Many UK employees, contractors and remote workers now spend part of the year working from Italy. A frequent concern is how long they can work from Italy without triggering additional tax implications in the UK or in Italy. In practice, there is no single “safe” number of days that works for everyone. Tax consequences depend on UK tax residence rules, Italian tax residence rules and the Italy–UK double tax treaty, as well as on the way the employment relationship is structured.

This article provides a practical overview from the perspective of an international tax law firm, aimed at UK residents who work from Italy and at Italian professionals working for UK employers.

Core factors that determine tax implications

Before looking at day‑count thresholds, it is necessary to understand the core factors that drive tax exposure when a UK resident works from Italy.

Tax residence status in the UK and in Italy

The first factor is tax residence. The UK applies the Statutory Residence Test, which combines day‑counting with qualitative connections to the UK such as a home, family, work and prior presence. Spending 183 days or more in the UK in a tax year almost always results in UK tax residence, but residence can arise even with fewer days if sufficient UK ties are present.

Italy applies different criteria. An individual is treated as tax resident if, for more than 183 days in a calendar year, any one of the following conditions is met: registration in the municipal population register, residence (habitual abode) in Italy or domicile (centre of vital interests) in Italy. A person may therefore become Italian tax resident without formal registration if their family and economic centre of life moves to Italy and their presence there is sufficiently prolonged.

It is possible, particularly in a year of transition, for both countries to regard an individual as resident under their domestic rules. In that case, the Italy–UK double tax treaty must be used to resolve dual residence through tie‑breaker criteria such as permanent home and centre of vital interests.

Employer location and place where work is performed

The second key factor is the identity and location of the employer and the place where duties are performed. Typical situations include:

  • a UK employee of a UK company working remotely from Italy for a limited period
  • a UK‑resident individual employed directly by an Italian company
  • a contractor with clients in both the UK and Italy

The employer’s location and the place of work determine not only where the salary is taxed but also whether the employer faces payroll, social security or permanent establishment exposure in Italy.

UK tax residence rules for individuals working from Italy

Overview of the Statutory Residence Test

The UK Statutory Residence Test determines whether an individual is UK tax resident for a particular tax year. It includes:

  • automatic residence tests, under which an individual is UK resident if certain objective conditions are satisfied (for example, spending at least 183 days in the UK)
  • automatic overseas tests, which treat an individual as non‑resident if they work full‑time overseas and spend only a limited number of days in the UK
  • the sufficient ties test, which examines UK ties such as a home, close family members, substantive UK work and prior presence, and then combines these with day‑counts

An individual who works from Italy for part of the year may still remain UK tax resident if the automatic residence tests or sufficient ties test are met. This is often the case for employees of UK‑based companies who only temporarily work from Italy.

Consequences of remaining UK tax resident

If an individual remains UK tax resident while working from Italy, the UK will generally tax their worldwide income, including salary, subject to any applicable reliefs. The UK employer will usually continue to operate PAYE on the employment income, unless a specific arrangement is put in place.

At the same time, working physically in Italy may give Italy a right to tax the portion of the salary relating to duties performed on Italian territory. Whether Italy may exercise that right depends on the length of presence in Italy and on the detailed conditions of the Italy–UK tax treaty.

Italian tax rules when UK residents work from Italy

Italian rules on tax residence and the 183‑day threshold

Under Italian domestic law, an individual is considered tax resident if, for more than 183 days in the calendar year, at least one of the following applies: registration in the municipal population register, residence understood as habitual abode in Italy, or domicile understood as the centre of vital interests located in Italy. It is not necessary to satisfy all conditions; one is enough.

This means that a UK citizen who spends most of the year working from Italy, particularly if accompanied by family and economic ties, can become Italian tax resident even if they remain on the payroll of a UK employer. Once Italian tax residence is established, Italy will generally tax that individual on their worldwide income and foreign assets, subject to double tax relief and any relevant special regimes.

Non‑resident taxation of Italian-source employment income

If an individual is not Italian tax resident, Italy may still tax employment income that is considered Italian‑source. In general, salary relating to work physically performed in Italy is treated as Italian‑source income, even when paid by a foreign employer. The extent of Italian taxation in such cases depends on the Italy–UK tax treaty, which may limit Italy’s taxing rights in the case of short‑term assignments that satisfy strict conditions.

