Italy’s exit tax and moving to Portugal: the five-year deferral, the double-tax trap and where IFICI fits

On 30 October 2026, Italy’s government sent parliament a budget that taxes your investment gains on the day you stop being an Italian tax resident, if you hold €800,000 or more in financial investments.^[1]

Most of the coverage since then says the fix is simple: leave before 2027. For most people it isn’t. Italy counts residence by the whole year, so if you lived there for most of 2026, your exit counts from 1 January 2027, the exact date the new tax starts.^[1][3]

So if you’re planning a move to Portugal, the real questions are different. What will Italy charge you, can you put it off, and can the same gain be taxed again in Portugal? That last one is where Portugal’s IFICI regime decides how much you keep.

The rest of Europe’s moves on wealthy residents, including Italy’s €300,000 flat tax for newcomers, are in our overview of Europe’s golden visas. This post is only about leaving Italy for Portugal.

Neste guia9 sections

1. What is Italy's proposed exit tax?
2. Should you rush to move to Portugal before 2026 ends?
3. What happens if you move to Portugal?
4. Can the same gain be taxed twice?
5. What is IFICI, and who actually qualifies?
6. What does Portugal tax if you don't qualify for IFICI?
7. Does Portugal have an exit tax, or a flat tax like Italy's?
8. When do you need to act?
9. How do you find out if IFICI works for you?

What is Italy’s proposed exit tax?

It’s a tax on gains you haven’t cashed in yet, charged when you stop being an Italian tax resident. It’s in article 17 of Italy’s draft 2027 budget, and it would apply when your loss of residence takes effect on or after 1 January 2027.^[1][2]

It applies to you if two things are true:

• You’ve been an Italian tax resident in at least six of the last ten tax years. Your nationality doesn’t matter.
• Your financial investments are worth €800,000 or more. That’s their total value, not your gain.^[1]

“Which of my assets count?”

Only financial ones. The draft counts shares and holdings in companies, funds and ETFs, bonds and other securities, derivatives, foreign currency, precious metals and crypto. Property, cash in euros, dividends and interest don’t count.^[1]

Once you’re over the €800,000 line, every investment that has gone up is taxed on its own gain, valued at market price on 31 December of the year before you leave. Investments that have gone down don’t reduce the bill.^[1]

“Is it a new 26% tax?”

No. It applies Italy’s ordinary rates on investment gains, which is why the press reported “26%”:

• 26% on shares, funds and ETFs.
• 33% on crypto.
• About 12.5% on Italian and other qualifying government bonds, because only 48.08% of their gain is counted.^[1]

You pay within 180 days of the date your loss of residence takes effect.^[1]

Should you rush to move to Portugal before 2026 ends?

No, not to escape the exit tax. If you’ve lived in Italy for most of 2026, moving in November or December, and registering as a Portuguese tax resident, doesn’t change the fact that Italy treats you as its resident for all of 2026.^[3][7]

Italy has no split tax year. If you were resident, domiciled or physically present in Italy for most of 2026, you’re an Italian tax resident for the whole year. So your exit takes effect on 1 January 2027, the date the draft starts taxing exits, with your investments valued on 31 December 2026.^[1] Only people who left by about the start of July 2026, and cut their home, family and registry ties, are outside it.^[7]

Here’s how different move dates play out under the draft:

• Move on 15 November 2026: you’ve lived in Italy for about ten and a half months, so Italy treats you as resident for all of 2026. Your exit takes effect on 1 January 2027 and the tax applies. Rushing didn’t help.
• Stay all of 2026 and move in March 2027: you’re out of Italy for most of 2027, so your exit also takes effect on 1 January 2027, with the same 31 December 2026 valuation. It’s the same result as the rushed move, with three more months to plan.
• Moved on 20 May 2026, with your home and family: you were in Italy for under half the year, so you’re not an Italian tax resident for 2026 and the tax doesn’t reach you. That’s the only way out, and for most people that date has passed.

Days aren’t the only test. If your spouse, children or main home stay in Italy, or you stay on the Italian population register, Italy can still treat you as resident for the year.^[3]

“Can a December move make things worse?”

Yes, in two ways.

• You can end up resident in both countries for part of 2026. Portugal treats you as resident from your first day living here, while Italy keeps you for the whole year.^[14][3] How that overlap is settled is a question for advisers in both countries.
• You can use up a year of IFICI. Arrive in December 2026 and 2026 becomes your first year as a Portuguese resident. IFICI’s ten years count from that year, so if your qualifying role isn’t in place yet, you lose a year of the regime.^[9][10]

So the deadline that matters isn’t 31 December. It’s having your Portuguese role, and your company if your route needs one, ready for the year you arrive.

