Italy's draft 2027 Budget Law proposes a 26% exit tax on unrealised financial gains for individuals transferring tax residence abroad, higher Financial Transaction Tax rates (FTT), increased IRES surcharges on financial and insurance companies, and new tax incentives for cloud computing, alongside the repeal of the national handling fee on low-value imports.
Italy’s government has presented the draft Budget Law for 2027 to the parliament on 30 October 2026. It was earlier approved by the Council of Ministers on 28 October 2026.
The main tax measures are as follows:
Exit tax on unrealised financial gains
- Scope and thresholds: Effective 1 January 2027, an exit tax applies to individuals transferring their tax residence outside Italy who have been tax resident in Italy for at least 6 of the 10 tax years preceding the transfer. The scope covers unrealised financial capital gains where the aggregate fair market value of the financial assets and rights is at least EUR 800,000. The measure also extends to non-commercial simple partnerships, equivalent entities, and non-commercial entities.
- Tax rate & tax base: The tax rate is set at 26%. For government bonds and eligible public debt securities, the taxable base is reduced to 48.08% to maintain an effective tax rate equivalent to the standard 12.5% rate.
- Payment terms & deferral option: Tax is generally payable within 180 days of transferring tax residence. Eligible taxpayers relocating to EU Member States or qualifying non-EU jurisdictions may defer payment by paying 50% upfront and providing an adequate guarantee.
- Duration & cessation of tax: Deferral lasts five tax years for EU destinations and 10 years for qualifying non-EU destinations. Tax on unsold assets ceases after the relevant period, upon the taxpayer’s death, or upon returning tax residence to Italy, with excess payments refunded.
Increase in financial transaction tax rates
The budget doubles the Financial Transaction Tax (Tobin Tax) rates from 1 January 2027, increasing the standard rate from 0.4% to 0.8%, the reduced rate for regulated market transactions from 0.2% to 0.4%, and the high-frequency trading rate from 0.04% to 0.08%.
IRES surcharges on financial intermediaries & insurance companies
- Financial intermediaries surcharge: Increases the existing Corporate Income Tax (IRES) surcharge by 3 percentage points (raising the surcharge rate from 3.5% to 6.5%) for the 2027 and 2028 tax periods. This applies to financial intermediaries and Banca d’Italia, but explicitly excludes Electronic Money Institutions (IMEL), Asset Management Companies (SGR), and Investment Firms (SIM).
- Insurance companies surcharge: Introduces a temporary 3% IRES surcharge for insurance and reinsurance companies for the 2027 and 2028 tax periods.
- Deduction allowance: Both measures incorporate an annual tax deduction of up to EUR 200,000 per entity for each tax period, applicable up to the additional tax generated by the surcharge.
Tax credit for cloud computing
The budget introduces a tax credit of up to 30% of qualifying subscription costs incurred in 2027–2029 for cloud computing services and software linked to advanced intangible capital goods. The incentive is available to resident enterprises and domestic permanent establishments of non-resident enterprises, subject to an annual expenditure ceiling of EUR 30 million. The credit can be used through F24 offset compensation, is exempt from standard annual compensation limits, and is excluded from IRES and IRAP taxation.
Abolition of the EUR 2 handling fee on low-value consignments
The budget law repeals Italy’s national EUR 2 administrative handling fee on low-value consignments imported from non-EU countries, valued at up to EUR 150, effective 1 January 2027.
The repeal follows the introduction of a standardised EU-wide EUR 2 Union handling fee and a EUR 3 flat customs duty per item under EU Regulation 2026/2108 and Delegated Regulation C(2026)6694, following the removal of the customs duty exemption for low-value imports. The change aims to avoid duplicate charges by replacing the national fee with the harmonised EU-level system.
