The Exit Tax Is Worth €3 Million. That Is the Point.

Italy has drafted a tax on leaving. The revenue is trivial. The precedent is not.

On 28 October 2026, the Italian cabinet approved something no Italian government had ever written into a budget: a tax on citizens who leave, charged on gains they have not realised. On 30 October 2026 the text went to Parliament.

Expected revenue in the first year: €3.37 million.

No government builds a new tax for €3 million. In my reading, it builds it for what the tax can become.

At €800,000 of investments, this is not a tax on the super-rich. It taxes anyone whose portfolio grew faster than their plans.

And it is not about leaving. It is about whether leaving remains a choice.

What the draft says

The bill text and technical report are not yet fully public. What follows is the measure as reported on 30 October.

• Who. Anyone who has been an Italian tax resident for at least six of the last ten years and transfers tax residence abroad, where the transfer costs Italy the right to tax the gains.
• Threshold. €800,000. Most outlets describe it as financial investments. AGI describes it as the total value of assets and rights. The difference is not technical. It decides how many families are inside.
• Base. Unrealized gains on shares, holdings and other financial instruments: market value minus purchase cost.
• Rate. 26%.
• Payment. Within 180 days of the transfer.
• Deferral. For moves to the EU, or to a State with specific tax-cooperation agreements: payment deferred until sale, against a 50% advance and a guarantee. Maximum five years for the EU, ten for the other admitted States. If the assets are not sold within that period, the tax is not due, and excess advances are refunded.
• In force. Transfers effective from 1 January 2027.

Until now, Italy’s exit tax (art. 166 TUIR) reached businesses, including sole entrepreneurs who moved a business abroad. Private portfolios are new territory.

One point must be stated plainly, because anyone who omits it is selling fear. For an EU move, the draft is lenient on paper. Hold for five years and the liability lapses. The cost there is not confiscation. It is immobility: half the liability parked, a guarantee in place, and a portfolio you cannot sell without triggering the tax. In my reading, it also cannot be meaningfully restructured.

The €2.08 million question

The severity is outside the EU.

Take an illustrative case. An entrepreneur holds a €10 million listed portfolio with a cost basis of €2 million. The unrealized gain is €8 million. At 26%, the liability is €2.08 million.

• Move within the EU: €1.04 million up front, a guarantee on the balance, five years of constrained flexibility.
• Move to a non-admitted State: €2.08 million in cash within six months, on assets that have not been sold.

That second scenario is not a tax problem. It is a forced-sale problem.

Which non-EU States will be admitted has not been published. Whether Switzerland, the UAE, or Monaco fall on the list will determine whether this measure is friction or a wall. Switzerland is the instructive case. In Wächtler (C-581/17, 2019), the Court of Justice of the EU held that Germany’s immediate exit tax on a move to Switzerland breached the EU–Swiss Agreement on the Free Movement of Persons, for a taxpayer exercising an economic activity there. A list that excludes Switzerland would invite litigation.

Two presumptions for the same family

For the family heading to Dubai or Monaco, the exit tax does not arrive alone.

Under art. 2, paragraph 2-bis TUIR, Italian citizens who move to a listed preferential-tax jurisdiction are presumed to remain Italian residents. The taxpayer bears the burden of proof. The UAE and Monaco remain on that list. Switzerland was removed in 2024.

The result is a double charge on the same act. You must prove you have left. Then you pay for having left.

Registration with AIRE, the register of Italians resident abroad, is a form, not a defense. Italian tax courts continue to reclassify registered emigrants as residents where family, property, bank accounts or business management remain in Italy.

The direction, not the measure

Read this bill alongside its neighbours.

• Entry. The flat tax on foreign income for new residents: €100,000 in 2017, €200,000 in 2024, €300,000 for arrivals from 2026.
• Transactions. The financial transaction tax: 0.2% before the 2026 budget, 0.4% after it, 0.8% in this bill. Two doublings in two budgets.
• Exit. A new charge on departure, on gains not yet realised.

Each step is defensible in isolation. Together they describe a direction. Mobile capital is now priced at every border it crosses: coming in, trading inside, going out.

Across the exit-tax regimes I analyze in TaxNomadism, the sequence repeats: introduction, extension, tightening. Germany extended its regime to all investment fund units from January 2025. Norway abolished its five-year write-off in 2022, then moved toward a hard payment deadline regardless of sale. Italy is at stage one.

Threshold, rate, asset perimeter, list of admitted States. These are parameters. Parameters move. You will face the tax in force when you leave, not the one announced this week.

Where the draft is exposed

The Court of Justice has been here before. In de Lasteyrie du Saillant (C-9/02, 2004) and N (C-470/04, 2006), it treated a mandatory guarantee as a disproportionate condition for deferral, and required account to be taken of losses in value after departure. In Commission v Portugal (C-503/14, 2016), it struck down an exit charge on individuals. In Verder LabTec (C-657/13, 2015), it accepted installments as proportionate.

In my reading, a 50% advance plus a guarantee goes beyond what the Court has accepted. That is a credible ground for challenge, not a certainty.

Constitutional arguments under articles 53 and 16 of the Italian Constitution will be raised. They are weaker. A tax on leaving is not a prohibition on leaving.

The practical window is narrow. The Budget Committee of the first chamber makes amendments in November and early December. After that, the text is effectively closed.

What about HNWI? THINK FAST AND MOVE FAST! THE EXIT TAX BOMB IS HERE!

Three questions for this week

1. Have I been an Italian tax resident for at least six of the last ten years?
2. Do my investments, or my total assets until the text clarifies the base, exceed €800,000, and what is my unrealised gain?
3. Is my likely destination in the EU, an admitted State, or neither, and could I pay the full liability within 180 days without selling?

If the answers are yes, yes, and neither, your exposure is critical.

One note on timing. Italy assesses residence on the greater part of the tax year, with no split-year for individuals. For most current residents, a departure now takes effect in 2027 and falls within the measure's scope. That is analysis, not instruction. Only a genuine, documented relocation, planned with qualified advisors, stands. Anything else is a residence on paper, and Italian tax courts treat it as exactly that.

The method behind the number

In TaxNomadism, exit-tax exposure is Factor 2 of the Master Sovereignty Score: weighted at 20%, scored from 0 to 100, with a target below 25. The book’s composite cases of Roberto Silva and Maria Santos make the point in one line. Same class of advisors. Opposite outcomes. The difference was a 42-month planning window.

The book predates this Italian measure. It does not describe it. It provides the method that makes it readable: the Exit Tax Exposure Score, the Three-Layer Sovereignty Architecture, the Alliance Grid, and the ten questions of the Advisor Audit I would put to anyone who claims to manage your mobility.

TaxNomadism is available here: https://amzn.eu/d/06aCEXqX

Before Parliament amends the bill, know your number.

Exit taxes do not eliminate mobility. They tax the delay in preparing for it.

This article analyses a draft bill (Disegno di Legge di Bilancio 2027, approved by the Council of Ministers on 28 October 2026) that may be amended or rejected by Parliament. Figures are as reported by the Italian press on 30 October 2026 and have not been checked against the final statutory text. It is not legal or tax advice and does not invite anyone to avoid lawful obligations. Any transfer of residence must be genuine and implemented with qualified professional advice. Case studies cited from the book are composites. Opinions are the author’s own. The author has a commercial interest in the book cited.