Italy’s 2027 Budget Bill proposes individual exit tax

Article 17 would insert Article 307-bis into the Income Tax Code. It would apply where an individual had been Italian tax resident for at least six of the preceding ten tax years, a departure causes Italy to lose taxing rights over the relevant income, and the aggregate normal value of the specified assets and rights is at least €800,000. The measure is proposed law and may change during parliamentary review.^[1][2]

Specified financial gains

The proposal refers to financial-income categories including shareholdings, securities, crypto-assets, fund units, foreign currency, precious metals, derivatives and claims. Directly held real estate is outside the described scope. The tax base is the sum of positive asset-by-asset differences between normal value at the end of the tax year before residence is lost and tax acquisition cost. Certain qualifying government bonds would be included at 48.08% of the gain.^[2]

Payment and deferral route

The draft generally requires payment within 180 days after residence loss takes effect. For moves to an EU Member State or another jurisdiction meeting specified information-exchange and tax-recovery conditions, the taxpayer could defer the balance until disposal, but would pay 50% upfront and provide an acceptable guarantee. The proposed deferral period is five tax years for EU moves and ten years for other qualifying destinations.^[2]

Rate and commencement remain conditional

The proposal would apply where loss of Italian residence becomes effective from 1 January 2027. The bill taxes the referenced income categories under their ordinarily applicable rules. The rate and treatment therefore require case-by-case confirmation, and final legislation and implementing rules remain outstanding.^[2]

Potentially affected individuals and groups supporting internationally mobile owners or executives should map residence history, asset classifications, tax basis, destination and liquidity before any move. They should not accrue a final liability solely from the proposal. Open questions include normal-value mechanics, the precise loss of Italian taxing rights, the final rate, implementing procedures and interaction with other residence regimes.^[2]