Not tax or legal advice. This page sorts public sources, as of 31 Oct 2026. Whether and how any of it applies to you is a question for your tax adviser.
In short
- Italy's government is proposing an exit tax in its 2027 budget bill: 26% on financial income and unrealised gains when someone moves their tax residence abroad.
- It would apply to people with at least €800,000 in financial assets (bank deposits excluded) who were tax resident in Italy for at least 6 of the last 10 years.
- Status: a bill approved by the Council of Ministers, not law. Parliament debates it from November; the planned start is 1 January 2027.
- Exit taxes mostly hit those who move late. If you're considering a move, plan early and get advice in both countries.
- Liechtenstein doesn't override Italian rules. It is a predictable location when there is real substance behind it.
Status check 31 Oct 2026
What's in the Italian draft?
Sorted, with sources. The text may still change in parliament.
ITgovernment bill
Who and what
- New Art. 307-bis of the income tax code (TUIR), part of the 2027 budget bill (Il Sole 24 Ore, 31 Oct).
- Individuals plus certain partnerships and non-commercial entities.
- From €800,000 in financial assets (shares, holdings, other financial instruments). Bank deposits don't count.
- Tax resident for at least 6 of the last 10 years.
- 26% on financial income and accrued, unrealised gains.
ITproposed
Payment and deferral
- Payment within 180 days of the change of residence.
- For moves to an EU state or a “cooperating” state, a deferral is planned, against a 50% down payment and security.
- The tax would then only fall due on a sale within a set period: 5 years for EU states, 10 years for other cooperating states.
- Which states count as cooperating is up to the final text. Whether Liechtenstein is one is open. We expressly make no such claim.
ITin parliament
Timeline
- 28 Oct 2026: the Council of Ministers approves the budget bill (governo.it, Italian).
- Chamber of Deputies: budget committee from 3 Nov, hearings roughly 5–12 Nov, amendments until about 17 Nov (ANSA, Italian).
- The budget has to pass by 31 Dec. The rule is planned for moves from 1 Jan 2027.
As of 31 Oct 2026. Not law. We update this page when things change.
What it honestly means
Plenty of posts are turning the draft into “leave now”. The honest part is usually missing. Three things matter:
- Exit taxes hit those who move late. What would be taxed is the growth built up in Italy until you leave. The longer a portfolio or a stake grows there, the larger the possible bill. If you're seriously considering a move, plan early and with advice, not in December under time pressure.
- Substance, not a mailbox. An address alone is neither a residence nor a company seat. If you build something in Liechtenstein, you need a real presence: a registered company with its seat and desks on the ground, and decisions made here. More: Substance in Liechtenstein.
- Moving doesn't erase your home country's rules. Italy applies its own rules to decide whether someone has really left and what falls due on departure. Double taxation questions come on top: Double taxation and Liechtenstein.
Why we still like talking about Liechtenstein: the environment is predictable. Founders plan in years, not in headline cycles.
Exit taxes in Europe compared
Italy wouldn't be the first country with an exit tax. A short comparison as of 1 Nov 2026. The full overview including wealth and data taxes: Tax news Europe.
