
Family nucleus: if your non-separated spouse and minor children reside in Spain.
The new-residents regime requires moving your effective residence to Italy. The Spanish debt becomes time-barred after 4 years and the move may trigger the exit tax (art. 95 bis of the Income Tax Act). An unfavourable reassessment with high income easily exceeds €300,000.
Why traditional evidence isn't enough
- Flight tickets: prove the purchase of the trip, not that you boarded or how long you stayed.
- Utility bills: prove consumption, not the holder's personal presence.
- Card statements: prove use, not that you used it in person.
- Certificate and residence permit: party-issued documents; the tax authority requires effective presence.
- Google Maps Timeline: rejected by the tax authority because it is editable by the user.
How GeoNotary solves it
- Continuous, automatic location record: covers all 365 days, with no gaps in the chain of custody.
- Biomechanical verification of the carrier: confirms it was you carrying the device.
- Public blockchain sealing + eIDAS timestamp: an unalterable, verifiable record.
- Expert report: admissible before the tax authority, the Economic-Administrative Tribunals and the administrative courts.
Unlike daily-selfie check-in apps, GeoNotary doesn't rely on you remembering to register each day, nor does it leave the days you forget without proof: it records continuously and silently, and certifies who was carrying the device — not just that a phone was somewhere.
Frequently asked questions
Start proving your residence in Italy today
The proof is preventive: the sooner you install it, the stronger your defence.
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