The Italian exit tax is, at 1 November 2026, a bill that has not been voted. The Council of Ministers approved it on 28 October 2026 and presentation to Parliament was authorised on 30 October 2026. Everything below about the Italian side describes that text as drafted and will change if Parliament changes it. Where the bill is silent, or a point depends on an implementing decree not yet published, the answer says so rather than filling the gap.
The answers are grouped by theme and each can be read on its own. Swiss figures come from official sources and are given as published; the income tax comparisons are estimates and not quotations. Where no source settles a question, most importantly whether Switzerland qualifies for deferral, we set out the criterion, what is known and what is not.
The Italian exit tax
Has the Italian exit tax been enacted?
No. At 1 November 2026 it is a bill, not a law. The Council of Ministers approved it on 28 October 2026 and presentation to Parliament was authorised on 30 October 2026. We have found no primary source confirming a formal filing in the Chamber of Deputies or giving a parliamentary reference number, so we state neither. Through article 17 of the 2027 budget bill it would insert article 307-bis into the new income tax code (D.Lgs. 19 giugno 2026, n. 117), and it would apply to losses of Italian tax residence taking effect from 1 January 2027. A vote is expected by the end of December 2026, and the text may change before then.
Who falls within the scope of the exit tax?
As drafted, the bill targets individuals who have been Italian tax residents for six of the previous ten tax periods and whose assets in the perimeter have an aggregate normal value of €800,000. The threshold is all-or-nothing and applies to the value of the assets, not to the gain on them. The tax is due only where the transfer causes Italy to lose its power to tax the gain. Società semplici, the Italian simple partnerships, and non-commercial entities are also caught.
On what date are my assets valued for the Italian exit tax?
On the last day of the tax period before the one in which your loss of Italian residence takes effect. For a transfer taking effect in 2027 that is 31 December 2026: not the day you move, and not the day you register with AIRE, the register of Italians resident abroad. This is widely misreported. In practice it is your position at 31 December 2026 that is measured, whether you leave in January or in September 2027.
What is inside the exit tax perimeter, and what is outside it?
Inside are gains of the kind Italian law taxes as miscellaneous financial income: qualifying and non-qualifying shareholdings, securities, fund units, derivatives, receivables and other financial instruments, and crypto-assets. Real estate is outside the perimeter. Life insurance policies are not dealt with by the bill, so their treatment is uncertain. The bill speaks of assets and rights rather than of financial investments, which is a reason to have the wording checked against your own holdings.
How is the exit tax computed, and where does the 26% rate come from?
The gain is computed asset by asset and only positive differences are added together, so latent losses do not offset latent gains under the text as drafted; an implementing decree of the Ministry of Economy and Finance, announced but unpublished, could provide otherwise. The 26% rate is not written in the article: it is the rate of the ordinary substitute tax on miscellaneous financial income, as the technical report confirms. Test a scenario with our exit tax calculator; the mechanics are set out in our guide to the Italian exit tax in 2027.
Deferral and Switzerland
How does deferral of the exit tax work?
Instead of paying within 180 days of the date your loss of residence takes effect, you may opt for deferral by paying an advance of 50% and providing a suitable guarantee. The bill sets a maximum deferral of five tax periods for a move within the EU and ten for a move outside it. During deferral a lesser-of rule compares the latent gain with the amount actually realised, but only on sales for consideration; gifts and transfers to controlled entities or family members bring back the full latent gain. The tax lapses if nothing is sold, on death, or on return to Italian residence. The nature, form and amount of the guarantee are not defined.
Will Switzerland qualify for deferral of the Italian exit tax?
The point is open, and we do not answer yes or no. The bill names no state. It sets a cumulative test: agreements allowing an adequate exchange of information with the destination state, and agreements on mutual assistance in recovering tax claims of a scope comparable to Directive 2010/24/EU. For Switzerland the first limb is plausible, given the 2015 protocol to the Italy-Switzerland treaty, in force since 13 July 2016. The second is doubtful: Switzerland excluded recovery assistance when it joined the multilateral convention on administrative assistance, and the 1976 treaty contains no equivalent clause. If Switzerland were not admitted, the whole tax would fall due within 180 days. No source we have found settles the question.
What should I plan for while the question of Switzerland remains open?
