Italy's draft budget adds a 26% exit tax for residents leaving with €800,000 or more
Article 17 of Italy's 2027 budget bill would tax unrealised gains when long-term residents move abroad from 1 January 2027. On 5 November the deputy economy minister said Rome is open to changes. What the draft covers, and what it leaves unclear.
On 30 October 2026, the text of Italy’s 2027 budget bill reached the Chamber of Deputies with a measure the government had not trailed: an exit tax for private individuals. Article 17, which would insert a new article 307-bis into the consolidated income tax code (MySolution), would charge 26% on the unrealised gains of residents who move their tax residence abroad holding assets worth at least €800,000.
On 5 November, Deputy Economy Minister Maurizio Leo told Reuters that Italy “is happy to consider proposals to improve the exit tax”. He did not say what might change.
Who the draft would catch
The tax would apply to transfers of residence taking effect from 1 January 2027, and only to people who were Italian tax resident for at least six of the ten tax periods before leaving. The base is the gain accrued before departure: market value less tax-recognised cost, asset by asset, with losses ignored. Payment falls due within 180 days of the move.
According to IMI Daily, which reviewed the bill and its technical report, the measure targets financial assets such as shareholdings and securities. Italian government bonds get a reduced base that brings their effective rate to 12.5%. Simple partnerships (società semplici) and non-commercial entities are also in scope, which matters because the società semplice is a common holding vehicle for Italian family wealth.
Italy already taxes companies and entrepreneurs who emigrate. Until now, private investors could leave without a deemed disposal.
Deferral, at a price
On IMI Daily’s reading of the text, a person moving to another EU state, or to a country with which Italy has tax cooperation agreements, could defer payment until the assets are sold. The condition is that half the tax is paid up front and a guarantee is lodged. Deferral would run for up to five tax periods after an EU move and up to ten after a move elsewhere. Assets still unsold at the end, or passed to heirs in the meantime, would escape the charge, and the tax would be refunded if the person returns to Italy.
The published accounts do not list the qualifying non-EU countries. For families looking at Switzerland or the UAE, that list decides whether the bill can be deferred or must be paid in full within six months.
The six-in-ten residence test and the €800,000 threshold both match France’s exit tax under Article 167 bis of the General Tax Code. France, however, grants deferral within the EU automatically and without a guarantee. In 2004 the EU Court of Justice ruled in de Lasteyrie du Saillant (Case C-9/02), a case about France’s earlier exit tax, that making deferral conditional on guarantees was itself a restriction on freedom of establishment.
Small yield, loud reaction
The technical report, as reported by IMI Daily, puts revenue at €3.37 million in 2027 and €6.74 million a year from 2028 to 2031. The Istituto Bruno Leoni called the measure a “disguised wealth tax”, Reuters reported. Antonio Tomassini of DLA Piper in Milan told the agency that every one of his clients had been in touch, and asked the government to confirm the tax would not reach people who moved to Italy under preferential regimes until those regimes expire.
That question is still open. New residents can pay a flat €300,000 a year on foreign income, and the published reports do not say how Article 17 would treat them when they leave. Someone who arrived under the regime in 2021 would already meet the six-year test in 2027.
Parliament normally passes the budget by the end of December, and Article 17 can be amended before the final vote.
What it means for family offices
Italy has been a destination for mobile families, and part of its appeal was that leaving cost nothing. The draft changes the calculation for anyone resident six years or more: a later move, to Switzerland or the Gulf in particular, could carry an immediate 26% charge on paper gains held directly or through a società semplice. Families with Italian residence and a possible move in view will want their advisers to watch three points as the bill goes through Parliament: whether flat-tax residents are carved out, which non-EU countries qualify for deferral, and whether the guarantee requirement survives EU law scrutiny.
Sources: Reuters via Euronext (5 November 2026); IMI Daily (31 October 2026); MySolution (6 November 2026).