Italy's Exit Tax from 2027: Rate, Threshold, and How It Compares to Germany and Austria

Starting January 1, 2027, Italy plans to introduce an exit tax (Wegzugsteuer) of 27–33% on unrealized gains for anyone whose assets exceed €800,000 — and the bill still has to clear parliament in November 2026.

In short

• Italy’s exit tax rate is 27–33% on unrealized gains for assets over €800,000, and the entire sum is taxed, not just the excess.
• Only those who were tax residents of Italy for at least 6 of the last 10 years fall under the tax — regardless of citizenship.
• Relocating to the EU or to a country with a double-taxation treaty means paying 50% of the amount, with the rest covered by a bank guarantee.
• The payment deadline is 180 calendar days after leaving Italy.
• It remains unclear whether the tax will reach users of special regimes: 7% flat-rate retirees, non-dom holders, and impatriati.

When Italy’s Exit Tax Takes Effect

The bill still has to pass through the Italian parliament in November 2026 — just weeks before the rule is meant to take effect. Nothing about these plans was announced publicly before the end of 2026; the decision arrived without advance notice.

That compressed timeline leaves little room for anyone potentially affected to prepare: only about a month separates the bill’s passage through parliament from the date the tax is set to begin. How much the final text of the law will differ from the draft currently under discussion is not clear from the available information.

The Tax Rate and Which Assets It Covers

The exit tax rate will run from 27% to 33%, charged on unrealized gains — that is, on the increase in value that hasn’t yet been locked in through a sale. The tax applies to all assets except real estate: foreign currency, gold, cryptocurrency, and stakes in partnerships and capital companies. Real estate is explicitly carved out; everything else is covered.

The threshold for falling under the tax is assets worth more than €800,000. This isn’t a tax-free allowance — the tax isn’t charged on the amount above the threshold, but on the entire capital sum. If someone holds €900,000 in assets, the tax is calculated not on the €100,000 difference, but on the full €900,000.

This isn’t a tax-free allowance — the tax isn’t charged on the amount above the threshold, but on the entire capital sum.

Italy has never had a personal exit tax before. After 2022, as part of an EU anti-tax-avoidance directive, the country introduced what’s known as exit taxation — but only at the corporate level, when a business moves its assets abroad. That didn’t touch personal exit taxation.

Parameter	Value
Rate	27–33%
Asset threshold	over €800,000
Nature of the threshold	not a deduction — the full amount is taxed
Excluded assets	real estate
Taxable assets	currency, gold, crypto, company stakes

Who Falls Under the Tax Based on Residency Period in Italy

The tax applies to anyone who was an unlimited tax resident of Italy for at least 6 of the last 10 years (c13, c17). That timeframe is the key condition: without it, the exit tax doesn’t apply, no matter how much in assets someone holds.

Leaving in a rush before the end of 2026 doesn’t exempt someone who has already crossed that threshold (c11). The decisive factor is the tax year preceding the departure itself — meaning resident status is locked in ahead of time, not at the moment of leaving. If someone has already lived in Italy for the required period, they remain within reach of the tax even if they leave before the end of the year (c12).

Leaving in a rush before the end of 2026 doesn’t exempt someone who has already crossed that threshold (c11).

The flip side of the rule: someone who hasn’t yet reached 6 years of residency can still leave the country without this tax for now — not just in 2026, but the following year and the year after that, as long as the threshold hasn’t been reached (c23).

The rule applies not only to Italian citizens but to foreigners as well: if someone has lived in the country for at least 6 of the last 10 years and holds assets that fall under the tax, citizenship doesn’t matter (c29).

The EU Relocation Relief and the Payment Deadline

For anyone relocating within the EU, or to a country that has a double-taxation treaty with Italy, only 50% of the exit tax is due upfront, not the full amount (c14, c18). The remaining 50% doesn’t need to be paid immediately — a bank guarantee can be provided to the government to cover that portion instead (c15, c19).

The amount that is due must be transferred within 180 calendar days of leaving Italy (c16, c20). For anyone relocating outside the EU and outside the countries covered by a tax treaty, the 50% relief doesn’t apply, though the 180-day countdown still starts from the date of departure.