Accordingly, a UK resident spending relatively short periods in Italy may avoid Italian tax on salary if the treaty conditions are met, but the same individual could become taxable in Italy if those conditions are not satisfied or if the stay becomes prolonged.

Role of the Italy-UK double tax treaty

Allocation of taxing rights on employment income

The Italy–UK double tax treaty contains a specific article regulating the taxation of employment income. The general rule is that salary is taxable in the state where the employment is exercised. However, an exception applies if all of the following conditions are met:

  • the employee is present in the other state for a limited period that does not exceed 183 days in the relevant period
  • the employer is not resident in that other state
  • the remuneration is not paid by or on behalf of a permanent establishment that the employer has in that state

If these three conditions are all satisfied, the salary may be taxed only in the employee’s state of residence, even though the work is physically performed in the other state.

Practical effect of the 183‑day rule for UK workers in Italy

For a UK‑resident employee who works temporarily in Italy for a UK employer with no Italian permanent establishment, and whose presence in Italy does not exceed 183 days, the treaty can allow the salary to remain taxable exclusively in the UK.

However, if the 183‑day threshold is exceeded or if the remuneration is borne by an Italian company or permanent establishment, Italy may acquire taxing rights on the salary. If, in addition, the individual meets the domestic criteria for Italian tax residence, Italy may tax the salary on a worldwide basis, with relief for UK tax obtained through foreign tax credits and treaty provisions.

The 183‑day rule should therefore be viewed as a conditional exception within the treaty, not as a blanket guarantee that “up to 182 days there are no tax implications”.

Typical scenarios for UK residents working from Italy

Short stays in Italy for a UK‑based employee

When a UK‑resident employee spends a limited number of weeks per year working remotely from Italy, without moving family or economic centre of life and while maintaining their main home in the UK, the risk of Italian tax residence is generally low. The 183‑day threshold is not approached, and the treaty exception on short‑term employment often applies, so that salary remains taxable only in the UK.

In such cases, the main issues to verify are immigration requirements, social security contribution arrangements and internal policies of the UK employer on remote working from abroad.

Extended periods in Italy without formal relocation

Where a UK employee spends several months each year in Italy, working from there on a recurring basis, the situation is more complex. Time spent in Italy may approach or exceed 183 days over a twelve‑month period, and there may be a gradual shift in personal and economic connections towards Italy.

In this scenario, it is no longer sufficient to rely on the 183‑day rule as a simple threshold. Italian tax residence may arise if the individual spends most of the year in Italy and moves their centre of vital interests there. Even if Italian residence does not arise, the treaty exception may cease to apply, and Italy may become entitled to tax the salary attributable to work performed in Italy.

Full‑time remote work from Italy for a UK employer

The most sensitive case is that of a UK citizen who moves to Italy and performs their work from Italy on a full‑time basis, while remaining employed by a UK company. If the individual spends more than 183 days per year in Italy and moves their home and family there, Italian tax residence is likely. In addition, the treaty exception will not be available because the 183‑day condition will not be satisfied.

In practice, the salary may become taxable in Italy and remain taxable in the UK under UK rules or through payroll withholding, generating a risk of double taxation. Relief must then be obtained through the foreign tax credit mechanism and correct application of the treaty. The UK employer may also face questions on whether the employee’s presence in Italy constitutes a permanent establishment.

UK tax implications of working from Italy

PAYE withholding and UK reporting

Even when an individual works from Italy, a UK employer will often continue to operate PAYE on the salary, particularly if the employee remains on a UK contract and is still treated as UK tax resident. The existence of Italian taxing rights does not automatically switch off PAYE.

This can result in tax being paid in both countries on the same income. Correct reporting is essential: the individual may need to file a UK tax return, an Italian tax return or both, claiming relief for foreign tax paid in accordance with domestic rules and the treaty.

Dual residence and overlapping obligations

Extended periods of work in Italy can lead to dual residence, where both the UK and Italy view the individual as tax resident under their domestic rules. In this situation, the treaty tie‑breaker must be applied to determine the country of residence for treaty purposes.

The tie‑breaker analysis is fact‑specific and examines permanent home, centre of vital interests, habitual abode and nationality. A mistaken assumption about residence status can result in unexpected liabilities, penalties for late filing and difficulties in obtaining relief for double taxation.