It’s still a draft, as of early November 2026. Parliament holds hearings until 12 November, takes amendments around 17 November and usually passes the budget by 31 December. One party is already preparing an amendment for start-ups.^[5] The government expects the tax to raise only €3.37 million in 2027, which tells you how few people it expects to pay it.^[5]

What happens if you move to Portugal?

Portugal is in the EU, so you can defer most of the tax. Instead of paying it all within 180 days, the draft lets you pay half up front plus a guarantee, and puts the rest on hold for five tax years.^[1][2]

How the deferral ends depends on what you do with each investment:

• You keep it for the five years: Italy charges nothing on it, and the draft says overpayments are refunded.
• You sell it within the five years: Italy charges the lower of the gain at your exit and your real gain on the sale, minus what you paid up front. If the price has fallen since you left, Italy recognises the fall.
• It passes to your heirs on your death, or you move back to Italy while you still hold it: nothing more to pay on it.^[1][2]

For a move that takes effect in 2027, the five tax years are 2028 to 2032. What the guarantee looks like, and how the refund works, is left to a later decree from Italy’s finance ministry.^[1]

Can the same gain be taxed twice?

Yes, if you sell within the five years and you don’t have IFICI. Once you live in Portugal, the Italy–Portugal tax treaty gives Portugal alone the right to tax your later gains on shares and securities.^[4] That’s exactly why Italy taxes them on the way out.

Portugal doesn’t reset your purchase price when you arrive. If you sell, it taxes your gain from what you originally paid, whatever Italy already charged on exit.^[13] And the Italian draft gives no credit for tax you pay in Portugal.^[1]

“So what could that cost me?”

Take a simple case. You hold €1,000,000 of ETFs bought for €600,000, so you have a €400,000 gain when Italy values them on 31 December 2026. You move to Portugal, defer, and sell in 2029 for €1,100,000.

Without IFICI, you’d pay about €244,000 on a €500,000 gain. With IFICI, Portugal exempts the gain on those ETFs, and you pay only Italy’s €104,000. And if you hold for the full five years, Italy’s charge falls away too.^[8]

These figures are an illustration, before any Portuguese relief for long-held investments and before exchange costs. Your own numbers depend on what you hold, where it’s issued and when you sell.

What is IFICI, and who actually qualifies?

IFICI is Portugal’s tax regime for people who come to work in qualifying jobs, and it lasts ten years. It taxes the qualifying work income at a flat 20%, and it exempts most foreign income: dividends, interest and gains on shares and funds issued outside Portugal.^[8][9]

Two details matter for a portfolio leaving Italy:

• “Foreign” depends on where the investment is issued, not where your broker is. A US or Irish ETF held at an Italian broker is foreign. So are Italian shares. Portuguese shares aren’t.^[8]
• Pensions aren’t covered, and investments from blacklisted tax havens are taxed at 35%.^[8]

“Can I get IFICI as an investor?”

No. You need a qualifying job or role, every year. The exemption on your foreign investments comes with that role; it isn’t available on its own.^[9][10]

The route that fits most people moving with a portfolio is the third one: you become the paid manager of your own Portuguese company, in an activity on the official list. Software, engineering, research and manufacturing are on it. Management consultancy isn’t.^[10]

On top of that, you must not have been a Portuguese tax resident in the previous five years, and you can’t have had NHR, the regime IFICI replaced. More on the routes in our guide to IFICI.

What does Portugal tax if you don’t qualify for IFICI?

Your foreign investment income and gains at a flat 28%, unless you choose to add them to your other income on the normal scale.^[11]

• Long-held listed investments get a break: 10%, 20% or 30% of the gain is left out once you’ve held them for more than two, five or eight years.^[12]
• Italian tax on your Italian dividends, capped at 15% by the treaty, is credited against the Portuguese tax.^[4][11]
• Your purchase price stays the original one, as above.^[13]

Does Portugal have an exit tax, or a flat tax like Italy’s?

No to both. Portugal doesn’t tax your shares or funds when you leave; crypto is the only investment it values on the way out.^[15] And it has no lump-sum regime like Italy’s €300,000 a year for wealthy newcomers. The regimes for new residents are IFICI and, for returning Portuguese emigrants, Regressar.

When do you need to act?

Your Portuguese dates start the day you move. Portugal treats you as a resident from your first day living here.^[14]

• If you arrive in 2027, 2027 is your first IFICI year, and you enrol by 15 January 2028 on the Portal das Finanças.^[9][10]
• Your qualifying role has to be in place in that first year, because IFICI is checked year by year. If your company isn’t set up yet, that comes first, and it takes weeks.
• On the Italian side, your 180 days to pay, or to pay half and post the guarantee, run from the date your exit takes effect.^[1]

If you’re thinking of moving before the end of 2026, take the timing to an Italian tax adviser first. The whole-year rule is exactly where a late-2026 move goes wrong.

