Italy exit tax calculator 2027

What this calculator computes

The calculator applies the rules that, under article 17 of the Italian 2027 budget bill, would determine the tax due when Italian tax residence is lost. The article does not lay down a self-standing regime: it inserts a new article 307-bis into the D.Lgs. 19 giugno 2026, n. 117, under the heading “Imposizione in uscita dei soggetti che non esercitano imprese commerciali”.

Who is in scope: three cumulative conditions

The charge would reach individuals who have been Italian tax residents for at least 6 of the 10 tax periods preceding the transfer, whose assets and rights have an aggregate normal value of at least €800,000, and only where the transfer causes Italy to lose its taxing power over those gains. All three conditions must be met together.

The €800,000 figure is an entry threshold, not an allowance: once it is crossed, the calculation covers the whole latent gain rather than the excess. Nationality is irrelevant — the rule looks at tax residence, not at your passport. This matters for foreign nationals who have settled in Italy: a British, American or German citizen resident there for six years or more is in scope exactly like an Italian national.

When value is measured — the point most often reported wrongly

Normal value is not measured on the day you move, nor on the day you register with AIRE. The bill fixes it on the last day of the tax period preceding the one in which the loss of tax residence takes effect: for a transfer effective in 2027, that is 31 December 2026. The date carries weight, because it freezes the snapshot of the portfolio on which the whole calculation is built.

The asset-by-asset calculation

The charge does not fall on wealth but on gains accrued and not yet realised. For each holding the tax-recognised cost is deducted from normal value, and only the positive differences are added together. A €2m portfolio bought for €1.2m produces a latent gain of €800,000 and a tax of €208,000 at 26%. Someone who bought and has not gained owes nothing, whatever the portfolio is worth.

Because only the positive differences are added, latent losses are not offset against gains: the calculator computes them and shows them separately without reducing the base. The implementing decree of the Italian Ministry of Economy and Finance, provided for by the bill and not yet published, could rule otherwise.

One point on the rate: the 26% is not written into article 307-bis, which refers taxation to “the ordinarily applicable provisions”. It is the rate of the ordinary Italian substitute tax on financial income, confirmed by the technical report accompanying the bill.

The reduced base of 48.08%

Certain bonds benefit from a taxable base reduced to 48.08%, bringing the effective rate to roughly 12.5%, in line with how these instruments have long been treated. The perimeter is wider than usually reported: not only Italian government securities and equivalents under article 31 of Presidential Decree 601/1973, but also bonds issued by states on the Italian white list of countries allowing an adequate exchange of information, and bonds issued by their territorial bodies. The calculator applies the reduction when you select that category.

Payment and the 50% upfront amount

The tax must be paid within 180 days of the date on which the loss of tax residence takes effect. Alternatively, the taxpayer may opt to defer it until the assets are actually disposed of, by paying 50% of the tax within that same deadline and providing adequate security — whose nature, form and amount the text does not specify. Deferral runs for 5 tax periods where the move is to an EU member state and 10 periods otherwise.

During the deferral, a disposal for consideration is taxed on the lower of the latent gain and the positive difference between sale price and tax cost — a genuine advantage if values fall after you leave. That comparison, however, exists only inside the deferral regime and only for disposals for consideration. On a gratuitous disposal, or a transfer to controlled companies and entities or to family members, the tax falls on the entire latent gain.

If the assets are not disposed of within the deferral period, the tax is not due. The same applies to assets transferred on death during the deferral, and to assets not disposed of if tax residence returns to Italy within that period; amounts paid in excess are refunded.

Deferral to Switzerland: the question with no answer yet

This is the decisive unknown for anyone looking at Geneva or the canton of Vaud, and it deserves an honest answer rather than a reassuring one. The bill lists no countries and does not refer to a decree that would publish such a list. Instead it sets a functional, cumulative test: agreements must be in force with the destination country both for an adequate exchange of information and for mutual assistance in the recovery of tax claims, of a scope analogous to that provided for by Directive 2010/24/EU.

For Switzerland the first limb is plausible: the 2015 protocol to the treaty with Italy introduced exchange of information on request to the OECD standard. The second limb is doubtful: Switzerland excluded assistance in the recovery of tax claims when acceding to the multilateral convention on administrative assistance, and no clause of equivalent scope is found in its treaty with Italy.

The practical consequence is serious and should be stated plainly: if Switzerland were not among the qualifying states, the tax would be due in full within 180 days, with no deferral and no lower-of-two-amounts relief on a later sale. That uncertainty is what makes the calendar decisive — a transfer whose effect falls on or before 31 December 2026 would remain outside the scope of the rule altogether. The question is examined in detail on exit tax and Switzerland: deferral or immediate payment.

What the calculator does not do

An estimate is not an analysis. The calculator deliberately ignores several things that change the outcome of a real file:

• your personal and family circumstances, the actual composition of the portfolio, and the documentary evidence of the tax cost of each position — which is where real files get complicated;
• the treatment of special Italian regimes, on which the bill is silent: we therefore say nothing about their fate;
• the Swiss tax that would apply once you arrive, which differs sharply depending on whether you fall under lump-sum taxation or ordinary taxation, and on the canton you choose — see Geneva vs Vaud;
• the treatment provided for by the Italy-Switzerland double taxation treaty, and the separate question of whether a lump-sum taxpayer is treaty-resident at all.

That is why the result turns into a request for analysis: the figures you entered travel with the request, and an Ark Fiduciaire SA adviser answers on your actual case — in English or Italian — within one business day.