Immigration, social security and compliance aspects

Immigration requirements for UK citizens in Italy

From an immigration perspective, UK citizens no longer benefit from EU freedom of movement. As a general rule, they may stay in the Schengen area for up to 90 days in any 180‑day period without a visa. Longer stays or work‑related stays require an appropriate visa or residence permit issued by the Italian authorities.

Individuals who intend to work from Italy for an extended period should therefore check both tax and immigration rules to ensure that their presence is lawful and consistent with their employment arrangement.

Social security coordination between Italy and the UK

In addition to income tax, social security contributions are an important part of the overall cost of working from Italy. Depending on the circumstances, an individual may remain affiliated to the UK social security system for a period while working abroad, or may become subject to Italian contributions if the work and presence in Italy become more substantial.

Any analysis of how long a person can work in Italy without negative consequences should therefore include social security considerations and, where necessary, reference to applicable coordination instruments or certificates.

When specialised advice is essential

There is no universal answer to the question of how long a UK resident can work in Italy without tax implications in the UK or in Italy. The outcome depends on individual circumstances and on the interaction of UK residence rules, Italian residence rules, the Italy–UK double tax treaty, immigration law and social security regulations.

Professional advice from an international tax law firm is strongly recommended when:

  • time spent working from Italy is more than occasional
  • the period in Italy may approach or exceed 183 days in a year
  • family members, home or significant assets are based in Italy
  • the employer is considering long‑term remote work arrangements from Italy
  • there is any uncertainty on residence status or on the allocation of taxing rights between the UK and Italy

A coordinated review of residence, day‑counts, employment contracts, treaty provisions and social security ensures that both the individual and the employer have a robust, defensible position and that potential double taxation or compliance risks are identified in advance.

FAQ – Working From Italy as a UK Tax Resident

How many days a UK resident can work in Italy

In practice there is no single fixed number of days that guarantees there will be no tax implications. Under Italian law, spending more than 183 days in Italy combined with other factors can trigger Italian tax residence. Under the Italy–UK treaty, spending more than 183 days in Italy can also remove the short‑term employment exception and give Italy taxing rights over your salary. Shorter periods may still have consequences if your centre of vital interests shifts to Italy or if other treaty conditions are not met.

UK tax on salary when working remotely from Italy

If you remain UK tax resident and employed by a UK company, the UK will generally continue to tax your worldwide salary and your employer is likely to operate PAYE, even while you work from Italy. At the same time, Italy may tax the portion of your salary related to work performed on its territory if the treaty conditions for exclusive UK taxation are not satisfied. In that case, relief is obtained through foreign tax credits and correct treaty application.

Application of the Italy-UK tax treaty to employment income

The Italy–UK double tax treaty allocates taxing rights over employment income and contains a specific short‑term assignment rule. Where all three conditions are met (stay not exceeding 183 days, employer not resident in the other state, remuneration not borne by a permanent establishment there), salary is taxable only in the state of residence. If any of these conditions fails, the state where the work is performed may tax the income, and the state of residence should then grant double tax relief.

Risk of becoming Italian tax resident while working from Italy

You can become Italian tax resident if you spend more than 183 days in Italy in the calendar year and have your residence or domicile there in the legal sense, or if you are registered in the municipal population register for most of the year. Even without formal registration, moving your family, home and main economic interests to Italy while working from there for most of the year can lead to Italian tax residence and worldwide taxation in Italy.

Permanent establishment risks for UK employers with staff in Italy

If a UK employer has an employee working from Italy on a long‑term basis, there may be a risk that the Italian authorities view the arrangement as a permanent establishment, especially where the employee performs key functions, negotiates contracts or effectively represents the business in Italy. This can expose the UK company to Italian corporate tax, VAT registration and local compliance obligations, so the structure of the remote work arrangement should be reviewed in advance.

Social security and working from Italy as a UK employee

Working from Italy also raises social security considerations. Depending on the duration and nature of the assignment, an individual may continue to be covered by the UK system for a period, or may need to pay social security contributions in Italy. Certificates and coordination rules may apply, and the social security position should be analysed alongside the tax and immigration analysis to avoid gaps or double contributions.

Need for professional tax advice on Italy-UK remote work

Whenever an individual plans to work from Italy for more than a short period, combine work in both countries or move their home and family to Italy while keeping a UK employment contract, professional advice becomes essential. An international tax adviser can analyse residence tests, treaty rules, payroll obligations, social security coordination and immigration requirements, and design a compliant structure that minimises the risk of double taxation and future disputes.