Italy makes leaving sound simple: register with AIRE, and the anagrafe forgets you. The Agenzia delle Entrate has a longer memory. Since 2024 it looks at where you live, where your family is and how many days – or hours – you spend on Italian soil.
This guide covers how Italian tax residency ends after the 2024 reform, why there’s (almost) no exit tax, what stays taxable after the move and a practical 12-month plan. It’s general information as of September 2026, not tax advice.
Who this guide is for#
Anyone living in Italy and moving abroad for good: employees, freelancers, founders, retirees and expats moving on. It matters most if your family stays behind for a while, you’re heading to a low-tax country, you run a business or you hold foreign investments that IVAFE currently taxes. Leaving Germany instead? Read leaving Germany.
How Italian residency ends#
Legislative Decree 209/2023 rewrote article 2 of the income tax code (TUIR) from the 2024 tax year. You’re resident in Italy for a tax year if, for the greater part of it (183 days, 184 in a leap year), at least one of these applies:
- Residence in the civil-law sense: your habitual place of living is in Italy.
- Domicile, now defined as the place where your personal and family relationships are mainly based. Business ties matter less than before; spouse, children and home matter more.
- Physical presence in Italy. The Agenzia delle Entrate’s Circular 20/E of 2024 says fractions of days count, however short. A late flight out is still a day in.
- Registration in the anagrafe (the resident population register) – but since 2024 only as a presumption you can rebut by showing none of the other tests applied.
Days don’t need to be consecutive. And because the test runs over the whole tax year, Italy has no split year in its domestic law: you’re resident for the entire year or not at all. Leave on 30 June in a normal year and you can stay under 183 days of presence; leave in September and you’re resident, with worldwide income, until 31 December.
AIRE: required, just not decisive#
Italian citizens who move their habitual residence abroad for more than 12 months must register with the AIRE, the register of Italians resident abroad, within 90 days of the move – usually online through the consulate’s Fast It portal. The municipality then cancels you from the resident register.
Since 1 January 2024, failing to register costs €200 to €1,000 for each year, for up to five years, imposed by your last municipality. After the reform, AIRE registration no longer protects you by itself, but not registering is now expensive and leaves the anagrafe presumption pointing at Italy.
The black-list presumption#
Article 2(2-bis) TUIR survived the 2024 reform unchanged. Italian citizens who deregister and move to a state on the list of privileged tax regimes for individuals (the ministerial decree of 4 May 1999) are presumed to remain Italian residents. The burden of proof flips to you: lease, utilities, work, bank activity, family, social life – all abroad and documented.
At the time of writing the list includes Monaco and the UAE, among others. Switzerland was removed from 2024 onwards, and Cyprus and Malta are no longer on it. Check the current list before you book the flight.
Two residencies: the treaty tie-breaker#
If Italy and your new country both claim you, the double tax treaty decides: permanent home, centre of vital interests, habitual abode, nationality. Italy has treaties with most popular destinations, including Portugal, Cyprus, Malta, Switzerland and the UAE. A treaty win limits what Italy can tax, but the black-list presumption still means you carry the evidence. How the tests work elsewhere: tax residency explained.
Exit tax: only for business assets#
Good news for investors: Italy doesn’t tax private individuals on unrealized gains when they move away. Your ETF portfolio, your listed shares and even a qualifying stake in your own Srl can leave with you without a deemed sale.
Article 166 TUIR is the exception, and it targets business. It applies when an enterprise – a company, or an individual running a commercial business (impresa commerciale) – loses its Italian tax residence or moves assets to a foreign permanent establishment.
| Situation | What happens | Source |
|---|---|---|
| Private investor moves abroad | No exit tax on shares, funds or crypto | Art. 166 TUIR only covers businesses |
| Company or sole trader transfers tax residence abroad | Business assets are deemed sold at market value; the gain is taxed with business income | Art. 166 TUIR |
| Move to an EU state, or an EEA state on Italy’s white list with a recovery assistance agreement | Tax can be paid in five annual instalments | Art. 166 TUIR as amended by Legislative Decree 142/2018 |
| Move anywhere else | Due at once | Art. 166 TUIR |
The quiet trap is your company. If you move to Lisbon and run your Milan Srl from your new kitchen, its place of effective management may move with you – and article 166 can then apply to the company. See place of management.
Inbound regimes and the clawback#
Italy’s inbound regimes (the impatriate regime and the flat tax for new residents, see our Italy country guide) don’t matter much for leavers – with one exception. Under the impatriate regime for arrivals from 2024, you commit to staying resident for at least four years. Leave earlier and the benefit is recovered, with interest.
