Italy's Exit Tax: What It Is, When It Tries, How to Calculate It, and How to Legally Avoid It in 2026
The exit tax is the tax Italy levies on unrealized capital gains when an individual or company transfers their tax residence abroad. The objective is to tax the increase in value of assets accrued during their tax residence in Italy, even if the asset has not actually been sold. For individuals, the legal basis isArticle 166-bis of the TUIR(Consolidated Income Tax Code), introduced by Legislative Decree No. 142 of November 29, 2018 (implementing the ATAD Directive 2016/1164/EU). For companies, the exit tax is governed byArticle 166 of the TUIR(Consolidated Income Tax Code), amended by the same decree. The tax is applied as if the assets had been sold at their fair market value at the time of transfer and can reach 26% on capital gains from qualified shareholdings and 43% on business income.
This guide, updated to Circular 28/E of the Italian Revenue Agency (August 1, 2023), Legislative Decree 209/2023 (international tax reform), and the 2024-2025 case law of the Court of Cassation, explains who is subject to the exit tax, which assets it applies to, how it is calculated, when payment can be paid in installments or suspended, and which concrete strategies can legally minimize or eliminate the impact of the exit tax for those moving to Panama or other territorial tax jurisdictions. For entrepreneurs, investors, equity holders, cryptocurrency holders, and professionals planning to transfer their tax residency abroad, this page provides the complete regulatory framework and operational solutions.
Regulatory and operational summary
- Definition: tax on unrealized capital gains upon transfer of tax residence abroad (Article 166-bis of the TUIR for individuals, Article 166 of the TUIR for companies)
- EU regulatory basis: ATAD Directive 2016/1164/EU, art. 5 (exit taxation), implemented by Legislative Decree 142/2018
- Individuals: what is taxed: unrealized capital gains on qualified shareholdings, financial instruments, crypto-assets, UCITS shares, and rights to profits, if the total value exceeds €4 million or the shareholding exceeds 2% of voting rights (1% in regulated markets).
- Companies, what is taxed: the difference between the normal value and the tax value of assets transferred abroad (corporate capital gains)
- Tax rate: 26% on capital gains for individuals; IRES 24% + IRAP 3.9% for companies
- EU/EEA installment plan: Option to pay transfers to EU or EEA countries with tax cooperation agreements in 6 annual installments (Article 166, paragraph 4, TUIR)
- Suspension: for transfers to EU/EEA countries with information exchange, it is possible to suspend payment until the actual transfer of the goods (subject to the release of a suitable guarantee)
- Non-EU countries (Panama, Dubai, Paraguay): no installment payments or suspensions, the exit tax is due immediately with the tax return for the year of transfer.
- Strategy: Advance planning, pre-transfer divestment, portfolio reorganization, crypto-asset redemption, transfer timing
What is the exit tax: definition and legal basis
The exit tax (or exit tax, or fiscal emigration tax) is the mechanism through which the Italian government "crystallizes" and taxes latent capital gains—that is, accrued but unrealized gains—when a taxpayer moves their tax residence out of Italy. The logic is simple: if an asset has increased in value during the years of tax residence in Italy, Italy deems it entitled to tax that increase in value, even if the taxpayer has not sold the asset. The transfer abroad is treated, for tax purposes, as if it had been a fictitious sale at market value.
For individuals, the exit tax is governed byArticle 166-bis of the TUIR(Consolidated Income Tax Act), introduced by Article 2 of Legislative Decree No. 142 of 29 November 2018, which implemented Article 5 of the ATAD Directive (Anti-Tax Avoidance Directive, EU Directive 2016/1164). For companies and commercial entitiesappliesArticle 166 of the TUIR (. The two regulations share the same rationale but differ in scope, thresholds, calculation methods, and payment plan options.
The exit tax is not a new Italian law: it exists in a similar form in Germany (Wegzugsteuer, §6 AStG), France (exit tax abolished in 2019 for individuals but still in force for companies), Spain, the Netherlands, and all EU member states that have implemented the ATAD Directive. The Italian specificity lies in the quantitative thresholds for individuals and the lack of tax breaks for transfers to non-EU countries, which makes planning a transfer to jurisdictions like Panama particularly relevant.
Exit tax for individuals: art. 166-bis TUIR
Article 166-bis of the TUIR applies to individuals who transfer their tax residence from Italy abroad and who, at the time of the transfer, hold shares, financial instruments, crypto-assets, or other assets that have accrued unrealized capital gains. The rule does not affect all taxpayers: it establishes specific quantitative thresholds below which the exit tax is not triggered.
