Moving from Italy to Switzerland before the Italian exit tax

If you are tax resident in Italy and the bill is passed as drafted, the date that decides your exit tax is not the day you move to Switzerland. It is 31 December 2026: your financial assets would be valued on that day, and the gain taxed if your Italian residence ends from 1 January 2027. Whether payment can then be deferred is an open question for Switzerland, and the answer changes the cash you need within 180 days.

What the bill proposes, and why 31 December 2026 is the date that matters

Article 17 of the draft 2027 budget bill does not create a stand-alone regime. It inserts a new Chapter VI-bis and an article 307-bis into the new Income Tax Code (TUIR), the Legislative Decree of 19 June 2026, no. 117, under the rubric "Imposizione in uscita dei soggetti che non esercitano imprese commerciali", that is, taxation on exit of persons who do not carry on a commercial business. If you are used to the old TUIR articles 67, 68 and 166, the numbering will not help you: the new code is organised differently. The rule would apply to losses of Italian tax residence taking effect from 1 January 2027.

The single most consequential feature is the valuation date. The fair value of the assets is taken on the last day of the tax period preceding the one in which the loss of residence takes effect. For a move effective in 2027, that is 31 December 2026. It is not the date on which you sign a lease in Geneva, not the date of your AIRE registration and not the day you sell. A large part of the Italian press describes this wrongly, as a valuation at the date of departure. The practical consequence is that by the time you leave in 2027, the value on which the tax is computed is already fixed.

The tax rate is 26%, but the article itself does not write that figure. It refers to taxation "under the rules ordinarily applicable", and the technical report confirms that this means the ordinary substitute tax on miscellaneous financial income, which is 26%. For certain government bonds, including those of states on the information-exchange white list, the taxable base is reduced to 48.08%, which brings the effective rate back to the customary 12.5%.

This is an unvoted bill. The Council of Ministers approved it on 28 October 2026 and the presentation to Parliament was authorised on 30 October 2026. We have found no primary source confirming a formal filing at the Chamber of Deputies, so we cite no bill number. A vote is expected by the end of December 2026, and Parliament can amend the text. Everything below describes the draft, and we say so where a point is not settled.

Whether the rule reaches you

Three conditions, all of which must be met. First, you must have been tax resident in Italy for at least 6 of the 10 tax periods preceding the one in which you lose residence. Second, the aggregate fair value of the assets in scope must reach €800,000. This is a threshold on value, not on gain, and it works as an all-or-nothing entry ticket. Third, the transfer must actually cost Italy its power to tax. Nationality is irrelevant: the test is residence. A British, American or German national who has lived in Italy for six years or more is treated exactly like an Italian.

What sits inside and outside the perimeter matters more than the headline threshold, and the text is drafted in terms of "assets and rights", not "investments".

The calculation is made asset by asset and only the positive differences are added up. As drafted, an unrealised loss on one position does not reduce the gain on another. Non-commercial entities and società semplici are also caught. If your wealth is in a company, a trust or a fund wrapper, the first question is what the bill looks through and what it does not, and the text does not answer all of it.

Residence itself is a question of fact. Since the reform in force from 1 January 2024, you are resident if for most of the tax period (183 days, 184 in a leap year) you have in Italy your civil-law residence, your domicile or your physical presence; the criteria are alternative. Domicile means the place where your personal and family relations mainly develop. The AIRE registration is only a simple presumption. To see whether you are inside the rule and by how much, use the detailed analysis of the Italian exit tax for 2027, then run your own figures in the exit tax calculator.

The deferral, and the open question about Switzerland

The bill offers an alternative to paying immediately. In principle you can opt for deferral by paying 50% in advance and providing an adequate guarantee, whose nature, form and amount the text does not define. The deferral lasts up to 5 tax periods for destinations in the EU and up to 10 for those outside it. In this regime only, a "lesser of" rule applies: the tax is computed on the lower of the latent gain and the gain actually realised, and only on sales for consideration. A gift, or a transfer to a controlled company or a family member, brings back the whole latent gain.

Access to deferral depends on a cumulative test. The destination state must be bound to Italy by agreements allowing an adequate exchange of information and by mutual assistance in the recovery of tax claims of a scope analogous to Directive 2010/24/EU. The text names no state and refers to no decree that would publish a list. The test is functional, and Switzerland is therefore assessed on its own facts.

On the first limb, Switzerland looks plausible: the protocol of 23 February 2015 amended article 27 of the Italy–Switzerland convention, providing exchange of information on request to the OECD standard, in force since 13 July 2016. The second limb is doubtful. Switzerland excluded recovery assistance when it joined the multilateral Convention on Mutual Administrative Assistance, and we found no equivalent clause in the 1976 Italy–Switzerland convention, whose consolidated text of 13 July 2016 we read in full.

So we do not write that Switzerland is admitted, and we do not write that it is excluded. The point is open, the risk is real, and if Switzerland were not admitted the whole tax would be due within 180 days of the date on which the loss of residence takes effect, without deferral and without the "lesser of" clause. For a client with a large unrealised gain, that is the figure to plan liquidity around. Our page on the Swiss deferral question sets out the argument and the scenarios in more detail.

Two kinds of client, two routes

Switzerland does not offer a single regime for newcomers. What decides the route is whether you will work there, and that question comes before any comparison of tax rates.