IVIE and IVAFE: the wealth taxes you leave behind#
As a resident, Italy charges two wealth taxes on assets held abroad. Both depend on residence, so they stop once you’re no longer resident.
- IVIE on foreign real estate: 1.06% of the value from 2024 (0.76% until 2023), with a reduced rate for certain main homes. Not due if the amount is below €200.
- IVAFE on foreign financial assets: 2 per mille a year on market value, 4 per mille for products held in states with a privileged tax regime (from 2024). Foreign bank accounts pay a flat €34.20, or nothing if the average balance stays at €5,000 or less.
Both are calculated pro rata for the part of the year you held the asset – not for the months you lived in Italy. Because residence is decided for the whole year, the departure year is all or nothing: resident means full IVIE and IVAFE for that year, non-resident means none.
What stays taxable in Italy#
Non-residents pay Italian tax only on income produced in Italy (article 23 TUIR). As of September 2026, the main items:
- Work done in Italy. Salary for days you physically worked in Italy, and self-employment carried out there.
- Italian property. Rent stays taxable in Italy (you may be able to use the cedolare secca flat-rate option). IMU remains due, and the main-home exemption normally no longer applies once you don’t live there.
- Italian dividends. 26% is withheld for non-residents; your treaty may cut it, often via a refund claim.
- Pensions. Which country taxes them depends on the treaty; public-sector pensions usually stay with Italy.
- Not taxable: interest on Italian bank deposits and gains on non-qualifying holdings in Italian listed companies are excluded for non-residents by article 23.
IRPEF runs at 23%, 33% (cut from 35% by the 2026 budget law) and 43%, plus regional and municipal surcharges. As a non-resident you file a Redditi PF return if you have Italian income beyond what’s already covered by withholding.
Social security and health insurance#
- SSN. Moving your residence abroad and registering with AIRE ends your regular enrolment in the national health service. Inside the EU/EEA and Switzerland, Regulation 883/2004 decides which country insures you, usually the one where you work; Italian pensioners use an S1. Outside, AIRE members with emigrant status or an Italian pension are entitled only to urgent hospital care in Italy, for up to 90 days a year. Plan private or local cover from day one.
- INPS. Your contributions stay on record. Within the EU/EEA and with treaty countries, periods abroad are combined when you retire. Voluntary contributions may be possible if your contribution history meets INPS’s minimums.
- Tell your ASL and INPS. Hand back your GP registration, update INPS with your foreign address and bank details if you receive benefits or a pension.
Banks, brokers and accounts#
- Italian accounts can usually stay open. Tell the bank your new address and tax residency. Under the Common Reporting Standard (CRS) it reports to your new country.
- Regime amministrato. In the administered regime, your Italian bank or broker withholds 26% on capital gains and income automatically. Once you’re non-resident, much of that is no longer Italian-source – but the bank only stops if you give it a declaration of non-residence. Do it before you sell anything.
- Foreign brokers flip the other way. While resident, you declared them in the RW section and paid IVAFE. From the first full non-resident year, both end.
- Some institutions drop non-residents, especially outside the EU. More: offshore banking.
Your exit, step by step
Pick a date that works for the 183-day test
Aim to leave before July so that presence, home and family are all abroad for most of the year. Remember that fractions of days count.
Check the black list
If your destination is on the individuals’ list, plan your evidence: lease, work, bank, family and daily life abroad from day one.
Move the family and the home
Domicile follows personal and family relations. A partner and children staying in Italy can keep you resident.
Register with AIRE
Within 90 days via Fast It. It’s mandatory, free and avoids the €200–1,000 annual fine.
Sort business, banks and the last return
Check article 166 if you run a business, give banks a non-residence declaration and file the Italian return for the departure year if you were resident.
Traps we see all the time
The September departure.
Leave on 2 July or later and you’re usually resident for the whole year, worldwide income and IVAFE included.
Family stays in Milan.
Your domicile – the centre of personal and family relations – may still be in Italy.
AIRE as a magic wand.
Registration is required, but since 2024 facts beat registers.
Dubai without evidence.
The UAE is on the black list. No proof, no exit.
The Srl on autopilot.
Managing your Italian company from abroad can move its residence – or keep yours in Italy.
The forgotten regime amministrato.
No non-residence declaration, and the bank keeps withholding 26% as if you never left.
