Italy's 2027 Budget Bill would tax the unrealized investment gains of residents who leave with at least €800,000 in financial assets, at 26%, for any departure that takes effect from 1 January 2027. The full bill, who it would hit and what can still change are in Italy's exit tax. This page is about the other half of the decision: where to go, and what each address asks of an Italian before it treats him as gone.
The rule that decides it all: the Italian black list
Leaving Italy for tax purposes is not the same as leaving Italy. Under Article 2, paragraph 2-bis of Italy's income tax code, an Italian citizen who moves to a country on the list of the decree of 4 May 1999 is presumed still resident in Italy until he proves otherwise, Taxing.it explains. While that presumption holds, no residence is lost, so the exit tax would not even begin to apply, Fiscomania notes, and Italy keeps taxing him as a resident.
The list matters because of who is on it and who is not:
- Switzerland left it. A decree of 20 July 2023 removed Switzerland from the list from 2024, InformazioneFiscale reports. An Italian who moves to Lugano no longer has to prove the move is real. The Italian tax agency has to prove it is not.
- Monaco and the UAE are still on it. An Italian who moves to Monaco or Dubai carries the burden of proving the move: a real home, life and interests in the new country, and not in Italy.
For a foreign national leaving Italy, the presumption does not apply: it is written for Italian citizens only.
Switzerland: tax-free gains and the lump sum
Switzerland does two things no Italian address does. It taxes no capital gain on private movable assets, shares and funds included, under article 16 of the federal tax act. And most cantons still offer the lump sum: a foreigner who does not work in Switzerland can be taxed on his spending in place of his income and wealth.
The federal floor of the lump sum is CHF 434,700 a year of taxable spending. The cantons set their own: CHF 434,700 in Ticino and Graubünden, CHF 425,194 in Geneva, CHF 415,000 in Vaud and CHF 250,000 in Valais, according to the Federal Tax Administration. Zurich, Schaffhausen, Appenzell Ausserrhoden and Basel-Stadt abolished it. Its users are fewer than they were: 4,557 people paid CHF 821 million in lump sum tax at the end of 2018, and 3,478 used it in 2022, with Valais at 841, Ticino at 725 and Vaud at 706 in Blick's survey of the cantons.
Lugano
Lugano is the natural first stop: the same language, the same lake country, a short drive from Milan, and a canton that keeps the lump sum. On a salary, $1M keeps $647K. It ranks 9th on the Patrician.ch 100.
St. Moritz and Gstaad
For a family that does not need to work locally, the Alpine resorts in lump sum cantons are the other classic choice. St. Moritz in Graubünden ranks 17th and Gstaad in Bern ranks 14th. On a salary, they keep $723K and $635K of $1M.
Zug
For an Italian who will keep working, Zug keeps $787K of a $1M salary and ranks 11th.
Monaco: no income tax, and the burden of proof
Monaco levies no personal income tax on its residents, French nationals excepted, and no wealth tax. A residence permit takes a home in the principality and a reference from a Monegasque bank confirming sufficient funds. The government sets no fixed amount. For an Italian citizen, Monaco's place on the black list means keeping the record of a real life there: the home, the days, the family, the clubs, the doctors. Monaco ranks 3rd on the Patrician.ch 100.
Dubai: no income tax, further away
Dubai levies no income tax on individuals and keeps $1M of a $1M salary. It ranks 2nd. Like Monaco, it is on Italy's black list, so the same burden of proof applies to an Italian citizen.
The exit tax deferral is not available everywhere
The bill lets the tax wait, against 50% paid up front and a guarantee, only for a move to an EU country or to a country that exchanges tax information with Italy on the EU standard. Switzerland, Monaco and the UAE are outside the EU, and the list of qualifying countries is left to a decree of the Ministry of Economy and Finance that has not been published, Fiscomania notes. Until it is, no one can say whether a move to Lugano or Monaco would qualify for deferral.
Staying instead: the other side of the ledger
For comparison, Milan itself keeps $553K of a $1M salary and ranks 52nd. A foreigner arriving in Italy now pays a flat €300,000 a year on foreign income, up from €200,000, and after 6 of the 10 years would meet the exit tax test on leaving. The full ranking from an Italian start is in moving from Italy, the Swiss lump sum against Italy's flat tax in their head to head, and every place against your own position in the calculator.
Sources
- Il Sole 24 Ore, the exit tax in the Budget Bill
- Fiscomania, article 307-bis TUIR
- InformazioneFiscale, Switzerland off the black list
- Fiscomania, Monaco and the black list
- Taxing.it, the black list countries
- Swiss Confederation, Federal Act on Direct Federal Taxation, art. 16
- Swiss Federal Tax Administration, taxation on expenditure
- Swiss Federal Department of Finance, lump-sum taxation
- Blick, the cantons' lump sum count
- Government of Monaco, tax in Monaco
- Government of Monaco, residence permits
- 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.