For both outcomes. If deferral were available, you would owe an advance and need a guarantee whose terms the bill does not define. If it were not, the entire tax would be payable within 180 days of the date your loss of residence takes effect, with no deferral and no lesser-of rule. The sensible course is to cost the second scenario now, to know which assets would fund it, and to ask your Italian adviser to follow the parliamentary text and any implementing decree. Our page on exit tax deferral and Switzerland sets out the reasoning in full.
Nationality, and who this actually concerns
Does the exit tax apply only to Italian citizens?
No. The rule turns on Italian tax residence, not on nationality. A British, American or German national who has been tax resident in Italy for six of the previous ten tax periods, and whose assets in the perimeter reach the threshold, is within the scope of the bill as drafted, exactly as an Italian citizen would be. What changes with nationality is the Swiss side: whether you may settle in Switzerland, and on what conditions, depends on the immigration regime that applies to your nationality.
I am not an EU national: can I still move to Switzerland?
That depends on a different immigration regime, whose conditions we do not set out here. The permit rules described on this page are those for nationals of EU and EFTA states under the Agreement on the Free Movement of Persons. A national of another state is outside that agreement and must be assessed individually, before any move, because the permit conditions and the Italian timetable are independent of each other. Expenditure-based taxation is open to anyone who does not hold Swiss nationality, but it presupposes a right to reside in the first place.
How is Italian tax residence determined, and does AIRE registration end it?
Since the 2024 reform of article 2 of the income tax code, you are resident if, for the greater part of the tax period, your civil-law residence, your domicile or your physical presence is in Italy. The tests are alternative. The greater part means 183 days (184 in a leap year), and domicile is where your personal and family relations are mainly developed. Registration is now only a rebuttable presumption: the Revenue Agency’s circular 20/E gives the example of a person registered with AIRE who keeps a house available in Italy and returns at weekends, who may be found domiciled in Italy. No single official date makes a departure enforceable against the Italian tax authority.
Is Switzerland still on Italy’s black list?
No. A decree of the Ministry of Economy and Finance of 20 July 2023, published in the Official Gazette on 28 July 2023, removed Switzerland from the list of privileged-tax states for individuals, with effect from 1 January 2024. The presumption of Italian residence that applied to a citizen struck off the population register who moved to a listed state no longer applies to a move to Switzerland, and the burden of proving Italian residence is back on the tax authority. The Revenue Agency’s circular 20/E of 4 November 2024 confirms this.
Expenditure-based taxation
Who can be taxed on expenditure in Switzerland?
Under article 14 of the federal direct tax act and the Federal Tax Administration’s circular no. 44, you must not hold Swiss nationality (dual nationals included), must be taking up residence in Switzerland for the first time or returning after at least 10 years abroad, and must carry on no gainful activity in Switzerland, in a main or secondary occupation of any kind. Both spouses must meet the conditions, and social deductions are not available. Our guide to lump-sum taxation explains the system for readers coming from Italy.
What are the minimum tax bases for expenditure-based taxation in Geneva and Vaud?
They are minimum bases to which the ordinary scale is applied, not amounts of tax. For direct federal tax the minimum expenditure is 435'500 CHF for 2026 and 437'000 CHF for 2027, with a rule of seven times the annual rent or rental value. In Geneva the cantonal base is 426'357 CHF for 2026, or 468'993 CHF with the 10% increase shown in the canton’s table. In Vaud it is 415'000 CHF, wealth supplement of 15% included. We publish no minimum tax in francs for either canton: it depends on the scale, the communal rate and the control calculation, and is worked out case by case.
Does the Italy-Switzerland treaty protect a lump-sum taxpayer?
This is not established, and we claim nothing either way. Article 4(5)(b) of the treaty provides that an individual who is not subject to the taxes generally levied in a state on all income arising in the other state is not treated as a resident of it. Nothing therefore establishes that an ordinary lump-sum taxpayer counts as a treaty resident. The existing mechanism is modified global taxation: Italian-source income for which relief is claimed is added to the expenditure base and taxed under the ordinary scale, and Italy is among the states concerned. We have found no official source on how Italy treats a Swiss lump-sum taxpayer in practice.
What is the control calculation, and can I return to the lump sum after giving it up?
The control calculation is a floor: your tax cannot be lower than the ordinary tax on income from Swiss sources and on income for which treaty relief is claimed. Both Geneva and Vaud apply it. Anyone who renounces expenditure-based taxation can in principle not return to it. Several cantons have abolished the regime altogether: Zurich on 1 January 2010, then Schaffhausen, Appenzell Outer Rhodes, Basel-Landschaft and Basel-Stadt. Geneva and Vaud retain it.
