Italy’s planned exit tax would bill departing crypto holders for paper gains

Picture a Milan software engineer who bought bitcoin years ago, now holds €1 million worth of it, and plans to move to Lisbon in 2027. Under a clause tucked into Italy's draft budget, she could owe tax on the gain before she has sold a single coin. Article 17 of the 2027 budget bill would make long-term residents who leave the country pay tax on the paper profits they built up while living there, as long as their assets reach €800,000.

The government has framed the measure as closing a gap for wealthy investors. Crypto media have framed it as a 33% exit charge on token holders. The official summaries say 26% and do not mention crypto at all. Which reading is right will decide how much a departing holder pays, and Parliament has until the end of December to settle it.

Who would pay, and when

The bill went to the Chamber of Deputies on Oct. 30, two days after Prime Minister Giorgia Meloni's cabinet approved a €26 billion budget package, according to IMI Daily. The exit tax sits in a 157-article text that also cuts income tax for middle earners and raises levies on banks, insurers and energy companies.

The test has three parts. A person must have been an Italian tax resident for at least six of the ten tax years before leaving. The move must take effect on or after Jan. 1, 2027. And their combined assets and rights must be worth at least €800,000, measured at the end of the year before departure. Italy also has to lose its right to tax the income as a result of the move, which is the normal outcome under tax treaties that follow the OECD model.

What gets taxed is the gap between each asset's market value and its cost for tax purposes, added up across the portfolio. It is not a wealth tax. Someone sitting on €900,000 of cash with no gains would owe nothing. According to Italian news agency AGI, which summarized the government's technical report, the rate is 26%. Government bonds get a reduced base of 48.08% of the gain, which works out to an effective 12.5%.

Payment is due within 180 days of the move. People relocating to another EU country, or to a country that has a tax cooperation agreement with Italy, can defer most of it. They pay half up front, post a guarantee, and settle the rest only if they sell. The deferral lasts up to five tax years for EU destinations and up to ten for other qualifying countries. If the assets are still unsold at the end, the tax lapses and the advance is refunded. The same happens if the assets pass to heirs or the person moves back to Italy.

IMI Daily worked through an example: a long-term resident moving to Spain with a €2 million share portfolio bought for €1.2 million would face €208,000 on the €800,000 gain, with €104,000 due right away.

Where the 33% figure comes from

Crypto news sites, starting with Chinese-language outlets on Nov. 1, reported that departing token holders could pay as much as 33%. The number is not invented. Italy raised its tax on crypto gains from 26% to 33% from Jan. 1, 2026, under the 2025 budget law, and the 2026 budget confirmed that rate. Gains on euro-denominated e-money tokens, the regulated stablecoins defined under the EU's MiCA rules, stayed at 26%. The old €2,000 tax-free allowance for crypto gains was scrapped in 2025.

The draft taxes each gain under the ordinary rules for its type of income, according to AGI's summary. That is the reasoning behind the 33% reading: if bitcoin gains are taxed at 33% when sold, they could be taxed at 33% when deemed sold at the border. But neither AGI's summary nor Italian business coverage of Article 17 mentions crypto-assets. The technical report lists gains on shareholdings, securities and other financial instruments. Whether tokens count, and at which rate, is something the government has not spelled out.

For the engineer in the example, the difference is real. On a hypothetical €800,000 gain, 26% is €208,000 and 33% is €264,000.

A small sum with a long reach

The money involved is modest. The technical report projects €3.37 million in revenue in 2027 and €6.74 million a year from 2028 through 2031. That first-year figure is roughly what Italy collects from about 11 wealthy newcomers under its flat-tax regime, which charges new residents €300,000 a year on foreign income.

That regime is part of why the proposal drew attention abroad. About 3,600 millionaires moved to Italy in 2025, according to Henley & Partners figures cited by The Telegraph, putting it behind only the United States and the United Arab Emirates. Until now, Italy let private investors leave without a deemed sale, even though it already applied the principle to companies and sole traders under Article 166 of its income tax code. The government's stated aim, according to Italian business press, is to stop people from moving abroad just to realize gains out of Italy's reach.

Critics say the drafting is too loose to judge. Federico Salmoiraghi, quoted by IMI Daily, called the measure "poorly defined, leaving considerable room for doubt and interpretation." He argued that uncertainty could put off wealthy people thinking of moving to Italy, at a cost larger than the revenue, and urged the government to rewrite or withdraw it.

There is also legal history. In 2004, in the de Lasteyrie du Saillant case, the EU Court of Justice ruled that France's original exit tax on individuals breached the freedom of establishment. It also found that making deferral depend on a guarantee was itself a restriction. France rewrote its rules and now grants automatic deferral without a guarantee for moves within the EU and European Economic Area. Italy's draft uses the same six-of-ten-year test and the same €800,000 threshold as France, but asks for a 50% advance and a guarantee. Published accounts do not say whether Switzerland or the UAE, two common destinations for wealthy Italians, would qualify for deferral.

What exchanges will tell Rome

For crypto holders, the exit tax lands on top of a reporting system that is already running. Since Jan. 1, 2026, crypto service providers across the EU have had to collect data on their customers' purchases, sales and transfers under DAC8, the bloc's tax transparency directive. Providers hand that data to their home tax authority the following year, and authorities swap information on foreign residents. The first exchange, covering 2026, is due by Sept. 30, 2027.

In practice, an Italian resident's holdings at an EU-licensed exchange will be visible to Italian tax officials whether or not that person plans to leave. The exit tax decides what happens to those gains when they do.

The budget is the last one Meloni's government will pass before the general election due in 2027, and lawmakers can still amend Article 17 before the final vote. Parliament normally approves the budget in the last days of December. If the clause survives, the first moves it can catch are those dated Jan. 1, 2027.

This article is for information only and is not investment advice.

Sources

• AGI · Manovra: anche la tassa sui super ricchi che lasciano l'Italia
• IMI Daily · Italy budget bill proposes 26% exit tax on residents leaving with €800,000 or more
• The Telegraph via Yahoo · Meloni targets Italy's wealthy with 'exit tax'
• Money.it · Criptovalute, tasse in Italia: come funziona
• KuCoin News · Italy proposes a 33% exit tax on crypto holders leaving the country
• European Commission · DAC8