Application thresholds: when the exit tax kicks in
The exit tax for individuals applies exclusively when the shareholdings, securities, and financial instruments held by the taxpayer meet at least one of the following conditions, defined in Article 166-bis, paragraph 1, letters a) and b):
Value threshold: the total value of the equity investments and financial instruments exceeds €4,000,000 (four million). The value is calculated at fair market value (normal value) on the transfer date, not at historical cost.
Participation threshold: The taxpayer holds a stake exceeding 2% of the voting rights or 5% of the capital of a company listed on regulated markets, or exceeding 20% of the voting rights or 25% of the capital of an unlisted company. These thresholds correspond to the definition of "qualifying participation" for tax purposes.
If neither threshold is exceeded, the exit tax does not apply. A taxpayer who transfers residence abroad with a listed equity portfolio worth €3 million, without qualifying holdings, is not subject to the exit tax. This is a key point in planning the transfer.
How to calculate the exit tax for individuals
The calculation follows this logic: upon transfer of tax residence, the unrealized capital gain is determined as the difference between the value of the assets on the date of transfer and their tax-recognized cost (purchase price, possibly revalued). The tax is applied at arate of 26% (substitute tax on capital gains, art. 5, paragraph 2, Legislative Decree 461/1997).
Practical example. An Italian entrepreneur owns 100% of an Italian limited liability company. He incorporated the company with capital of €50,000. After 15 years of operation, the fair value of the stake, determined by an appraisal, is €2,000,000. He decides to transfer his tax residency to Panama. Unrealized capital gain: €2,000,000 – €50,000 = €1,950,000. Exit tax: €1,950,000 × 26% = €507,000. This amount is due even if the entrepreneur has not sold the stake and received nothing.
Second example: diversified portfolio. An investor holds: listed shares worth €3.5 million (cost €1.8 million), a qualifying participation in an unlisted SME worth €800,000 (cost €200,000), and crypto-assets worth €500,000 (cost €100,000). Total value: €4.8 million, above the €4 million threshold. Exit tax on listed shares: (€3,500,000 – €1,800,000) × 26% = €442,000. Exit tax on the SME: (€800,000 – €200,000) × 26% = €156,000. Exit tax on cryptocurrencies (if deemed eligible): (500,000 – 100,000) × 26% = 104,000 euros. Total exit tax: 702,000 euros.
Exit tax for companies: art. 166 TUIR
Article 166 of the TUIR regulates the exit tax for companies and commercial entities that transfer their tax residence abroad or transfer assets (business assets) to a permanent establishment located outside Italy. The rule also applies when an Italian permanent establishment of a foreign company ceases to exist, resulting in the "repatriation" of the assets to the foreign parent company.
The taxable capital gain is determined by the difference between the normal value (fair market value) and the taxable value of the transferred assets. The tax is IRES (corporate income tax) at 24%, plus IRAP (regional business tax) at 3.9% on the value-added component. For companies, the tax base is generally broader than for individuals: it includes real estate, goodwill, trademarks, patents, receivables, inventories, and all other assets.
Example. An Italian LLC decides to transfer its registered office and tax residence to Panama. Its assets include: property listed on the balance sheet for €300,000, with a market value of €800,000; unrecognized goodwill, estimated at €500,000; and trade receivables of €200,000 (tax and fair value are the same). Capital gain from exit tax: (€800,000 – €300,000) + €500,000 = €1,000,000. IRES: €1,000,000 × 24% = €240,000. IRAP: varies based on the region and the composition of the added value. Estimated total: approximately €280,000.
Installment payments and suspension: options for EU/EEA transfers
The ATAD Directive requires Member States to provide for the possibility of paying the exit tax in installments when the transfer occurs to another EU Member State or to a European Economic Area (EEA) state with which a cooperation agreement exists for mutual assistance in the collection of tax debts. Italy has implemented this provision in Article 166, paragraph 4, of the Consolidated Law on Income Tax (TUIR):
Six annual installments. For transfers to EU/EEA countries, the exit tax can be paid in six equal annual installments, with interest calculated at the legal rate. The first installment is due with the tax return for the year of transfer.
