
From 2027, those who move their tax residence with financial assets exceeding 800 thousand euros will have to pay a tax on the capital gains accrued.
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The maneuver aims to preserve the State's taxing power on income accrued during residence in Italy.
Leaving will cost, but only for those with a wallet above 800 thousand euros. From 2027, the measure introduces a tax on financial earnings accrued and not yet collected by those who transfer their tax residence abroad. At the time of departure, shares, bonds, funds and other financial instruments are treated as if they had been sold on 31 December of the previous year, and 26% is applied to the capital gain, which for government bonds drops to an effective 12.5%. The objective, we read in the explanatory report, is to "preserve the taxing power" of the State on income generated during residence in Italy.
There are two conditions and they must apply together: at least six years of residence in the last ten and financial assets of at least 800 thousand euros. The threshold concerns the value of the assets, not the earnings, and properties are excluded. The tax must be paid within 180 days. Anyone who moves to an EU country, or to a non-EU country with information exchange and collection agreements, can postpone it until the actual sale, but must immediately pay a 50% deposit and provide a guarantee.
If within five years, ten outside the EU, the securities are not sold, the tax is not due and the advance payment is returned; the same applies in the event of death or return to Italy. The seller pays the lower of the capital gain calculated at the start and the one actually realized.
For public coffers the withdrawal is worth little. The technical report estimates 3.37 million in 2027 and 6.74 million per year from 2028, with reimbursements expected for 3.37 million per year from 2032. The calculation starts from the 6.58 billion paid in 2025 as a substitute tax on capital income and capital gains, reduced to the share of financial wealth above 800 thousand euros (73.1%) and the share of residents who every year emigrate (0.28%).
The norm is already set to change. Forza Italia, with the president in the Senate Stefania Craxi, says it agrees with "the rationale" but asks for "three corrections". The first: «Only what is matured in Italy should be taxed», taking the value of the goods upon arrival as a reference. The text today calculates the capital gain on the original purchase cost and therefore also affects earnings accrued before moving to Italy, while the technical report describes the tax as a levy on income "accrued during the period of residence".
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