Nobody can tell you today whether Italy's exit tax will be deferrable if you move to Switzerland, because the bill names no state. It sets a two-part test, and our reading is that Switzerland plausibly meets the first part and doubtfully meets the second. The point is open and the risk is real: if Switzerland were not admitted, the whole tax would be due within 180 days.
The question: spread over years, or due in full within 180 days?
If you are planning a move to Geneva or the canton of Vaud, this is the question that decides how much cash you need to find, and when. The Italian exit tax is a bill, not a law. The Council of Ministers approved it on 28 October 2026, and its presentation to Parliament was authorised on 30 October 2026. It is article 17 of the 2027 budget bill, and it inserts an article 307-bis into the new consolidated income tax code (D.Lgs. 19 giugno 2026, n. 117). It would apply to losses of Italian tax residence taking effect from 1 January 2027, for people who have been resident in Italy for at least 6 years out of the preceding 10 and whose qualifying assets have an overall value above €800,000. Our page on Italy's exit tax from 2027 sets out the mechanics in full.
The tax falls on unrealised gains, calculated asset by asset at the last day of the tax period before your departure takes effect: 31 December 2026 for a move effective in 2027, not the day you move. The rate of 26% is not written in the article. It is the rate of the ordinary substitute tax on financial miscellaneous income, and the technical report confirms that it applies. As drafted, the tax is due within 180 days of the date on which the loss of residence takes effect.
There is an alternative to paying everything at once. If the destination state qualifies, you may defer: you pay part of the tax upfront, provide an adequate guarantee, and the balance is pushed out over a number of tax periods. Whether Switzerland qualifies is the question this page is about. The honest answer today is that nobody knows, because the text does not name a single state and refers to no decree that would publish a list. No official source answers the Swiss question, and for that reason this page cites none for it. Everything below marked as a reading is our own.
The difference matters in cash, not in principle. With deferral, you fund half the tax in the first six months and the rest later, if at all. Without it, you fund all of it in the same six months, and for someone whose wealth is in illiquid or concentrated positions that can mean selling the very assets that were taxed in order to pay for the tax.
- Substitute tax of 26% on the unrealised gain, computed asset by asset.
- Paid in full within 180 days of the transfer of residence.
- No guarantee to post, no reporting obligation in the following years.
- 50% of the tax paid up front at the time of the move, plus a guarantee.
- Deferral of up to 5 tax periods towards an EU country, up to 10 towards other admitted countries.
- The tax is cancelled if the assets are not disposed of during the deferral period.
The draft publishes no list of countries. The written criterion is exchange of information and assistance in the recovery of claims (Directive 2010/24/EU). Until the text is voted and the implementing decree published, nobody can say whether Switzerland will be admitted to the deferral: we do not claim it.
What the text requires: two limbs, both to be met
The bill does not say which countries may benefit from deferral. It sets a functional criterion, and the criterion is cumulative. With the destination state there must be in force, at the same time:
- agreements allowing an adequate exchange of information in tax matters; and
- agreements on mutual assistance in the recovery of tax claims, of a scope analogous to that of Directive 2010/24/EU.
The word that carries the weight is "and". A state that exchanges information impeccably but has no instrument on recovery does not pass the test, and the reverse is equally true. It is easy to read the first limb, find it satisfied, and stop there. A reader who does so has answered half the question.
Directive 2010/24/EU is the benchmark. It is the instrument that organises assistance in the recovery of tax claims between EU member states, so for an EU destination the test is measured against something that already exists. For a non-EU state, the test is whether the treaties it has with Italy reach an analogous scope. The text does not define "analogous", and it does not say who decides. That is why the Swiss answer cannot be looked up: it has to be argued from the treaties, and it may ultimately be settled by the implementing decree of the Ministry of Economy and Finance, which the bill provides for and which has not been published.
What deferral gives you, if you qualify
It helps to be precise about what is at stake, because the benefit is substantial and each element has a condition attached. As the bill is drafted:
- You pay an upfront share of 50% to opt for deferral. We read this as half of the tax, and the payment falls within the same 180-day window.
- You provide an adequate guarantee. The text does not define its nature, its form or its amount, so nobody can say today which assets would be accepted.
- The balance is deferred for up to 5 tax periods if the destination is in the EU, and up to 10 tax periods if it is outside the EU. Switzerland, if admitted, would be in the second category.
- The tax is cancelled if the assets are not disposed of during the deferral, if you die, or if you return to Italian tax residence.
- If you dispose of an asset for consideration during the deferral, the tax is computed on the lower of the latent gain and what the sale actually yields. This rule exists only inside the deferral regime and only for disposals for consideration.
- An anti-avoidance rule removes the lower-of treatment for a gift, or for a transfer to controlled companies or entities or to family members. In that case the tax bears on the whole latent gain.
The last two points are easy to overlook. Deferral is not only a way of paying later: it changes the amount of tax in the cases the bill allows. Without deferral there is no lower-of rule and no cancellation. Immediate taxation is on the whole latent gain, and it is final.
Switzerland on the first limb: what exists
On exchange of information, the facts are clear and official. The protocol of 23 February 2015 amended article 27 of the Italy-Switzerland convention to provide for exchange of information on request to the OECD standard. It has been in force since 13 July 2016.
Automatic exchange sits on top of that. Switzerland applies the Common Reporting Standard on a legal basis in force since 1 January 2017, and the Italian ministerial decree of 26 April 2018 lists Switzerland among the jurisdictions concerned. The first year of exchange was 2018, covering reportable periods from 2017.