Suspension until actual transfer. As an alternative to payment by installments, the taxpayer can request a suspension of exit tax payment until the actual transfer of the assets. In this case, a suitable guarantee (bank guarantee or insurance policy) is required to cover the suspended tax. The suspension ends and the tax becomes immediately due in the event of a transfer of the assets, a subsequent transfer to a non-EU country, bankruptcy proceedings, or failure to renew the guarantee.
Legitimate strategies to minimize the exit tax
The exit tax can be managed, reduced, or in some cases eliminated through perfectly legitimate tax planning strategies, which must be implemented before transferring tax residency. Once the transfer is finalized, the options are drastically limited.
1. Pre-transfer divestment and reinvestment
If capital gains are unavoidable, it may be preferable to realize them (sell the assets) before the transfer, paying the ordinary capital gains tax (26%) and having the net liquidity available for reinvestment in the new country of residence. This strategy is advantageous when the taxpayer intends to liquidate the assets anyway and when the exit tax cost is identical to ordinary taxation. The operational advantage is certainty: a fixed amount is paid on an actual gain, rather than a tax calculated on an estimated value that could be challenged by the Revenue Agency.
2. Reorganization to stay below the threshold
For individuals, the exit tax is not triggered if the total value of the holdings and financial instruments is less than €4 million and no qualifying holdings are held. A reorganization of assets that brings the portfolio below this threshold before the transfer eliminates the exit tax requirement. Possible options include: partial sale of holdings to reduce the percentage thresholds (2% or 20%), distribution of dividends that reduce the value of the holding, or transfer of holdings to trusts or foundations (observing CFC regulations and anti-avoidance provisions).
3. Crypto-asset redemption before transfer
The 2025 Budget Law (Law 207/2024, Article 1, paragraphs 24-29) introduced the option of revaluing cryptoassets by paying a substitute tax of 18% on the value as of January 1, 2025. Those intending to move abroad and holding a significant crypto portfolio can consider the tax exemption: by paying 18% on the current value, the taxable cost is "raised" to market value, eliminating or drastically reducing the unrealized capital gain subject to exit tax. After the tax exemption, if the value has not further increased, there is no capital gain to tax upon transfer.
4. Transfer timing
The timing of the transfer directly impacts the exit tax. If the market is declining and the value of the assets is temporarily depressed, transferring at that time reduces the latent capital gain. Conversely, moving during a market peak maximizes the tax. The timing must also be evaluated in relation to the AIRE: tax residency is lost when, for the majority of the tax period, one is no longer resident in Italy (183-day rule, art. 2, paragraph 2, TUIR reformed by Legislative Decree 209/2023).
5. Effective and complete transfer of residence
The exit tax presupposes the transfer of tax residence. If the transfer is not effective, and the taxpayer maintains domicile, family relations, or a predominant physical presence in Italy, the Revenue Agency may challenge the transfer (as in cases of residing abroad ) and apply both worldwide taxation and the exit tax simultaneously. For this reason, the transfer must be planned down to the smallest detail: AIRE registration, deregistration from the registry, certificate of tax residence in the new country, and actual relocation of the center of vital interests.
Tax reporting requirements: how to file your exit tax
The exit tax must be declared in the Personal Income Tax Form (for individuals) or the Corporate Income Tax Form (for corporations) for the year in which the transfer of tax residence occurs. For individuals, the exit tax gain must be reported in Section RT (financial capital gains). For corporations, it must be reported in Section RF as a positive component of business income.
The taxpayer must determine the fair value of the assets on the date of transfer. For unlisted investments, a sworn appraisal prepared by a qualified professional (chartered accountant, certified public accountant, or registered appraiser with the Chamber of Commerce) is required. For listed investments, the stock market price on the date of transfer is used. For cryptoassets, the market value resulting from exchange platforms on the date of transfer is used.
The tax is paid using the F24 form, with the specific tax code for the exit tax. The payment deadlines are the same as for ordinary income taxes: balance due by June 30th of the following year (with the option of deferring to July 30th with a 0.40% surcharge).
Exit tax and RW framework: coordinated obligations
Transferring tax residence does not automatically eliminate tax monitoring obligations. In the year of transfer, the taxpayer is still required to complete the RW Form for assets held abroad up to the date of transfer. From the year following the transfer, if tax residence is effectively abroad, the obligation to complete the RW Form ceases, as does the obligation to pay IVAFEand IVIE.