Open Questions: Italy’s Special Tax Regimes

Whether the exit tax applies to users of Italy’s special tax regimes remains unresolved (c21). This concerns three groups: retirees living in Italy who pay a flat 7% rate on foreign pensions and other foreign income such as investment income, holders of non-dom status, and those using the impatriati regime (c21, c22).

For each of these categories, whether they fall under the new tax is still an open question — there’s no clarity on this point yet (c21). In the meantime, while clarity is lacking, it’s reasonable to assume the tax could apply to these categories too — anyone who is an unlimited taxpayer in Italy would be wise to think through their next steps in advance (c21).

Germany’s Exit Tax: How It Differs from Italy’s

Germany’s exit tax (Wegzugsteuer) currently applies only to those who hold at least 1% of the capital in a foreign company — for example, a German GmbH or a Swiss AG (c24). Freely traded shares (“dispersed ownership”) fall outside this tax — and that’s exactly the approach Germany hasn’t applied so far, while Italy has now built it into its own model (c25). Germany’s tax also doesn’t cover precious metals, cryptocurrency, or other assets — only stakes in capital companies (c26).

Freely traded shares (“dispersed ownership”) fall outside this tax — and that’s exactly the approach Germany hasn’t applied so far, while Italy has now built it into its own model (c25).

Since 2024, the rule has been widened: ETFs are now caught by the exit tax if at least €500,000 has been invested in them (c34). That’s already a precedent — Germany is finding ways to extend the tax beyond company stakes.

Further tightening is seen as nearly inevitable: Germany’s exit tax has already been strengthened twice in the past five years, and it’s expected not to stay limited to the 1% capital-stake threshold (c32, c33, c58, c59). For now, though, the German model only covers business assets — anyone without a stake in a company, holding only freely traded shares, falls outside the current version of the tax (c55, c56).

Austria’s Exit Tax: How It Differs from Italy’s

Austria’s exit tax is softer than Italy’s in one respect and tougher in another (c27). Softer — because Austria doesn’t apply the 6-year unlimited tax residency condition that serves as Italy’s threshold for triggering the tax: the absence of that waiting period theoretically eases the situation, but it also means Austria’s tax can apply without any waiting period at all (c28). Tougher — in terms of asset coverage and how long it’s been in force: Italy is only now introducing an equivalent rule, while Austria’s exit tax has applied to private capital assets (privates Kapitalvermögen) since 2016 (c35).

In practice, Austria’s tax already affects wealthy asset holders, even though not every asset class falls under it yet (c38). Cryptocurrency is already on that list — Austria’s exit tax currently extends to crypto as well (c39).

Are GmbH, SICAV, and Fund Structures Taxed?

In Italy, holding structures don’t shield anyone from the exit tax: structures such as GmbHs and SICAVs fall under it too (c40). That sets Italy’s model apart from Germany’s: in Germany, GmbHs and investment funds don’t fall under the Wegzugsteuer (c41).

Another option is setting up a foundation (Stiftung), but it’s not yet clear whether that route will remain available going forward (c42). On top of that, setting up a foundation triggers gift tax considerations — a separate tax from the exit tax, applied to the transfer of assets into the foundation itself (c43).

Exit Tax in Italy, Germany, and Austria: Key Differences

Table scrolls sideways

Criterion	Italy	Germany	Austria
Residency condition	6 of the last 10 years	not specified in the source	no such condition
In effect since	being introduced in 2026	in effect, tightened twice in 5 years	since 2016
Asset coverage	all assets except real estate, including GmbH and SICAV	stakes of 1%+ in a company; ETFs from €500,000 since 2024	private capital assets, including cryptocurrency
Rate	27–33%	not specified in the source	not specified in the source

Data reflects what’s stated in the article; not every parameter for Germany and Austria is specified in it.

Frequently asked questions

What happens if you leave Italy before reaching 6 years of residency?

As long as you haven’t accumulated 6 of the last 10 years of unlimited tax residency, you can leave Italy without triggering the exit tax — and that applies not only to leaving in 2026, but in the years that follow, as long as the threshold hasn’t been reached.