A tax is normally due when something is sold.
The draft budget law now circulating in Rome would ask for one when someone leaves. Nothing would need to change hands. If a family moved its tax residence abroad, the State would ask what its shares and securities were worth on that day, subtract what they cost, and take 26% of the difference. The gain would be on paper. The bill would not.
The measure is a new article 307-bis of the Italian income tax code. It would apply to individuals who have been tax resident in Italy for at least six of the previous ten tax years, and who held financial assets of at least 800,000 euro on 31 December of the year before they leave. The Financial Times notes that the threshold counts gross assets, with no deduction for borrowings. Shares, holdings, financial instruments and government bonds would fall inside it, and Milano Finanza adds that crypto-assets appear to be included. Government bonds would be taxed on 48.08% of the gain, an effective rate of 12.5%, as QuiFinanza reports.
Payment would fall due within 180 days. For those moving within the European Union, or to countries that exchange tax information, half would be paid up front with a guarantee and the balance when the asset is sold, within five years for the EU and ten elsewhere. If the asset were not sold in that period, if there were a succession, or if the person returned to Italy to stay, the tax would be cancelled and refunded.
Real estate does not appear in the perimeter described by any of the reports I have read. The text is still a draft, and Parliament may change it.
The figure that stands out is the smallest. By the government’s own calculations, as reported by Fanpage, the estimated revenue would be 3.37 million euro in 2027, because only half a year would count, and 6.74 million a year from 2028 to 2031, inside a budget of some 26 billion, as Milano Finanza notes. At that scale the measure is not mainly about revenue. Deputy Economy Minister Maurizio Leo told Reuters that Italy is happy to consider proposals to improve the exit tax and is always open to dialogue, without saying what changes may be adopted.
What remains open concerns the regime for new residents, who pay a flat 300,000 euro a year on foreign-sourced income, as Reuters notes. Marco Cerrato of Maisto e Associati, quoted by the Financial Times, reads the current wording as seeming to exclude the foreign assets of those who benefit from the regime, and says clarifications will be needed. Antonio Tomassini of DLA Piper in Milan told Reuters that the government needs to make clear that the rule will not apply to people who moved their tax residence to Italy under preferential regimes, at least until the regime expires. The text still has to pass Parliament.
It is too early to draw conclusions. The text is a draft, and the government has said it is open to improving it. What the discussion shows is how carefully a decision of residence is read: not by a single rate, but by the whole framework and its continuity over time. Reuters notes that the new-resident regime has helped Milan become a top relocation hub. That interest explains why every detail of the draft is being read so closely.
A residence is a patrimonial decision before it is a fiscal one. The tax is the visible part. What a family weighs underneath is whether the framework will still be recognisable in twenty years. That is a question for time, not for a table of rates, and no one can promise the answer.
What can be held steady is the order of the questions. Where will the family live, and for how long? Who will look after the place when the next generation takes over? What does the decision protect? The figures follow those answers, never the reverse.
As far as the reports show, a property held in custody is not what this draft would tax. It is, however, the asset that anchors a residence, and so the choice of residence is where this draft would be felt.
Rules are written and rewritten. A place kept in care for generations has outlasted many budget laws. For a private conversation, write to me.
This note reports a draft measure and is not tax or legal advice. For your own position, consult your tax adviser.
Sources: QuiFinanza · Fanpage · Milano Finanza · Reuters, via Global Banking & Finance Review · Financial Times