Caution: if the transfer is contested by the Revenue Agency as fictitious (tax residence still in Italy due to lack of actuality), the taxpayer may be subject to both the exit tax (paid) and worldwide taxation (with Form RW and property taxes), with the risk of double taxation and penalties for failure to file a tax return in the years following the "fictitious" transfer. This scenario further highlights the need for a genuine and documentable transfer.
Case law and practice on exit tax
ECJ, Case C-164/12 (CDR, 23 January 2014): The Court of Justice upheld the legitimacy of the exit tax provided that the Member State offers the option of paying in instalments for intra-EU transfers. Immediate and full taxation of intra-EU transfers without the possibility of deferral is contrary to freedom of establishment.
ECJ, case C-657/13 (Verder LabTec, 21 May 2015): clarified that the exit tax is compatible with EU law provided that the tax is determined at the time of the transfer but payment can be made in instalments, without the obligation to provide a guarantee if there is no real risk of non-collection.
ECJ, Case C-581/17 (Wächtler, February 26, 2019): In relation to Switzerland (an EEA/EFTA member state), the Court found the immediate and full imposition of the exit tax without the possibility of payment in installments to be disproportionate. This precedent applies to transfers to Switzerland and Liechtenstein, but does not apply to non-EU/EEA countries such as Panama.
Circular 28/E of August 1, 2023 (Revenue Agency): provided operational clarifications on the post-reform exit tax rules, specifying the scope of application, thresholds, methods for calculating the normal value, and the conditions for payment by installments. It confirmed that for non-EU transfers, payment is due immediately and in full.
Cassation Court No. 23842/2025: In a case involving a transfer of residence to Monaco, the Court reiterated that the exit tax applies only when there is an actual transfer of tax residence. If the transfer is fictitious (the individual's foreign residence), the consequences are those of worldwide income taxation, not the exit tax. The two provisions are alternative, not cumulative.
Exit tax and cryptocurrencies: the unresolved issue of 2026
With the increase in the capital gains tax rate on cryptocurrencies to 33% effective January 1, 2026 (Article 1, paragraph 24, Law 207/2024) and the elimination of the €2,000 tax exemption effective 2025, many Italian holders are considering relocating abroad. The issue of the cryptocurrency exit tax is crucial and not yet fully resolved.
The legal issue is this: Article 166-bis of the TUIR refers to "shareholdings, securities, financial instruments, rights, and relationships" that generate income as defined in Article 67 of the TUIR. Since 2023, crypto-assets have been expressly included in Article 67, paragraph 1, letter c-sexies. Therefore, from a literal perspective, if the total value of crypto-assets exceeds the threshold of €4 million, the exit tax should apply. However, ministerial instructions and practice have not yet provided specific operational guidance for cryptocurrencies, leaving some room for uncertainty.
The most prudent strategy for a crypto holder planning a transfer to Panama is as follows: evaluate the 18% tax exemption (if still available), realize the positions before the transfer by paying 26% (or 33% starting in 2026) on the actual capital gain, or move before the portfolio value exceeds the €4 million threshold. In any case, planning should be done with the support of a professional specializing in international taxation.
Exit tax, foreign investment, and CFC: three distinct disciplines
Anyone planning to transfer their tax residency abroad must deal with three separate regulations that may interact but have different prerequisites and consequences:
Exit tax (Article 166-bis of the TUIR): applies upon transfer and taxes unrealized capital gains accrued in Italy. It is paid once, upon exit. The goal is to prevent a move abroad from allowing one to "escape" taxation on increases in value generated during Italian residence.
Foreign transfer (Article 73, paragraph 3, TUIR): This applies when the transfer is not effective; the company or individual is formally abroad but is managed from Italy. The consequence: worldwide taxation on all income, as if the transfer had never occurred. The exit tax becomes irrelevant because the taxpayer is still resident in Italy.
CFC rule (Article 167 of the TUIR): applies after the transfer, when the Italian shareholder (who in this case remains resident in Italy) controls a foreign company located in a low-tax country (effective tax rate <12%). The profits of the foreign company are taxed transparently by the Italian shareholder. The CFC rule does not affect exit tax but applies to those who remain in Italy and hold foreign interests.
The correct path for an entrepreneur wishing to relocate to Panama includes: exit tax planning (possibly pre-transfer transfer or tax acceptance), actual and documented transfer of tax residence (no foreign investiture), and management of CFC compliance for foreign companies that remain connected to Italian resident shareholders (if applicable).
