Yes. Italy plans an exit tax on individuals, the first it would aim at private people. Article 17 of the 2027 Budget Bill would add a new article 307-bis to Italy's income tax code and charge 26% on the investment gains a resident has built up but never sold, at the moment that resident moves abroad. Until now Italy taxed departures only for businesses.
It is a proposal. The Council of Ministers approved the bill on 28 October and its presentation to Parliament was authorized on 30 October. Parliament must pass the budget by 31 December, and any article can be amended or dropped on the way. If it passes as written, it applies to every loss of Italian tax residence that takes effect from 1 January 2027.
Who would pay
The bill sets 3 conditions, and all must hold:
- You were tax resident in Italy for at least 6 of the 10 years before you leave. Nationality plays no part: an Italian and a foreigner who has lived in Italy are treated alike.
- Your financial assets are worth at least €800,000 in total, valued on 31 December of the year before the move. Il Sole 24 Ore reports that bank deposits do not count toward it.
- The move costs Italy its right to tax those gains, which under most of Italy's tax treaties it would.
The same rules reach simple partnerships (società semplici) and non-commercial entities, Fiscomania notes, although the text does not say how the 6 of the 10 years test applies to them.
What it would tax
The base is the gain on each asset: its value on the valuation date minus what it cost for tax purposes. It covers shares, including stakes in private companies, listed and unlisted securities, investment funds, derivatives, precious metals and crypto. Real estate, dividends and interest stay outside. There is no allowance: once the €800,000 threshold is crossed, the tax falls on the first euro of gain, and a loss on one holding does not reduce the gain on another.
The rate is 26%, the ordinary Italian rate on financial gains. Italian and other qualifying government bonds count at 48.08% of the gain, an effective 12.5%. Crypto is taxed at 33% when sold in Italy, and commentators note the text does not make clear which rate the exit tax would apply to it.
When you would pay
The tax is due within 180 days of the date your residence ends. A move to another EU country, or to a country that exchanges tax information with Italy on the EU standard, can defer it on 2 conditions: pay 50% up front and lodge a guarantee. The deferral runs 5 years for an EU destination and 10 years for the others. Within that window the tax falls due on any asset you sell or give away. If you still hold the asset when the window closes, if it passes on your death, or if you move back to Italy, no tax is due on it and the 50% paid up front is refunded.
A worked example
A resident of Milan for the last 10 years holds a portfolio of listed shares worth €2,000,000 on 31 December, bought for €1,200,000. He moves abroad and his Italian residence ends on 1 January 2027. The gain is €800,000, and at 26% the bill is €208,000, due within 180 days. Moving to an EU country, he could pay €104,000 now and the rest only if he sells within the deferral window. Outside the EU, the same deferral depends on the destination being on the list of cooperating countries the Ministry of Economy and Finance has yet to publish. Otherwise he pays the full €208,000 within 180 days.
The timing trap of the year 2026
Italy tests residence year by year. Someone who leaves late in 2026 may still count as an Italian resident for the whole of 2026 and become non-resident only from 2027, Taxing.it points out, which would bring the move inside the new rules with the portfolio valued on 31 December 2026. Anyone planning to leave around the turn of the year should have the residence date checked against the final text before relying on the move being outside it.
The new residents' flat tax
Italy charges wealthy newcomers a flat tax on their foreign income, raised to €300,000 a year from €200,000 for those arriving from 2026. IMI Daily notes that reports on Article 17 do not say whether the exit tax would reach departing flat tax residents, and that a flat tax resident who arrived in 2021 would already meet the 6 of the 10 years test on leaving in 2027. For a family weighing Italy against Switzerland's lump sum, that open question now sits on the exit side of the decision.
Why the revenue is so small
The government's technical report puts the gross yield at €6.74 million a year, and €3.37 million in 2027, Il Sole 24 Ore reports. The same paper notes that the taxpayers it could reach hold about 73% of Italy's financial wealth. A tax that raises so little against so large a base reads less as revenue than as a toll on leaving, and Pagella Politica calls it a very particular wealth tax.
Will it survive EU law
Exit taxes inside the EU have a history in court. In de Lasteyrie du Saillant, case C-9/02 decided on 11 March 2004, the EU Court of Justice held that France's original exit tax on individuals breached the freedom of establishment. The Italian bill answers that line of cases with its deferral, but conditions it on the 50% payment and a guarantee. On 15 October an Advocate General's opinion in case C-430/25, on Poland's exit tax, questioned taxing gains that built up before the person became resident, Fiscomania reports. The Court has not ruled.
How Italy would compare
With this article, Italy would join the European countries that already tax departures, among them France, Germany, the Netherlands, Norway and Spain. The United Kingdom has none. Every country's rule, rate and deferral is set out in exit tax by country, and Italy's current position in leaving Italy.
Where Italians who leave are looking
The nearest answers sit on Italy's borders. Lugano, across the border from Milan, ranks 9th on the Patrician.ch 100 and taxes $1M of income at 35%. Monaco levies no income tax on residents and ranks 3rd. Further out, Zug taxes $1M at 21% and Dubai at 0%. Milan itself ranks 52nd. Rank any of them against your own position in the calculator or on the Patrician.ch 100.
Sources
- Il Sole 24 Ore, the exit tax in the Budget Bill
- ItaliaOggi, exit tax extended to individuals
- Fiscomania, article 307-bis TUIR
- Pagella Politica, the technical report
- AX Fiduciaire, the bill's timeline
- Taxing.it, timing and residence
- IMI Daily, flat tax residents and EU case law
- KPMG, Italy's flat tax raised
Figures come from the Patrician.ch 2026 model: indicative headline brackets for a non-US single filer, current to October 2026. Research, not tax, legal or immigration advice.