Worked example: June or September?#
Illustrative numbers only. Marco, a software architect from Milan, takes a job in Dubai. He holds €500,000 of ETFs with a foreign broker. His family moves with him, and he registers with AIRE. The only question: leave on 20 June 2026 or on 20 September 2026?
| Marco leaves 20 June 2026 | Marco leaves 20 September 2026 | |
|---|---|---|
| Days in Italy in 2026 | 171 | 263 |
| Italian tax status for 2026 | Non-resident (if home and family are abroad too) | Resident for the whole year |
| Dubai salary Sep–Dec (€50,000) | Not taxed in Italy | Taxed in Italy at up to 43% plus surcharges – roughly €21,500+ |
| IVAFE on the ETFs (2 per mille) | €0 | €1,000 |
| Black-list presumption | Applies – he must prove the move | Applies from 2027 |
Three months can cost more than twenty thousand euros. Either way, Marco needs the evidence folder for Dubai. Want to compare the ongoing tax side in the new country? Try our tax calculator.
Leaving Italy: from 12 months to day zero
Tick them off – your progress is saved in this browser only.
List Italian and foreign assets, property, pensions and future income. Check whether you run a business caught by article 166 or benefit from an inbound regime with a clawback.
Compare tax, residency rules and life in the country guides. Check the treaty with Italy and whether the country is on the black list.
Plan to be gone before July. Count days, including partial ones.
Decide who manages your Srl after the move and from where. Look at company formation if you want a new structure abroad.
Apply for your residence permit, secure a long-term lease and open a local bank account.
Plan the family’s move and schools. Sell, let long-term or give notice on your Italian home.
Tell banks and brokers, prepare the non-residence declaration for the regime amministrato and arrange health cover abroad.
Register with AIRE through Fast It within 90 days of the move. Keep every confirmation.
Register with your new tax authority and request a certificate of tax residence for banks and treaty relief.
If you were still resident in the departure year, file it with RW and IVAFE. Otherwise, file only for Italian-source income.
FAQ#
Does AIRE registration end my Italian tax residency?
Not by itself. Since 2024 the anagrafe is only a rebuttable presumption; the real tests are residence, domicile and physical presence for more than half the year. But AIRE registration is mandatory, and skipping it costs €200 to €1,000 per year.
Does Italy have an exit tax on my shares?
Not for private individuals. Article 166 TUIR only covers business assets of companies and entrepreneurs. Your ETFs and private shareholdings leave without a deemed sale.
Is there a split year when I leave Italy?
Not under Italian domestic law. Residence is decided for the whole tax year, based on more than 183 days (184 in a leap year). Leave early enough in the year and you can be non-resident for the entire year.
I’m moving to Dubai. What changes?
The UAE is on Italy’s black list for individuals, so as an Italian citizen you’re presumed to remain resident until you prove a real move. Collect evidence from day one and keep your family’s life abroad too.
Do I still pay IVAFE after I leave?
No. IVIE and IVAFE only apply to Italian residents. In the departure year it’s all or nothing: resident for the year means full IVAFE, non-resident means none.
The fine print#
Everything here is general information, not tax or legal advice. The rules fit on a page; proving where your life really is, especially from a black-listed country, is where a second pair of eyes pays off. Want your exit plan checked before you go? Book a strategy session.
Sources#
- Art. 2 TUIR (DPR 917/1986) – tax residence of individuals (Normattiva)
- Art. 23 TUIR – taxation of non-residents (Normattiva)
- Art. 166 TUIR – exit tax for businesses (Normattiva)
- Legislative Decree 209/2023 – international tax reform (Normattiva)
- Law 213/2023 – 2024 budget law incl. AIRE sanctions, IVIE and IVAFE (Normattiva)
- Agenzia delle Entrate – Circular 20/E of 4 November 2024 on tax residence
- FiscoOggi (Agenzia delle Entrate) – the new residence rules explained
- Ministerial Decree of 20 July 2023 – Switzerland removed from the list (Gazzetta Ufficiale)
- Agenzia delle Entrate – IVAFE rates
- Agenzia delle Entrate – IVIE rates
- Agenzia delle Entrate – IRPEF rates
- MEF – main measures of the 2026 budget law
- Agenzia delle Entrate – impatriate regime from 2024
- Ministry of Foreign Affairs – AIRE registration
- Consulate General in London – sanctions for failing to register with AIRE
- ATS Brianza – healthcare for Italians registered with AIRE
- Regulation (EC) No 883/2004 – coordination of social security systems