The rentier with no gainful activity in Switzerland

If you will live off your assets and carry out no gainful activity in Switzerland, expenditure-based taxation (the lump sum, or forfait fiscal) is on the table. Under the federal rules (article 14 of the Federal Direct Tax Act, AFC circular no. 44 of 24 July 2018) you must not be a Swiss national, you must be arriving for the first time or returning after at least ten years away, and neither you nor your spouse may exercise any gainful activity in Switzerland, principal or secondary, of any kind. Both spouses must meet the conditions. The tax is computed on your living expenses, with a federal minimum expenditure base of 435'500 CHF for 2026 and 437'000 CHF for 2027, a rule of seven times the annual rent or rental value, and a control calculation so that the result cannot fall below ordinary tax on Swiss-source income. Someone who gives it up cannot, in principle, come back to it.

The tax itself depends on the scale applied to that base and on the cantonal surcharges, so we give no amount in the abstract. Several cantons have abolished the regime, among them Zurich, Schaffhausen, Appenzell Outer Rhodes, Basel-Landschaft and Basel-Stadt; Geneva and Vaud have kept it. We do not treat the position of a lump-sum taxpayer under the Italy–Switzerland treaty as settled in the abstract either: it is examined file by file. The conditions, the cantonal minimums and the control calculation are set out on our page on Swiss lump-sum taxation.

The entrepreneur-shareholder

If you will manage a company from Switzerland, you will be exercising a gainful activity there, and lump-sum taxation is closed to you. The route is ordinary taxation on worldwide income and on wealth, combined with a Swiss company or a Swiss holding, either created for the purpose or by transferring an existing structure. The two events, your own move and the transfer of the company or holding, have separate Italian consequences and must be sequenced together; the Italian side of a corporate transfer is settled with an Italian adviser. Shareholdings fall within the scope of the exit tax bill, so the same valuation date applies to them. The page on transferring a company or holding to Switzerland describes how the Swiss structure is built and what it is not meant to do.

Geneva or Vaud: orders of magnitude, not quotes

The federal tax administration publishes an online calculator. We queried it on 01/11/2026 for the 2026 tax year, for a single filer with no children, no church tax and income of the "other" type, adding federal, cantonal and communal tax. The tax shield is not applied. These are estimates, not quotes, and they say nothing about your own situation.

At 1 million CHF, Cologny comes out at 370'036 CHF (37.0%), and Pully and Montreux match Lausanne: the choice of commune moves the result as much as the choice of canton. The maximum federal rate is 11.5% for a single person above 794'000 CHF. On wealth, the effective maximum rates before any shield run from 4.55‰ in Geneva city and 6.39‰ in Lausanne on 1 million CHF to 8.02‰ and 7.76‰ on 10 million CHF.

Both cantons cap the combined burden. Geneva (article 60 LIPP) limits income and wealth taxes to 60% of net taxable income, the net yield on wealth being taken at no less than 1%. Vaud (article 8 LICom) applies a ceiling of 60% of combined net income, with a floor on the wealth tax of 3‰ after capping. The Vaud figures above do not include the vote of 27/09/2026, in which voters accepted at 53.1% an initiative cutting cantonal income and wealth tax by 12%. The press says from the 2027 tax period; the exact date is still to be confirmed. The comparison of Geneva and Vaud adds schooling, housing and access.

What else has to be true for the move to hold

A tax plan fails if the move behind it is not real. Four things have to be in place besides the tax route.

The permit depends on your nationality. EU and EFTA nationals and third-country nationals, which is what British and American citizens are for this purpose, follow different procedures, and the cantonal population office, the OCPM in Geneva, is the point of contact. We quote no reporting deadline here, because two official pages contradict each other on it; we confirm it with the office on each file. See our page on the Swiss residence permit. Health insurance is compulsory for anyone resident in Switzerland, with premiums set by insurer and canton. AVS contributions are owed by residents who do not work, assessed individually; we give no figure for a lump-sum taxpayer.

On the Italian side, an Italian citizen who settles abroad must register with the AIRE within 90 days, through the consulate and the Fast-It portal, free of charge, effective on the day the complete application is filed. The register has been integrated into the national population register since 19 February 2026. The maximum penalty for failing to register is 1,000 euros per year, up to five years. Registration is a duty, not a proof: it does not by itself end Italian residence, and the Revenue Agency's circular 20/E of 4 November 2024 gives the example of an AIRE-registered person who keeps a home available in Italy and returns at weekends, who can still be judged domiciled in Italy.

One point works in your favour. Switzerland was removed from Italy's black list of privileged-tax states by the ministerial decree of 20 July 2023, with effect from 1 January 2024. The presumption of Italian residence for a de-registered citizen no longer applies, and the burden of proving residence no longer falls on you.

How we work, and what we do not do

Ark Fiduciaire SA is a fiduciary in Geneva and Lausanne. We handle Swiss and Italian taxation for people leaving Italy, expenditure-based taxation, and the transfer of a company or holding to Switzerland. Where a file needs a tax lawyer, we call on those of PBM Avocats; Hassan, a member of the Ark Fiduciaire board, is a tax lawyer. For everything else around the relocation (housing, removals, schools, health insurance, banking, permit, car) we work with partners, so you deal with one point of contact.

There are limits, and we state them. The Italian side of a file, such as the valuation at 31 December, the Italian filings and the position of a given asset in the bill, is settled with an Italian adviser, and we say so rather than improvise on it. We do not promise that deferral will be available to a Swiss resident, we do not present calculator estimates as a tax quote, and we do not give an opinion on a bill that has not been voted without telling you which points are open. What we examine on your file are the residence facts, the assets in scope, the route that fits your profile and the cash needed under each scenario, working from your documents. The form below is the first step.