What is Italy's proposed exit tax for individuals?

It is a tax on financial income accrued but not yet realised when an individual moves their tax residence out of Italy. Article 17 of the 2027-2029 budget bill (A.C. 3174) would add Article 307-bis to Italy's consolidated income tax code (Legislative Decree 117/2026).

Who would it apply to?

Individuals who were Italian tax residents for at least six of the ten tax periods before the move, if the total fair market value of the assets concerned is at least EUR 800,000 and the move means Italy loses the right to tax that income.

Is the EUR 800,000 threshold about gains or assets?

Assets. The explanatory report says the threshold refers to the total value of the assets and rights concerned, not to the amount of unrealised gains.

When would the tax be due?

Within 180 days from the date the loss of Italian tax residence takes effect. People moving to an EU state, or to a country with adequate information-exchange and tax-collection assistance agreements, could defer payment by paying a 50% advance and providing a guarantee.

Does it already apply?

No. It would apply to losses of residence effective from 1 January 2027, but the bill is still before Parliament and the text can change.

What if I move back to Italy?

Under the proposed text, with deferral, no tax is due on assets not sold if tax residence returns to Italy during the deferral period, and excess amounts paid are refunded.

Italy's proposed 2027 exit tax for people leaving

Italy's 2027 budget bill proposes an exit tax for individuals who move their tax residence abroad from 2027. It would tax unrealised financial gains of people resident for at least six of the last ten years whose relevant assets are worth at least EUR 800,000. The text is still before Parliament and may change.

The measure is Article 17 of the budget bill for 2027-2029, presented to the Chamber of Deputies on 30 October 2026 (A.C. 3174). If you are planning a move from Italy to the US, also check our guide to the US-Italy totalization agreement.

TL;DR

What: tax on financial income accrued but not realised when you leave Italy.
Who: individuals resident in Italy for 6 of the last 10 tax periods.
Threshold: total value of the assets concerned of at least EUR 800,000.
Payment: within 180 days, or deferred with a 50% advance and a guarantee (EU and countries with adequate agreements).
From: losses of residence effective 1 January 2027, if the rule is passed.

What would change

Article 17 would insert into Italy's consolidated income tax code (Legislative Decree 117 of 19 June 2026) a new Chapter VI-bis with Article 307-bis, on the "exit taxation of persons not carrying on commercial businesses".

According to the government's explanatory report, the goal is to preserve Italy's right to tax financial income accrued while a person was resident in Italy and not yet realised when they move abroad.

Who would be taxed

All conditions must be met:

you move your tax residence out of Italy;
you were resident in Italy for at least six of the ten tax periods before the move;
the total fair market value of the assets and rights concerned is at least EUR 800,000 on the last day of the tax period before the one in which the loss of residence takes effect;
Italy loses its power to tax that income.

The last point matters: the report says income that Italy can still tax, including under double tax treaties, is outside the charge. The same rules would also cover non-commercial simple partnerships (società semplici) and non-commercial entities.

How it would be calculated

The taxable base is the sum of the positive differences between the fair market value of each asset or right, on the last day of the tax period before the move, and its tax cost. Income is taxed under the ordinary rules for its type: for financial capital gains, Italy's Revenue Agency lists a 26% substitute tax.

For Italian government bonds and equivalent instruments, only 48.08% of the income counts: the report explains this keeps the reduced 12.5% rate that applies to them.

Payment and deferral

The tax would be due within 180 days from the date the loss of residence takes effect. If you move to another EU state, or to a non-EU state with adequate agreements on information exchange and mutual assistance in recovering tax claims, you could opt to defer payment by paying a 50% advance within the same deadline and providing a guarantee.

Deferral would last five tax periods for moves within the EU and ten in the other cases. If you sell an asset meanwhile, tax is due on the lower of the gain accrued at exit and the gain actually realised; for gifts or transfers to family members or controlled companies, the gain accrued at exit applies. The advance is credited against the tax due.

When no tax would be due

With deferral, no tax would be due on:

assets not sold within the deferral period;
assets passed on death during that period;
assets not sold if you move your tax residence back to Italy during that period.

Excess amounts paid would be refunded. Implementing rules are left to a decree of the Minister of Economy and Finance.

What to do now

The text can still change in Parliament. If you plan to leave Italy around 2027 and your investment portfolio is close to the threshold, follow the budget bill and have a professional review your position, including the relevant tax treaty.

FAQ

Is it law yet? No, it is a proposal in the 2027-2029 budget bill.

Is the threshold on gains? No, on the total value of the assets concerned.

How long to pay? 180 days, or deferral with a 50% advance and a guarantee.

What if I return? With deferral, no tax on assets not sold.

General information on a bill, not tax or legal advice.

Sources

Consulted on 10 November 2026.