Italy Bills 26% to Leave

Italy bills 26% to leave. Article 17 of the budget bill sent to parliament on 30 October would tax the unsold gains of anyone who moves out after six of the last ten years, once the financial assets they hold are worth at least €800,000. The same day, the US Treasury published its quarterly table of people who had left the American tax system in the quarter to September. The table prints no total; a count of its rows gives 1,331 names. One document puts a price on departure; the other counts departures, and neither mentions the other.

A bidding war becomes a lock-in

For years, the competition for wealthy movers was fought over the front door. Countries offered a flat tax on foreign income, an investor visa, a break on funds brought home for the first ten years. An exit charge works the other way: it leaves the income you earned while resident alone, and it taxes the gain you have not yet taken at the moment the plan stops, which makes the second move more expensive than the first.

I laid the Italian text next to the US list and looked for the sentence where one acknowledges the other, and it is not there. The invoice lands when a family is re-pricing the whole plan: a five-year posting that turns into eight, a retirement that moves once more to be near children. It lands with a figure the entry brochure never printed. The model is French, and IMI Daily reads article 167 bis of the French tax code as using the same six-of-ten test and the same €800,000 figure. It notes that Italy and Portugal were two of the most popular destinations that let a resident go without first selling everything on paper [8]. What is new is that a country still selling residence has joined the states that charge for departure — and that the sale and the charge now sit in one document.

The American ledger shows the size of that flow. The third-quarter notice is 16.4% shorter than a year earlier, 261 names fewer. The first three quarters of 2026 total 4,573, against 3,934 in 2025 — up 16.2% [1][2][9][10][11][12]. That is a jumpy series, not a wave and not a trickle. Every name in it is someone who made the decision Italy now wants to make dearer.

The US charge is worth setting out, because the Italian draft copies its shape. America treats all property as sold the day before departure. It excludes $910,000 of gain for 2026. It calls you a covered expatriate if your average tax over the past five years is above $211,000, if your net worth reaches $2 million, or if you cannot certify five clean years of tax compliance [5][6][7]. The net-worth line is fixed by statute; the income line rises with inflation each year.

By the numbers

€800,000 — Asset test: the threshold counts the stakes and securities a person holds, not the gain being taxed [3].
26% — Rate, cut on state debt: the rate is 26%, and the base falls to 48.08% for government bonds — 12.5% in effect, by desk arithmetic [4].
180 days — Payment clock: the bill gives 180 days from the move, and a deferral needs a 50% advance plus a guarantee [3].

What I’d watch before December

The six-of-ten test is the first filter, and it is a calendar question: an arrival inside the last three years sits outside the charge, as does a move that leaves Italy able to tax the same income. The deferral is the second. Someone heading to another EU state can postpone the balance by paying half up front and posting a guarantee, with five tax years to sell. Outside the EU the window is ten, and only for states that share tax data and help collect [3]. If nothing is sold inside the window the charge falls away. So does it on death, or on a return to Italy [3].

What I am watching next is the committee stage. The bill went in on 30 October and parliament usually passes a budget by the end of December, so article 17 can still be amended, narrowed or dropped. An adviser quoted by the migration press has already called for it to be withdrawn [8]. A relocation model that prices the entry regime and the years of residence but stops at the move out is missing a column. The expat financial and international tax evaluator is the version of that model that now has to carry one.

On the American side the number to watch is the year’s last list. Three quarters have run 4,573 names, against 4,888 for the whole of 2025, so a quiet fourth quarter leaves the year flat and a busy one puts it above last year [1][2][9][10][11][12][13]. That gap matters because a country that prices exit is usually described as losing people, and the quarterly data has never backed so simple a story.

The catch

The revenue is the tell. The technical report puts the potential take at €13.47 million and the expected figure at €6.74 million a year, €3.37 million of it in 2027 [4]. It also assumes, prudently, that half of every advance comes back as a refund, because an asset nobody sells never owes the tax. Households above the €800,000 line hold 73.1% of Italian household financial wealth. The charge reaches a group that owns most of it and still raises an amount that rounds away beside the budget it sits in. The country’s own emigration rate explains the rest: 0.28% of residents over 15 in 2025 [4].

I could be wrong, but a tax built to raise this little is not a revenue measure. It reads as a statement about which departures a government thinks it can afford, made as the countries selling residence discover that buyers also leave. The draft also leaves its sharpest question open: nothing published says whether a departing flat-tax resident is caught at all, and the French template it follows has never had to answer that either [8]. Until the December vote, the honest version is that one large European destination has decided a departure should cost something — not that the cost is settled.

At a glance

The shift: A country that sells residence is now pricing the exit. The number: 1,331 names on the US list for the third quarter. The risk: It is a draft bill, and deferral costs 50% up front.

Sources

Gini Loh

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Financial Systems Engineer

Gini Loh builds interactive decision engines and analytical frameworks to help professionals optimize compensation, evaluate assets, and automate investments.

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