---
title: Italy's 2027 Budget Would Tax Wealthy Residents 26% on Unsold Gains When They Move Abroad
description: Italy's 2027 budget adds a 26% exit tax on unsold gains for residents leaving with €800,000 or more invested. Who pays, when and how deferral works.
author: Dr Marina Nani (Editor-in-Chief)
date: 2026-11-02T07:02:55.391Z
updated: 2026-11-02T07:02:55.405Z
canonical: https://www.richmanmagazine.com/article/italy-exit-tax-2027-unrealised-gains
image: https://cdn.nanimediahouse.com/pexels-37732117.webp
categories: Money
content_type: News
region: Italy
publication: Rich Man Magazine
about:
  - type: Place
    name: Italy
---

If you have lived in Italy for six of the last ten years and hold €800,000 or more in shares, funds or other financial assets, moving your tax residence abroad from 1st January 2027 could cost you 26% of every gain you have not yet cashed in. The measure sits in Article 17 of the 2027 budget bill, which Prime Minister Giorgia Meloni's cabinet approved on 28th October. Italian journalists found it when the full text of the bill reached parliament on 30th October.

The headline numbers of the budget were already public. Reuters reported that the package is worth €26 billion in tax cuts and spending, the last before a general election due in 2027, with banks and insurers contributing more than €5 billion and energy companies and the gambling sector €700 million each. The exit tax was not among the measures ministers presented.

## How Italy's Exit Tax Is Calculated

The €800,000 figure is an entry test, not an allowance. It applies to the market value of your financial assets on 31st December of the year before your residence changes. Cross it and the tax falls on your gains, asset by asset, from the first euro.

For each holding, the gain is the difference between its market value on that date and what it cost you for tax purposes. Only the holdings that have risen count. The Italian news site Fanpage gives a worked example: shares bought in 2022 for €100,000 and worth €120,000 at the end of 2026 produce a taxable gain of €20,000, so €5,200 at 26%. Italian government bonds keep their lower 12.5% rate.

The test is your loss of Italian tax residence, not your nationality. A British or American investor who has lived in Milan for seven years is in the same position as an Italian citizen. Payment is due within 180 days of the date your residence moves.

## Deferral for Moves Within the EU

If you move to another EU country, or to a country with an agreement to share tax information with Italy and help collect its debts, you can pay half within the 180 days and defer the rest. The deferral runs for five tax years after an EU move and ten after a move to another qualifying country. You also have to provide a guarantee.

What happens next depends on what you do with the assets:

- **You sell during the deferral period:** the tax is worked out on the lower of the original paper gain and the gain you actually made.
- **You keep the assets for the whole period:** no tax is due and Italy refunds the half you paid.
- **You return to Italy, or the assets pass on your death:** the same refund applies to assets you have not sold.

On a large portfolio, that 50% payment still has to come from somewhere. The tax lands on gains you have not turned into cash, so you may have to sell investments to pay a bill on investments you never sold.

## A Tax That Raises €6.74 Million a Year

The government's own technical report puts the revenue at about €13.47 million a year in full. Since most leavers will pay only the first half, the report halves that to €6.74 million a year from 2028 to 2031, and €3.37 million in 2027. Set against a €26 billion budget, the money is almost nothing.

The purpose shows in the mechanics. Under Italy's tax treaties, most of which follow the OECD model, gains on shares are taxed by the country where the seller lives. Once you move, Italy loses any claim on the growth your portfolio built up while you lived there. The exit tax takes Italy's share at the border, and Fanpage describes it as a way to discourage wealthy residents from leaving at all.

## Italy's €300,000 Flat Tax for Wealthy Newcomers

The same government charges the rich to come in. Since 1st January 2026, new residents can pay a flat €300,000 a year on all their foreign income, up from €200,000. Reuters reported that nearly 1,500 people used the regime in 2023 and that it raised €315 million between 2020 and 2023. Cristiano Ronaldo used it during his years at Juventus.

So Italy [sells residence to wealthy foreigners](https://www.richmanmagazine.com/article/dubai-golden-visa-aed-2-million-property-europe-closes) at €300,000 a year and now proposes a charge on the way out. The reports on Article 17 do not yet say how the exit tax would apply to flat-tax residents, whose foreign income Italy taxes through the fixed payment.

## The French Model Behind the €800,000 Threshold

Italy did not invent these numbers. France's exit tax applies to people who have been French tax residents for six of the previous ten years and hold shares worth more than €800,000, or more than half of a company. France also defers the tax for moves within the EU. Italy's draft uses the same residence test and the same value threshold.

Germany, Spain, the Netherlands and Norway also tax unrealised gains when residents leave, each with its own thresholds and deferral rules. The United States goes further and taxes citizens who renounce their citizenship.

## What Happens Next in Parliament

The text is a draft. Both chambers of parliament have to pass the budget by 31st December 2026, and the threshold, rates or deferral rules could change before then.

One detail matters if you are [planning a move this winter](https://www.richmanmagazine.com/article/relocation-s-cost-when-moving-to-the-world-s-best-countries-with-high-quality-of-life). The rules apply when your loss of tax residence takes effect from 1st January 2027, not when you physically leave. Italy usually sets tax residence for a whole year, so if you leave in late 2026 but count as resident for 2026, Colin Jamieson, a lawyer who advises on Italian tax at Taxing.it, points out that you could still fall inside the new rules. Article 17 also contains no rebasing, so gains built up over decades before the law existed would be taxed in full.

If any of this applies to you, the time to take advice is before the bill passes, not after.

## FAQ

**Q: How does an exit tax work?**
An exit tax treats your investments as if you sold them on the day you stop being a tax resident of a country. You pay tax on the gains built up while you lived there, even though you still own the assets and have received no cash. Most countries apply it only above a value threshold and after a minimum number of years of residence, and many let you defer payment if you move within the European Union.

**Q: Which countries have an exit tax?**
In Europe, France, Germany, Spain, the Netherlands, Denmark, Austria and Norway tax unrealised gains when residents move abroad, and Belgium introduced one alongside a new capital gains tax in 2026. Canada applies a departure tax on emigration. The United States taxes citizens who renounce their citizenship and long-term green card holders who give up their status. Thresholds, rates and deferral rules differ in each country.

**Q: Who has to pay the US exit tax?**
The US expatriation tax applies to citizens who renounce their citizenship and to long-term residents who give up a green card held in at least eight of the previous fifteen years. You are caught if your net worth is $2 million or more, if your average annual income tax over the previous five years exceeds a threshold the IRS adjusts each year, or if you cannot certify five years of US tax compliance. Gains above an annual exclusion amount are then taxed as if you had sold everything the day before you left.