Our reading, not a source: on that basis the first limb is plausible for Switzerland. We use that word deliberately. The bill speaks of an "adequate" exchange of information, we have no text that defines adequacy for this purpose, and we have no official statement that treats the Swiss exchange network as meeting it for the exit tax. The first limb is the comfortable one, and it is not the one that decides the matter.
Switzerland on the second limb: what we looked for and did not find
The second limb is where the difficulty lies. We read the consolidated text of the convention between Italy and Switzerland, signed in Rome on 9 March 1976 and consolidated at 13 July 2016, looking for a clause on assistance in the recovery of tax claims. We did not find one. The convention covers the allocation of taxing rights, the elimination of double taxation and, since 2015, exchange of information on request. It does not contain a clause of a scope analogous to Directive 2010/24/EU.
Our file also records that Switzerland excluded assistance in the recovery of tax claims when it joined the multilateral convention on administrative assistance in tax matters. That removes the other route one might have expected to rely on.
That is an absence we observed, and we state it as such. It is not proof that no instrument exists. Another agreement, or another provision we have not identified, could be relevant, and if one appeared we would correct this page the same day. But on what we have read, we cannot point to an instrument that fills the second limb.
Our reading, not a source: on that basis the second limb is doubtful for Switzerland. The point is therefore open, the risk is real, and if Switzerland were not admitted the tax would be due in full within 180 days, with no upfront share, no guarantee, no spread over several periods and no lower-of rule.
| Limb | What the bill asks | Where Switzerland stands |
|---|---|---|
| 1. Exchange of information | Agreements allowing an adequate exchange of information in tax matters | Exchange on request since the 2015 protocol, in force 2016, and automatic exchange under the CRS since the first exchange year of 2018. Plausible (our reading). |
| 2. Recovery assistance | Agreements on mutual assistance in the recovery of tax claims, of a scope analogous to Directive 2010/24/EU | No such clause in the consolidated Italy-Switzerland convention text that we read; another instrument not excluded. Doubtful (our reading). |
| Both limbs | Cumulative: each must be met | Open. |
The two scenarios, in cash
The example below is illustrative. It is not a forecast and not a quotation, and it uses a latent gain we chose for the purpose. We assume qualifying assets of a value well above the €800,000 threshold, a total latent gain of €5,000,000 calculated asset by asset at 31 December 2026, no losses offset (the bill provides none, though the implementing decree could say otherwise), and an upfront share calculated on the tax. We do not model the cost of the guarantee, because the text does not define it, and we do not model an instalment schedule, because we do not know the bill's.
| Switzerland not admitted: payment in full | Switzerland admitted: deferral | |
|---|---|---|
| Latent gain (assumed) | €5,000,000 | €5,000,000 |
| Tax at 26% | €1,300,000 | €1,300,000 |
| Cash due within 180 days | €1,300,000 | €650,000, plus an adequate guarantee for the balance |
| Balance | None: everything has been paid | €650,000, deferred for up to 10 tax periods |
| If you sell an asset for consideration | Nothing further: the tax was already computed on the whole latent gain | Tax on the lower of the latent gain and what the sale yields (not for gifts or transfers to controlled entities or family) |
| If you sell nothing, die, or return to Italy | The tax stays paid | The deferred balance is cancelled |
The point is the first cash line. Between the two outcomes, €650,000 has to be found within 180 days, in one case and not in the other. It must come from outside the assets whose gain is taxed if you do not want to sell them, and in the deferral case you also need something to put up as a guarantee. If your portfolio is liquid, the difference is an inconvenience. If it is a stake in a company, a fund with gates or a concentrated holding you have no wish to sell, it is the difference between a planned move and a forced sale.
In the deferral column the tax can end up lower than €1,300,000, by cancellation or by the lower-of rule. That is a benefit you can only count on once you know you qualify. A file cannot assume it.
What this means for a move planned now
The practical consequence is that the file must be built so that it survives either outcome. The vote is expected before the end of 2026, and it may not settle the Swiss question: the bill names no state, and the implementing decree is yet to come. Waiting for certainty may mean having none before the valuation date has passed.
Building for both outcomes comes down to three things:
- Know your liquidity. Work out how much cash you could raise within 180 days of the loss of residence taking effect without selling the positions you want to keep. Our exit tax calculator gives the order of magnitude of the tax for your own figures, which is the number to compare it with.
- Know what could serve as a guarantee. The text does not say what is acceptable, so do not commit assets to other uses without need, and do not assume that a particular asset will be accepted.
- Know which assets you do not intend to sell. Cancellation and the lower-of rule reward holding, but only if deferral is available. Those are the assets whose tax you would have to pay in cash if it is not.
If you hold a company or a holding, the sequencing is different and the liquidity question harder, as our page on transferring a company or holding to Switzerland explains. For the rest of the framework, including what the bill does and does not cover, see Italy's exit tax from 2027.
How we handle this specific uncertainty
Ark Fiduciaire works from Geneva and Lausanne on Swiss and Italian taxation, with the tax lawyers of PBM Avocats when a file calls for it. On this point our job is limited and precise. We tell you what the text says, what it does not say, and what we would do in each case: if Switzerland is admitted to the deferral, and if it is not. We then build a plan that holds either way, from your own balance sheet and not from an average. The Italian filing side is settled with an Italian adviser, whom we work alongside.
We also tell you what we will not do. Anyone promising you a Swiss deferral today is promising something no source supports, and anyone telling you it is ruled out is doing the same. If either claim comes with a reference, ask for it, and send it to us. If it is a text we have not seen, we will want to read it. To start, request an analysis or use the form below.