| Country | Status 1 Nov 2026 | Source |
|---|---|---|
| Italy | Government bill, not law. 26% on unrealised gains from €800,000 in financial assets, resident 6 of 10 years, planned from 1 Jan 2027. | Il Sole 24 Ore |
| Germany | Law in force. If you were fully taxable for at least 7 of the last 12 years and hold at least 1% of a corporation, moving away triggers tax on the gain in those shares. Instalments over seven years on application. | § 6 AStG (German) |
| France | Law in force, change at first reading. On 30 Oct 2026 the Assemblée nationale adopted an amendment that would extend the period after which the exit tax lapses from 2 to 15 years. The Senate and the final budget are pending. | Amendment I-462 (French) |
| Norway | Law in force. For moves since 20 Mar 2024, unrealised gains are assessed and payable within 12 years. | Skatteetaten |
| Belgium | Law in force since 2026. The new 10% capital gains tax comes with an exit tax on departure. For moves to an EU or EEA state, payment is deferred automatically; without a sale within 2 years it is not owed. For Liechtenstein, check case by case. | SPF Finances (French) |
| Spain | Law in force. From €4m in shares and holdings, or more than 25% of a company worth more than €1m, resident 10 of 15 years. For moves to an EU or EEA state with exchange of information, by election only due on a sale within 10 years. For Liechtenstein, check case by case. | Art. 95 bis LIRPF (Spanish) |
| Austria | Law in force. Moving away counts as a disposal of capital assets, special rate 27.5%. For moves to an EU/EEA state, on application assessed only on an actual sale. For Liechtenstein, check case by case. | § 27(6) EStG (German) |
| Denmark | Law in force. From DKK 100,000 in shares and usually after 7 years of tax liability, gains count as realised on departure. Interest-free deferral; security required outside the EU and the Nordic countries. For Liechtenstein, check case by case. | Skattestyrelsen (Danish) |
| Ireland | No general exit tax. Return rule for domiciled individuals after no more than 5 years away (holdings of 5% or more, or over €500,000). | Revenue s. 29A |
| Switzerland | No general exit tax for individuals. According to the Federal Department of Finance, the Federal Council considers one ruled out under the constitution. | Federal Department of Finance (German) |
The logic is similar everywhere: what grew in the old country is taxed. The basics: Exit tax.
Liechtenstein in numbers
| Item | Status | Source |
|---|---|---|
| Corporate income tax | 12.5%, since 2011 (Tax Act in force since 1 Jan 2011) | llv.li, gesetze.li SteG |
| Minimum corporate income tax | CHF 1,800 a year | llv.li |
| EEA | Member since 1995 | gesetze.li |
| Currency | Swiss franc (CHF) | – |
| Blockchain Act (TVTG) | in force since 2020 | gesetze.li |
| GmbH (LLC) | from CHF 10,000 share capital | GmbH fact sheet, llv.li |
| EU list of non-cooperative tax jurisdictions | Liechtenstein is not on it (update 9 Oct 2026) | Council of the EU |
It's not a hack. It's boringly predictable, and that's the point. How incorporation works: GmbH formation in Liechtenstein.
digihub · In der Specki 3, Schaan
Substance means a real place to work
If you're looking at Liechtenstein seriously, you need more than an address: an office, people on the ground, decisions made here. At digihub in Schaan you get real desks, not a mailbox: coworking with a Flex Desk from CHF 169, a Full Desk from CHF 299 or a Private Office from CHF 549 a month, plus meeting room and community. A business address is available by agreement (Registered office & business address).
Come by for a coffee, and we'll see together whether Liechtenstein even makes sense for you.
Read next
Sources
- Italian government: Council of Ministers press release no. 195 (28 Oct 2026, Italian)
- Il Sole 24 Ore English: the budget also includes a tax on the super-rich who leave Italy (31 Oct 2026)
- Il Sole 24 Ore: original article (31 Oct 2026, Italian)
- la Repubblica: exit tax on capital gains when leaving Italy (30 Oct 2026, Italian)
- ANSA: budget timeline until approval (29 Oct 2026, Italian)
- Assemblée nationale: amendment I-462, PLF 2027 (adopted, 30 Oct 2026, French)
- § 6 AStG (exit tax), gesetze-im-internet.de (German)
- Skatteetaten: Exit tax
- SPF Finances: capital gains tax (French)
- llv.li: corporate income tax (German)
- Council of the EU: EU list of non-cooperative jurisdictions, update 9 Oct 2026
- llv.li: GmbH fact sheet (German)
Not tax or legal advice. Orientation based on public sources, as of 31 Oct 2026. The Italian draft may still change in parliament. Please check your own case with a tax adviser or lawyer in Italy and Liechtenstein.
Content from digihub.li · reviewed 31 October 2026.