The article focuses on the proposed exit tax included in Italy’s draft Budget Law and its potential implications for Italian tax residents who plan to, or have already taken steps to, relocate to another jurisdiction. Among other leading advisers, Luigi Belluzzo commented on the new-resident regime under Article 24-bis of the Italian Income Tax Code (TUIR) and on the potential effects of the proposed rules, which are expected to apply to qualifying changes taking effect from 1 January 2027. The article discusses a measure that would subject certain capital gains accrued during Italian tax residence to a 26% tax upon relocation abroad, including unrealised gains, and considers its potential impact on Italy’s—and Milan’s in particular—attractiveness to internationally mobile high-net-worth individuals. A broadly shared view among Italian advisers is that the proposed rule should not apply to taxpayers who have elected for the new-resident lump-sum tax regime. However, clarification during the parliamentary process is now more important than ever.
The contribution brings the Firm’s perspective to the international press on a highly topical issue. The full article is available on The Telegraph website: Italy lured wealthy elites with low taxes. Now they’re in Giorgia Meloni’s crosshairs
For many years, the Firm has advised international individuals and families, drawing on its own offices and a network of leading international correspondents, with offices in Milan, London, Lugano, Abu Dhabi, Verona, Rome and Singapore.
