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Country guide

For Italians

Since 2024 Italy has four separate residency tests, and failing any one of them for most of the year keeps you taxable on worldwide income. For Italian citizens moving to a country on Italy’s black list, such as the UAE or Panama, the law presumes you never left until you prove otherwise. Leaving properly means moving your life, not just your address, and keeping the evidence.

How it taxes
Residents on worldwide income; non residents on Italian source income only
Leaving test
No residence, domicile, presence or registry entry in Italy for most of the year (183 days)
Exit tax
Only for businesses that move; none on private shares or property
Dual citizenship
Allowed
General information, not tax advice. Astute Expat is not a firm of tax advisers, and this guide does not take your circumstances into account. Rules change and every situation is different, so speak to your accountant before you act. Our team includes accountants who know Italy and assist our clients when they leave, so the move is done properly and nothing is missed.

How tax residency works

Since 1 January 2024, article 2 of the TUIR, Italy’s consolidated income tax code, makes you tax resident for a year if, for most of it (183 days, or 184 in a leap year), you meet any one of four tests. Italy taxes residents on worldwide income and non residents only on income from Italian sources.

Each test stands alone, so meeting just one is enough. Partial days count as full days. Registration in the anagrafe is now a presumption you can rebut with evidence rather than an automatic rule, and the tie breaker rules in a tax treaty can override it.

Italian domestic law does not split the tax year. If you leave in the second half of the year, you are generally resident for the whole of it.

A special rule applies to Italian citizens. If you deregister and move to a country on the list of privileged tax regimes in the Ministerial Decree of 4 May 1999, you are presumed to remain resident unless you prove otherwise. The list includes the United Arab Emirates, Panama and Uruguay. Paraguay, Georgia and Turkey are not on it.

  • Residence: where you habitually live, as defined in the Civil Code.
  • Domicile: since 2024, the place where your personal and family relationships mainly develop, such as a spouse, partner or children.
  • Physical presence: any time spent in Italy, for any reason.
  • Registration in the anagrafe, the register of the resident population kept by your comune.

Leaving properly

Leaving Italy is a matter of evidence. The authorities look at where your family, home, work and daily life actually are, year by year.

  1. 01

    Register with AIRE

    Within 90 days of moving, register with AIRE, the register of Italians resident abroad, through the consulate for your new address. This removes you from your comune’s register. Not registering carries a fine of €200 to €1,000 for each year, up to five years.

  2. 02

    Move your family life

    Under the domicile test, a spouse, partner or children who stay in Italy can keep you resident on their own. Plan where your family, home and social life will be before you go.

  3. 03

    Count your days

    Stay well under 183 days of presence in Italy each year, counting partial days, and keep flight and entry records.

  4. 04

    Build an evidence file

    Keep a lease or title abroad, local residency, a tax residence certificate, utility bills, school enrolment and local bank statements. If you move to a black listed country, you need this for every year.

  5. 05

    File the final return

    File the Modello Redditi PF return for the year you leave, including the RW section that reports foreign assets, and pay IVIE and IVAFE where due.

  6. 06

    Update INPS and healthcare

    Give INPS your new address and payment details for any pension, and note that AIRE registration ends regular national health service cover.

Exit tax, property and investments

Italy has no exit tax on private individuals. The exit tax in article 166 of the TUIR applies when a business moves its tax residence, including a sole trader with business assets, and taxes unrealised gains on those assets. Private shares, funds and property are not taxed simply because you leave.

While resident you pay IVIE, a tax on property abroad at 1.06% of its value, and IVAFE, a tax on foreign financial assets at 0.2% a year, or 0.4% for assets held in black listed countries. Both stop once you are genuinely non resident. If you are presumed resident after moving to a listed country, they can apply to your new home and accounts there.

Italian property stays taxable in Italy. Non residents pay IMU, the municipal property tax, without the main home exemption; only limited reductions exist for some pensioners registered with AIRE. Rental income is taxed in Italy, where the 21% cedolare secca flat rate is available to non residents.