How do you find out if IFICI works for you?

Start with an eligibility assessment by a certified Portuguese accountant, before you form a company or commit to a role.

Perguntas frequentes

Is Italy’s exit tax already law?

Not yet. It’s in the draft 2027 budget sent to parliament on 30 October 2026, which can be amended and is usually passed by 31 December.^[1][5]

Should I move to Portugal before 31 December 2026 to avoid the exit tax?

No, if you’ve lived in Italy for most of 2026. Italy treats you as resident for the whole year, so a late move still counts as an exit on 1 January 2027. A December move can also use up a year of IFICI.^[3][9]

Does the exit tax apply to my house in Italy?

Não. It only counts financial investments. Property and cash in euros are left out.^[1]

I’m not Italian. Can it still apply to me?

Yes. The test is tax residence, not nationality: six of the last ten years as an Italian tax resident.^[1]

Do losses reduce the tax?

Não. Every investment with a gain is taxed on its own gain, and investments at a loss don’t offset them.^[1]

What rate does Italy charge?

Its ordinary rates: 26% on shares, funds and ETFs, 33% on crypto and about 12.5% on qualifying government bonds.^[1]

If I move to Portugal, do I have to pay it all at once?

Não. You can pay half within 180 days, post a guarantee and defer the rest for five tax years. Investments you don’t sell in that time owe nothing more.^[1]

Does Portugal give me credit for the Italian exit tax?

Not through a new purchase price. Portugal taxes a later sale from what you originally paid. With IFICI, gains on foreign-issued investments are exempt in Portugal, which removes the overlap.^[8][13]

Can I get IFICI just by moving my portfolio to Portugal?

Não. You need a qualifying job, or a paid manager role in your own company in a qualifying activity, every year. The foreign-income exemption comes with that role.^[9][10]

Are Italian shares “foreign” for IFICI?

Yes. For IFICI, what counts is where the shares are issued. Only Portuguese-issued investments are domestic.^[8]

Does IFICI cover my Italian pension?

Não. Pensions are left out of IFICI’s exemptions and taxed on Portugal’s normal scale.^[8]

Does Portugal have an exit tax?

Not on shares or funds. Crypto is the only investment Portugal values when you leave.^[15]

When do I apply for IFICI?

By 15 January of the year after you become a Portuguese tax resident, on the Portal das Finanças. If you enrol late, you lose the years you missed.^[9][10]

Sources and how we checked

We read the Italian draft budget, Italy’s tax code and the Italy–Portugal tax treaty, and the Portuguese tax code and the tax authority’s IFICI guidance, in the original. We give no tax advice: this post explains how the rules work, and your own case needs an adviser in each country. The Italian measure is a draft, and its details can change before parliament passes it.

1. The exit tax itself (new article 307-bis of Italy’s income tax code), its scope, rates, threshold, payment and EU deferral: Italy’s draft 2027 budget, article 17, government text of 30 October 2026.
2. The government’s explanation of the measure: explanatory report to the draft budget, October 2026, on article 17.
3. Italian tax residence, decided for the whole year: Italy’s income tax code, Legislative Decree 117/2026, article 2.
4. Who taxes later gains, and the 15% cap on dividends: Italy–Portugal double tax treaty, 1980 (Italian Finance Department), articles 10 and 13.
5. Parliamentary timetable, the expected revenue and the amendments in preparation: Il Sole 24 Ore English, 31 October 2026, Sky TG24, 30 October 2026 e Gazzetta del Sud, 3 November 2026.
6. Press reading of the draft: IMI Daily, 31 October 2026.
7. Why a late-2026 move is still caught: Taxing.it, “Italy’s proposed exit tax”.
8. IFICI’s exemption for foreign income, the pension exclusion and the 35% rate for tax havens: Portuguese income tax code (CIRS), article 81, Portal das Finanças.
9. IFICI’s 20% rate, conditions and enrolment: Tax Benefits Statute, article 58-A.
10. The tax authority’s IFICI questions and answers, including managers of their own company: Ofício Circulado 20276/2025.
11. The 28% rate on investment income: CIRS article 72.
12. The relief for long-held listed investments: CIRS article 43.
13. Gains measured from the original purchase price: CIRS article 48.
14. When your Portuguese tax residence starts: CIRS article 16.
15. No exit charge on shares or funds; the crypto rule: CIRS article 10.