Budget Act

Tax on wealthy people leaving Italia. Here’s who pays and how much

Budget Bill: introduction of an exit tax on financial assets worth over 800,000 euros

Panoramica dell'Aula della Camera dei Deputati,  Roma.  (ANSA/Maurizio Brambatti)

2' min read

Translated by AI
Versione italiana

2' min read

Translated by AI
Versione italiana

A key feature of the new Budget is the introduction of a full-fledged ‘exit tax’ (exit tax), designed to tax financial gains accumulated in Italia by those who decide to move abroad.

How it works and who it applies to

The legislation introduces Article 307-bis into the Consolidated Income Tax Law (TUIR). The measure targets individuals, unincorporated partnerships and non-commercial entities that hold financial assets of at least €800,000 (excluding bank deposits), comprising shares, equity interests and other financial instruments.

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There is also a time-related prerequisite for the tax to apply: the taxpayer must have been resident for tax purposes in Italia for at least 6 of the last 10 years prior to the move.

The tax is levied at the standard rate of 26 per cent on financial income and on ‘accrued’ capital gains (i.e. the increase in value that securities have gained over time, even if they have not yet been sold). For government bonds only, a tax relief is available: the basis on which the tax is calculated is reduced to 48.08 per cent.

Payment rules and the ‘deferred’ option

As a general rule, the balance must be paid within 180 days of the change of residence. However, for those moving to a European Union country or a cooperating state, the law provides an option: to defer payment until the securities are actually sold.

To be eligible for the deferral, you must:

  • Pay a deposit of 50 per cent of the tax due immediately.
  • Provide suitable security.

The deferral does not last indefinitely: for transfers within the EU, the tax will only be due if the assets are sold within 5 years; for cooperative non-EU countries, this period is extended to 10 years. If the securities are not sold during this period, if the taxpayer transfers them by way of inheritance following death, or if they return permanently to Italia, the tax is not due and any sums paid in advance as a provisional payment will be refunded.

Estimates of revenue for the State

According to technical calculations based on ISTAT data and tax returns, the taxpayers potentially affected represent the section of the population that holds around 73 per cent of Italy’s financial wealth.

The State estimates gross revenue, once the scheme is fully operational, of 6.74 million euros per year (with an initial intake of 3.37 million in 2027 due to the 180-day timeframe). As a precautionary measure, the technical report considers that, from the fifth year onwards (from 2032), refunds of 3.37 million per annum could be paid out to those who did not ultimately sell their assets, leaving a stable net benefit for the public purse.

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