Choosing the canton
How do income tax and wealth tax compare between Geneva and Lausanne?
These are estimates, not quotations, from the federal tax administration’s calculator for tax year 2026, consulted on 1 November 2026: a single person, no children, no church tax, federal, cantonal and communal tax, with no tax shield applied. On 500'000 CHF of income the total is 183'509 CHF in the city of Geneva (36.7%) and 200'779 CHF in Lausanne (40.2%); on 1'000'000 CHF, 403'615 CHF (40.4%) and 413'322 CHF (41.3%). Wealth tax at 10'000'000 CHF is at most 8.02‰ in Geneva and 7.76‰ in Lausanne before any shield. See our comparison of Geneva and Vaud.
What does the Vaud tax cut voted on 27 September 2026 change?
Vaud voters accepted, with 53.1% of the vote, an initiative cutting cantonal income and wealth tax on individuals by 12%; the estimated loss of revenue is 272 million CHF a year. The cantonal communiqué says “from next year”, while the press gives the 2027 tax period, so we write that the reduction applies from the 2027 tax period according to the press, the exact date remaining to be confirmed. None of the Vaud figures in the previous answer includes it. How much it lowers a given bill depends on the split between cantonal and communal tax, and we do not extrapolate.
What do schools and housing cost?
We publish only official figures. At the International School of Geneva (Ecolint) the 2026-2027 annual fees are 28'160 CHF for classes 1 to 4 and 36'540 CHF for classes 12 and 13, plus a one-off 4'000 CHF development fund. Le Rosey charges 154'200 CHF a year for boarding in 2025-26. We quote nothing for other schools, as the available figures come from third parties. On housing, the only official figure is Genevan: in the cantonal stock in 2024, a five-room free-market flat let to the same tenant for under three years averages 2'351 CHF a month excluding charges. That is not a high-end rent, and we have no official figure for Lausanne.
The permit and what you must do on arrival
Which permit does a person without gainful activity receive?
For an EU or EFTA national who will not work in Switzerland, the conditions are sufficient means not to depend on social assistance and full health and accident insurance. A B permit is in principle granted for 5 years, with no quota, and a C settlement permit may follow after 5 years of regular and uninterrupted residence. In Vaud a copy of the expenditure-based taxation decision can serve as proof of means. The residence permit guide details the cantonal files in Geneva and Vaud.
Is there a minimum amount I must hold to obtain a Swiss residence permit?
No federal rule sets an amount in francs, and we do not publish one. The test is qualitative: your means must be sufficient for you not to depend on social assistance, judged by the cantonal authority by reference to the social assistance standards. For a recently arrived retiree the means must exceed the threshold for supplementary benefits, failing which a permit may be refused. A figure quoted by an adviser or a website is therefore not a rule.
What must I pay for health insurance and old-age insurance?
Basic health insurance (LAMal) must be taken out within 3 months of taking up residence, with retroactive effect. Average monthly premiums, all ages, are 487.20 CHF in Geneva and 439.30 CHF in Vaud for 2026, rising to 508.60 CHF and 454.50 CHF for 2027. Holders of a permit without gainful activity may apply for an exemption if equivalent cover is maintained; the cantonal authority decides. A person without gainful activity pays between 530 CHF and 26'500 CHF a year in old-age contributions in 2026. A lump-sum taxpayer is treated as not gainfully active, and the expenditure taken into account counts as pension-type income multiplied by 20. The compensation fund calculates the amount, and we quote no individual figure.
What formalities apply on arrival: registration, driving licence and household goods?
In Geneva, one official page gives 14 days to register and another official guide gives 3 months for EU nationals; we advise acting within 14 days. Vaud requires notification to the commune’s residents’ office. An Italian driving licence must be exchanged within 12 months of taking up residence, after which you may not drive in Switzerland, although exchange remains possible. Household goods are imported free of duty if you have used them personally for at least 6 months, on form 18.44, within 2 years. A vehicle must be cleared at a staffed customs office on the first crossing, physically present.
Companies and holdings
Are the shares in my company within the exit tax?
As the bill is drafted, yes. Shareholdings, qualifying or not, are inside the perimeter, as are fund units and other financial instruments. The gain is computed holding by holding on the value at 31 December 2026, and the value counts towards the €800,000 threshold. Giving the shares away, or transferring them to a controlled entity or a relative, does not remove the exposure: the bill treats such operations as bringing back the full latent gain in the deferral regime.
