TLDR
Italy’s draft budget includes a 26% tax on unsold gains for residents who move abroad with at least €800,000 in financial assets.
The tax would apply from January 1, 2027, to people who lived in Italy for at least six of the previous ten years.
Payment is due within 180 days, but people moving within the EU or to cooperating countries can defer by paying 50% up front.
Government bonds get a reduced taxable base, bringing their effective rate to 12.5%.
The government expects revenue of €6.74 million a year once the scheme is fully running.
Wealthy residents who leave Italy from 2027 could face a 26% tax on gains they have not yet cashed in. The measure is part of the draft budget sent to the Chamber of Deputies on October 30.
Article 17 of the bill would apply to people who move their tax residence abroad with assets worth at least €800,000, or about $894,000. It would add Article 307-bis to Italy’s income tax law.
The tax would only apply to people who were tax residents in Italy for at least six of the ten years before leaving. It would cover moves that take effect from January 1, 2027.
Il Fatto Quotidiano listed the exit tax among the budget’s unannounced measures. The 157-article text appeared two days after the Council of Ministers approved the €26 billion package.
How the Exit Tax Would Work
The tax falls on gains built up before departure. These are calculated as the difference between each asset’s market value and its cost for tax purposes.
It targets shares, equity stakes, securities and other financial instruments, but not bank deposits. Simple partnerships and non-commercial entities are also covered.
Government bonds get a reduced taxable base of 48.08%. This brings the effective rate on them to 12.5%, the same rate Italy already applies to income from its public debt.
Italy already taxes companies and entrepreneurs who move abroad. The new rule extends this to private investors.
Payment and Deferral Rules
Departing taxpayers must pay within 180 days of the move. People moving to another EU country, or to a country with tax cooperation agreements with Italy, can delay payment until they sell.
To defer, they must pay 50% of the tax up front and provide a suitable guarantee. A long-term resident moving to Spain with a €2 million portfolio bought for €1.2 million would owe €208,000 and need to pay €104,000 at once.
Deferral lasts up to five years after a move within the EU and up to ten years for other qualifying countries. The tax is cancelled on any asset left unsold when the period ends, and advance payments are refunded.
Unsold assets are also exempt if they pass to heirs or if the taxpayer moves back to Italy. Reports do not name which non-EU countries qualify.
The rules closely follow France’s exit tax, which uses the same six-of-ten-year residence test and €800,000 threshold. France grants deferral within the EU without a guarantee.
The government’s technical report expects revenue of €3.37 million in 2027 and €6.74 million a year from 2028 through 2031. It puts net revenue at €3.37 million a year from 2032 once refunds are counted.
Federico Salmoiraghi of OFF Italy Consulting said the measure “appears poorly defined, leaving considerable room for doubt and interpretation.” He called on the government to “substantially revise the proposal or withdraw it altogether.”
Reports do not say whether the tax would reach residents under Italy’s flat-tax regime, which charges newcomers €300,000 a year on foreign income.
The bill is the last budget of Prime Minister Giorgia Meloni’s government before the 2027 general election. Parliament normally approves the budget by the end of December, and lawmakers can still amend Article 17 before the final vote.
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