Maneuver 2027, spotlight on the exit tax: what it is and who it affects

With the 2027 Budget, the exit tax, already foreseen for companies, also extends to private individuals who transfer their tax residence abroad and have financial investments of at least 800 thousand euros. In essence, it is a new tax designed for those who decide to transfer their tax residence from Italy to abroad starting from 1 January 2027.

The budget bill thus introduces a tax on earnings accrued in Italy with shares, equity investments and other financial instruments, even if they have not yet been sold. The ordinary rate is 26%, as indicated in the technical report, but the tax does not apply to the entire value of the investments: only the capital gain is taxed, i.e. the difference between the value achieved by the securities and their purchase cost.

The new regulation will concern those who have been tax residents in Italy for at least six of the last ten years and move to another country, causing the Italian tax authorities to lose the right to tax those earnings. The tax must be paid within 180 days of the transfer. However, those who move to an EU country, or to a state with specific tax cooperation agreements, will be able to postpone payment until the investments are sold, by paying a 50% deposit and presenting a guarantee. The postponement will last a maximum of five years for those moving to the EU and ten in the other admitted countries. If the investments are not sold within this period, the tax will not be due and any excess deposits paid will be refunded. The measure will apply to transfers of tax residence from January 1, 2027. The technical report estimates a potential revenue of 13.47 million euros, with initial collections expected to be around 6.7 million per year, of which 3.37 million in 2027.