Gains on shares in Italian companies can remain taxable in Italy for non residents in some cases, depending on the size of the holding and the tax treaty with your new country. Your accountant confirms your position before you sell.

Pensions and social security

INPS, the Italian social security institute, pays pensions abroad, and contributions you have already paid stay on your record. INPS asks for proof of life each year.

Where the pension is taxed depends on the tax treaty and the type of pension. Under many treaties a pension from private sector work is taxed only where you live, while pensions from public employment usually stay taxable in Italy, and some treaties treat INPS pensions differently again. Without a treaty, Italy withholds tax at source.

Registering with AIRE ends regular cover from the SSN, the national health service. Urgent hospital care during visits to Italy remains available for up to 90 days a year. Law 111 of 2026 created a €2,000 annual contribution that lets Italians registered with AIRE and living outside the EU and EFTA buy back access to SSN care in Italy; the procedure depends on an implementing decree, so we confirm whether it is open before you count on it.

Dual citizenship

Italy has allowed dual citizenship since Law 91 of 1992. Acquiring a second citizenship by residence, naturalisation or investment does not affect your Italian citizenship, and children born abroad to a parent born in Italy are still Italian at birth.

For context, Decree Law 36 of 2025, converted into Law 74 of 2025, narrowed citizenship by descent for people born abroad who hold another citizenship. Automatic citizenship now generally requires a parent or grandparent born in Italy, or a parent who lived in Italy for two continuous years after becoming Italian and before the birth. The Constitutional Court upheld this limit in 2026. It does not affect people who already hold Italian citizenship.

Avoid these

Common mistakes when leaving

  • Registering with AIRE but leaving a spouse or children in Italy. Since 2024 domicile follows your personal and family relationships, and that alone can keep you resident.
  • Moving to the UAE, Panama or Uruguay without a year by year evidence file. For Italian citizens the burden of proof is reversed for black listed countries.
  • Leaving in the second half of the year and expecting to be taxed on only part of it. Italian law does not split the tax year.
  • Not registering with AIRE at all. It now carries annual fines, and staying in the anagrafe leaves a presumption of residence you have to rebut.
  • Forgetting IVIE, IVAFE and the RW section in the final return for foreign property and accounts held while still resident.
  • Assuming national health service cover continues after registering with AIRE. Only urgent care during visits remains unless you pay the new annual contribution once it is available.
FAQ

Questions from Italians

Do I still pay tax in Italy after I leave?

Once you are genuinely non resident, only on Italian source income, such as rent from Italian property or a pension from Italian public employment. That means meeting none of the four tests for most of the year. If you move to a black listed country, you must also be able to prove the move is real.

Which countries trigger the presumption of residence?

Those listed in the Ministerial Decree of 4 May 1999, including the United Arab Emirates, Panama, Uruguay, Monaco, Singapore, Hong Kong and several Caribbean states. Switzerland was removed from 2024. Paraguay, Georgia and Turkey are not listed.

Can I keep my house in Italy?

Yes. You pay IMU without the main home exemption, and rent is taxed in Italy. A home kept for your own use, especially with family living in it, supports an argument that your domicile is still Italian, so think about how it will look.

Can I keep my Italian company?

You can keep the shares. Where the company is managed from matters for its own tax residence, and a business that moves abroad, including a sole trader’s business, can trigger exit tax under article 166. Plan the structure before you go.

Will my INPS pension follow me?

Yes, INPS pays pensions abroad. Whether Italy or your new country taxes it depends on the tax treaty and on whether the pension comes from private or public employment.

Can I still use the Italian health service?

Registering with AIRE ends regular cover. Urgent care during visits remains, and Law 111 of 2026 lets Italians living outside the EU and EFTA buy access for €2,000 a year once the procedure is in place.

Do I lose my Italian citizenship?

No. Italy allows dual citizenship, so taking a second one by residence, naturalisation or investment does not affect it.

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