Practical cases: exit tax simulation for typical profiles
Case 1: Digital freelancer with a portfolio below the threshold
An Italian freelancer with a VAT number decides to move to Panama. He holds a trading account with listed shares worth €80,000 (cost €45,000), crypto assets worth €120,000 (cost €30,000), and no company interests. Total value: €200,000, well under the €4 million threshold. No qualifying participations. Result: no exit tax due. The freelancer simply needs to properly file the return for the year of transfer (the last year of Italian residence), complete the RW form for the last time, and close his Italian VAT number (or maintain it if he still has Italian-source income).
Case 2: Entrepreneur with an Italian LLC
An entrepreneur owns 100% of an LLC with a turnover of €2 million and an appraised value of €5 million. Taxable value of the stake: €100,000. Unrealized capital gain: €4,900,000. The value exceeds the €4 million threshold and the stake is qualified (100% > 20%). Exit tax: €4,900,000 × 26% = €1,274,000. Possible strategy: sell the LLC to a buyer before the transfer, paying the same 26% rate on the realized capital gain but having access to the liquidity from the sale. Alternative: accept the exit tax and retain the stake, paying the tax with dividends distributed before the transfer.
Case 3: Crypto holder with relevant wallet
An investor holds Bitcoin and Ethereum worth €6 million, with a historical cost of €400,000. Unrealized capital gain: €5,600,000. If the cryptoassets are exempt from the exit tax (as is likely given the wording of the law), the tax would be: €5,600,000 × 26% = €1,456,000, or €5,600,000 × 33% = €1,848,000 if the 33% rate were applied (starting in 2026). If the taxpayer had taken advantage of the 18% exemption on the value as of January 1, 2025 (assuming the value was 5 million), he or she would have paid 5,000,000 × 18% = 900,000 euros in exemption, but the new tax cost would be 5,000,000 euros. Exit tax on the subsequent revaluation only: (6,000,000 – 5,000,000) × 26% = 260,000 euros. Total cost: 900,000 + 260,000 = 1,160,000 euros, less than the 1,456,000 without exemption. The saving is approximately 296,000 euros.
The five most serious mistakes in exit tax management
1. Not considering the exit tax when planning a relocation. Many taxpayers focus on their residency and corporate structure abroad, neglecting the exit tax. The result is an unexpected payment request that can jeopardize their liquidity and the entire relocation plan.
2. Moving without sufficient funds to pay the tax. For non-EU transfers, the exit tax is due immediately. Those who lack the funds to pay it are in tax default, subject to penalties of 30% and possible criminal penalties for significant amounts.
3. Do not request an appraisal for unlisted investments. Without a sworn appraisal, the Revenue Agency can independently determine the fair value of the investment, with the risk of a valuation higher than the taxpayer would have obtained with its own appraisal.
4. Failure to coordinate exit tax and Italian tax closure. The year of transfer is the last year of Italian tax residency: all worldwide income must be declared, the RW form completed, IVAFE and IVIE paid, and the exit tax paid. An error in any of these procedures may result in assessments and penalties for subsequent years.
5. Consider the transfer automatically eliminates all obligations towards Italy. Even after the transfer, the taxpayer remains subject to Italian taxation on Italian-source income (real estate in Italy, Italian pensions, dividends from Italian companies). Furthermore, if the transfer is contested as fictitious, all the consequences of the transfer are added to the exit tax already paid.
Reference legislation and practices
Italian domestic law
Article 166-bis, TUIR (Presidential Decree 917/1986, introduced by Legislative Decree 142/2018): exit tax for individuals, thresholds, taxable base, and calculation methods. Article 166, TUIR (reformed by Legislative Decree 142/2018): exit tax for companies and commercial entities. Article 5, Legislative Decree 461/1997: 26% rate on capital gains. Article 67, paragraph 1, letter c-sexies, TUIR: inclusion of crypto-assets among other income. Article 1, paragraphs 24-29, Law 207/2024 (2025 Budget Law): 18% tax exemption for crypto-assets, rate increase to 33% from 2026. Article 2, paragraph 2, TUIR (reformed by Legislative Decree 209/2023): tax residency criteria for natural persons. Article 10-bis, Law 212/2000 (Taxpayer Statute): abuse of rights and transactions without economic substance.
