For years, Italy has pursued a policy of tax attractiveness, positioning itself as a preferred destination for high-net-worth individuals and for Italians wishing to return from abroad, supported by some of the most competitive preferential regimes in Europe.
The 2027 Budget Bill, however, may change that picture: the draft seeks to introduce an exit tax on individuals, namely a tax on accrued but as yet unrealised capital gains, applicable to taxpayers who intend to transfer their tax residence abroad.
It should be stressed at the outset that the parliamentary process is still under way and that the text may undergo significant amendments, including the possible withdrawal of the measure.
What the proposal envisages
The measure would apply to individuals who have been tax resident in Italy for at least six of the ten tax periods preceding the transfer abroad. In particular, the charge would apply to financial income within the meaning of Article 76 of Legislative Decree No. 117/2026, including crypto-assets, with effect from 1 January 2027.
In more detail, upon such a transfer, financial income would be deemed to be realised in an amount equal to the difference between the normal value (as at the date of the last day of tax residence in Italy) and the tax-recognised cost of the relevant assets, provided that the normal value of those assets exceeds EUR 800,000.
From a strictly tax perspective, the levy should follow the rate applicable to the relevant category of income (i.e. 26 per cent) and, in the specific case of government securities, should be computed on 48.08 per cent of their amount, thereby resulting in an effective charge of 12.5 per cent.
In the case of transfers to another Member State of the European Union, or to States that ensure an adequate exchange of information, payment of the tax could be deferred for up to five tax periods, subject to an advance payment of 50 per cent.
The loss of taxing rights
It should be noted that the chargeable event would appear to be the loss of Italy’s taxing rights, including as a result of the application of conventions for the avoidance of double taxation. It would follow that, even where tax residence is transferred abroad, the retention of Italian-source income could give rise to concurrent taxing rights under the relevant treaty and, consequently, prevent Italy from applying the exit tax.
The new-resident regime: issues still to be resolved
As regards the Italian “res non-dom” regime, according to a preliminary reading put forward by practitioners in the field — consistent with the approach adopted when assessing the compatibility of exit taxes with EU law — latent gains on foreign assets covered by the substitute tax would remain absorbed by that tax. The exit tax would therefore apply only in residual cases: gains on assets located in Italy, which are already taxable under the ordinary rules, and gains on assets situated in foreign States excluded from the substitute-tax election.
It would follow that, under the current wording, the new-resident regime should not be hollowed out by the introduction of the exit tax. The measure appears likely to affect mainly taxpayers with a well-established presence in Italy. As this interpretation has not yet been expressly reflected in the legislative text, it would nonetheless be appropriate for the coordination between the two sets of rules to be clarified during the parliamentary process.
A picture that is still evolving
As noted above, the proposed new exit tax has given rise to concern among both current and prospective non-domiciled residents. The provision is, however, contained in the 2027 Budget Bill, whose parliamentary scrutiny has only just begun and whose text may still be amended. Against the backdrop of a presumably modest revenue yield, extending the measure to new residents would risk undermining the credibility and stability of a regime whose attractiveness rests on predictability.
It is also worth recalling that, in the previous Budget Law, the legislature initially sought to tighten the conditions for access to the dividend exemption and the participation exemption, only to reverse course a few weeks later.
Fidinam can help
This article was edited by Pietro Cumpostu and Filippo Tornambè, Partners at Fidinam Italia.
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This article is a professional English translation of the Italian text published by Fidinam Italia on 5 November 2026 on Fidinam blog.
