Italy's draft 2027 budget, sent to the Chamber of Deputies on 30 October, includes a 26 per cent tax on unrealised gains when wealthy residents move their tax residence abroad, IMI Daily reported on 31 October. Article 17 of the bill would apply to transfers taking effect from 1 January 2027. According to the report, the measure was not announced in advance.
The tax would cover people who were tax resident in Italy for at least six of the ten tax periods before leaving and who hold assets and rights worth at least €800,000. It targets financial assets such as shareholdings, securities and financial instruments, and the gain is the difference between each asset's market value and its tax cost. Government bonds would carry an effective rate of 12.5 per cent. Payment would be due within 180 days of the move.
People moving to another EU country, or to a country with a tax cooperation agreement with Italy, could defer payment until the assets are sold if they pay 50 per cent upfront and provide a guarantee. The deferral would last up to five tax periods for EU moves and up to ten for other qualifying countries; the tax would lapse on assets still unsold at the end, on assets passed to heirs, or if the person becomes Italian tax resident again. In IMI Daily's example, a resident moving to Spain with a €2 million portfolio bought for €1.2 million would owe €208,000, paying €104,000 upfront.
The government's technical report estimates revenue of €3.37 million in 2027 and €6.74 million a year from 2028 to 2031. According to IMI Daily, reports do not say whether the tax would apply to people leaving Italy's flat-tax regime for new residents, which charges €300,000 a year on foreign income for those who moved to Italy from 2026. France applies an exit tax with the same six-of-ten residence test and the same €800,000 threshold.
What it means
The exit tax is a proposal in a draft budget, not yet law. Parliament normally approves the budget by the end of December and can amend Article 17 before the final vote; as drafted, it would affect only moves that take effect from 1 January 2027.
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