Can I run a business in Switzerland and still be taxed on expenditure?
No. Expenditure-based taxation requires that you carry on no gainful activity in Switzerland, in a main or secondary occupation of any kind; the federal circular names artists, scientists, inventors and sportspeople among its examples. Of the members of a board of directors, only those who personally carry on a gainful activity in Switzerland are caught. An entrepreneur who intends to manage a Swiss company should therefore expect ordinary taxation. The choice between the two regimes is made before the move and shapes the rest of the file.
What happens to the Italian side if I move my company’s seat to Switzerland?
The bill does not address it. It deals with individuals, società semplici and non-commercial entities and their financial assets, and says nothing about the Italian tax treatment of a company that transfers its seat abroad. That must be settled with an Italian adviser before any step is taken. On the Swiss side we examine where the company and its holdings are best located and how they interact with your personal regime, with the tax lawyers of PBM Avocats where the file requires it. See transferring a company or holding to Switzerland.
Inheritance and gifts
Is there an inheritance tax treaty between Italy and Switzerland?
No. Switzerland has inheritance tax treaties with only eight states: Austria, Denmark, Finland, Germany, Sweden, the Netherlands, the United Kingdom and the United States. Italy is not among them, and the 1976 income tax treaty does not deal with inheritance. There is therefore no treaty rule to allocate taxing rights or to give relief for tax paid in the other state. Succession and gift taxes are cantonal and are applied on their own terms. Where an estate has links with both countries, the position of each must be checked with an adviser in each.
How are inheritances taxed in Geneva if I am taxed on expenditure?
Geneva exempts the surviving spouse and direct-line relatives from inheritance duties, but not always: the exemption does not apply if, in one of the last 3 final tax assessments before death, the deceased was taxed on expenditure. The heirs then fall under the first-category scale. For children, parents and spouse it runs from 2% on the bracket starting at 5'001 CHF to 6% above 500'000 CHF, with 5'000 CHF exempt per heir and no additional communal percentage. Grandchildren and grandparents pay 20% more and other descendants and ascendants 30% more. The same exception applies to gifts.
How does Vaud treat inheritances, and is the foreigners’ reduction available?
Vaud exempts the spouse or registered partner. Descendants are taxed after a deduction of 1'000'000 CHF per hereditary line, reduced by one hundredth for each tranche of 1'000 CHF above 1'001'000 CHF (estates opened since 1 January 2025). Gifts to children are exempt up to 300'000 CHF per child per calendar year; above that the whole gift is taxable. Unlike Geneva, the Vaud law has no exception for lump-sum taxpayers. Article 36 halves the tax for a foreigner who has never exercised gainful activity in Switzerland, but whether it reaches an Italian lump-sum taxpayer is open: the administration has not confirmed it, and we treat it as a point to examine, not an entitlement. We quote no Vaud rate.
Working with us
What do you handle, and what belongs to an Italian adviser?
We handle the Swiss side: eligibility for expenditure-based taxation, the choice between Geneva and Vaud, the Swiss tax position, the transfer of a company or holding and the Swiss structure around it. Tax lawyers of PBM Avocats join when the file calls for it, and partners handle housing, removals, schools, health insurance, banking, permits and cars through a single contact. The Italian side belongs to an Italian adviser: computing and filing the exit tax, the position on Italian tax residence and the treatment of a seat transfer. We work alongside your Italian adviser and say in each file where the line falls.
What is a realistic timetable between now and the end of the year?
At 1 November 2026 two months remain before the valuation date. For a transfer taking effect in 2027, the bill fixes it at 31 December 2026 whatever the date of your move, and it applies to losses of residence taking effect from 1 January 2027. What can still be done is to measure your exposure, check your eligibility for expenditure-based taxation and for a permit, and settle the canton. The vote is expected by the end of December, so the final text may arrive after those steps. We quote no processing times for permits or tax decisions, because the cantonal authorities set them and we found no official figure.
How does a file start?
Through the quote request. Tell us how many years you have been tax resident in Italy, the categories and approximate value of your assets at 31 December 2026, your family situation, your nationality and whether you intend to carry on a business in Switzerland. We analyse documents, not a telephone summary: tax returns, portfolio statements and, for a company, its registry extract and accounts. We then tell you whether the Swiss side points to expenditure-based or ordinary taxation, what has to be settled with your Italian adviser, and what we need next.