Revenue Agency Practices
Circular 28/E of August 1, 2023: operational clarifications on the exit tax following the reform of Legislative Decree 142/2018, including scope, thresholds, methods for calculating the fair value, and conditions for installment payments. Circular 20/E of November 4, 2024: clarifications on the new tax residency criteria introduced by Legislative Decree 209/2023, relevant for determining the time of transfer for exit tax purposes. Circular 30/E of 2023: tax regime for cryptoassets, relevant for inclusion in the exit tax scope.
European Union Law
Art. 5, Directive 2016/1164/EU (ATAD): Harmonized rules on exit taxation, obligation to provide for payment by instalments for intra-EU transfers. CJEU C-164/12 (DMC): Legitimacy of the exit tax with obligation to pay by instalments within the EU. CJEU C-657/13 (Verder LabTec): Obligation to pay by instalments without a guarantee in the absence of actual risk. CJEU C-581/17 (Wächtler): Exit tax and freedom of establishment towards EEA/EFTA states. CJEU C-9/02 (de Lasteyrie du Saillant): Landmark ruling that declared the original French exit tax unlawful for violation of freedom of establishment.
Exit tax planning and relocation to Panama: specialized advice
Studio Panama Italia assists entrepreneurs, investors, and business owners in planning the transfer of tax residency, including preliminary exit tax calculations, legitimate tax minimization strategies, coordination with AIRE registration, obtaining Panamanian residency, and compliant corporate structuring. Each plan is customized based on the client's assets, holdings, and objectives. We have been operating from Panama City since 2010, license no. 14465.
✉️ Write to us on WhatsAppFrequently asked questions about exit tax
What is the exit tax in simple terms?
This is the tax Italy applies to unrealized capital gains when a taxpayer transfers their tax residence abroad. In practice, if you own an asset that has increased in value over the years in Italy, the tax authorities will tax that increase even if you haven't sold the asset. It's calculated as if you had sold it at the time of the transfer.
Does the exit tax apply to everyone who moves abroad?
No. For individuals, the exit tax is only applicable if the value of their shareholdings and financial instruments exceeds €4 million, or if they hold qualified shareholdings (over 2% in listed companies or 20% in unlisted companies). Most taxpayers who move abroad are not subject to the exit tax.
Are cryptocurrencies subject to exit tax?
The issue has not been definitively clarified by practice, but the wording of Article 166-bis of the TUIR includes them: crypto-assets generate income pursuant to Article 67 of the TUIR and are classified as "financial instruments and other components." If their total value exceeds €4 million, it is prudent to consider them subject to the exit tax and plan accordingly.
Can I pay my exit tax in installments if I move to Panama?
No. The payment plan, split into 6 annual installments and payment suspension, is only available for transfers to EU or EEA countries with tax cooperation agreements. Panama is a non-EU country: the exit tax is due in full with the tax return for the year of transfer. Liquidity planning is essential.
What is the exit tax rate?
For individuals: 26% on capital gains from equity investments and financial instruments (substitute tax). For companies: 24% IRES plus 3.9% IRAP. For crypto-assets, a 26% rate applies until 2025 and 33% from 2026 on capital gains.
How can I legally reduce my exit tax?
The main strategies are: selling assets before the transfer (paying capital gains tax), reorganization to stay below the €4 million threshold, tax exemption for crypto assets at 18%, timing the transfer during a bear market, and distributing dividends to reduce the value of the shareholding. Each strategy must have a separate economic justification to avoid abuse of rights claims.
What if I pay the exit tax and then the transfer is disputed as fictitious?
This is the worst-case scenario. If the Revenue Agency disputes the transfer as fictitious (foreign investiture of the individual), the taxpayer is still resident in Italy and subject to worldwide taxation on all income. The exit tax paid may not be recoverable if the transfer never took place for tax purposes. Therefore, the transfer must be real, complete, and documentable.
Is moving to Panama worthwhile from an exit tax perspective?
Yes, for two reasons. First, Panama is on the OECD White List, so the reinforced presumption of Italian residency does not apply, and the transfer is easier to defend. Second, Panama has territorial taxation, so after the transfer, capital gains on international assets are not taxed. The exit tax is paid once upon leaving Italy, but from the following day, any gains are tax-free in Panama.
Find out how to obtain residency in Panama in 6 steps, register with AIRE, obtain a tax residency certificate, avoid foreign investment, open a company in Panama, calculate IVAFE and IVIE on foreign assets, and complete the RW Formstructures asset protection and Private Interest Foundations, consult the dedicated guides.
