Leaving Italy for Dubai: no exit tax, and that is not the good news

Italy is the one country in Western Europe where the headline answer is genuinely reassuring. There is no exit tax for private individuals. No deemed sale of your shareholding, no bill on unrealised gains, nothing comparable to the French charge under article 167 bis.

That is true, and it is also why Italians moving to Dubai walk into the harder problem without seeing it. Italy does not tax you for leaving. It disputes whether you left at all.

First, the good news, stated precisely

The Italian exit charge applies only to people carrying on a commercial business. The successor provision in the new consolidated code opens with exactly that wording, and taxes the difference between market value and tax book value of business assets, to the extent they do not stay tied to a permanent establishment remaining in Italy. The code then adds, in terms: the transfer abroad of a company’s tax residence does not by itself give rise to any taxation of that company’s shareholders.

So a private individual leaving with shares, a stake in an SRL, a portfolio or property triggers nothing. A sole trader or partner taking the business itself to Dubai is in a different position, and for them the instalment relief is closed: five annual instalments against security are available only for moves within the EU or EEA, to a state that also has a recovery assistance agreement. The Emirates qualify on neither count, so the business owner pays in full and at once.

The real problem: a list from 1999

Italian tax residency has a reversal of the burden of proof built into it. Italian citizens removed from the resident population register and transferred to a state not identified by ministerial decree are still treated as Italian residents, unless they prove the contrary.

The provision is written as a whitelist, but the whitelist decree was never issued. Under the transitional rule that fills the gap, the operative list remains the blacklist of the Ministerial Decree of 4 May 1999, identifying states with a privileged tax regime.

The United Arab Emirates are on it. Published in the Gazzetta Ufficiale of 10 May 1999, between Dominica and Ecuador: Emirati Arabi Uniti.

Have they been removed since? No. The list has been shortened exactly twice in twenty-seven years, removing Cyprus and Malta in 2010 and San Marino in 2014. The Emirates were never touched.

The consequence is blunt. An Italian citizen who moves to Dubai remains tax resident in Italy, despite AIRE registration, until they prove otherwise, and the burden sits entirely on the taxpayer.

Destination	Who has to prove what
A state on the 1999 list, including the UAE	You prove you genuinely moved your centre of life
Any other state	The authority proves you stayed resident

There is no time limit on this. The French exit tax is written off after two or five years. UK inheritance tax runs a defined number of years and then stops. The Italian presumption simply stays available to the tax authority for any year it chooses to examine.

The 2024 reform made the test harder to satisfy

Since the 2024 reform, you are resident in Italy if, for the greater part of the tax period, counting fractions of a day, you have your civil law residence or your domicile in Italy, or are simply present there. Three things in that sentence are routinely underestimated.

It is three alternative tests, not one. Civil law residence, domicile, or plain physical presence. Any one is enough.

Presence counts in fractions of a day. Arrival and departure days both count as days in Italy. A travel pattern that looked safe under a midnight-to-midnight rule does not survive this. The greater part of the tax period means more than 182 days, 183 in a leap year.

Domicile is now family, not business. It is the place where a person mainly develops their personal and family relationships. The old economic reading is gone. A spouse and school-age children still in Milan now weigh more heavily than an office in DIFC.

AIRE, and what proof actually looks like

Italian citizens moving abroad must declare it to the consular office covering their new district within ninety days of immigration. It goes to the consulate, not to the Italian municipality, and the same deadline applies to every later change of address abroad. Failing to do it costs between 200 and 1,000 euros for each year the omission continues, reduced to a tenth of the minimum if you regularise within ninety days.

But the filing people think closes the file is the same filing that opens it: the municipality reports AIRE registrations and removals to the Agenzia delle Entrate for its tax checks.

No single document settles residency. What is required is a body of evidence: a tenancy agreement or title in the UAE, Emirates ID and residence visa, actual days of presence evidenced rather than asserted, the family having moved and the children enrolled in school, local bank accounts and utility contracts in your own name, and the Italian home given up rather than kept ready and empty.

Two consequences people find out about late

Healthcare stops. AIRE registration ends entitlement to the national health service. The health ministry states plainly that Italian citizens moving to a country without a healthcare agreement lose the right to care both in Italy and abroad. The Emirates are not among the nine agreement countries, and for those there is expressly no cover at all, emergency treatment included. Private cover has to be in place before departure.

Family allowance stops. The assegno unico requires Italian income tax liability plus residence and domicile in Italy, or employment subject to compulsory Italian insurance. Someone who moves to the UAE, registers with AIRE and works there fails the first condition. The 2026 opening for children living abroad covers other EU member states, not third countries.

An Italian property is still taxed, and still taxed in Italy

IMU stays due, and the main-residence relief is gone because it requires both habitual dwelling and registration at the address. The basic rate is 0.86 percent, with municipalities able to raise it to 1.06 percent, and to 1.14 percent in certain cases. There is a relief halving IMU for non-residents receiving a pension arising under an international social security agreement, but a double tax treaty does not satisfy it, and whether such an agreement exists between Italy and the Emirates could not be verified from official sources. We will not claim it does. Assume the full IMU is due, and note that any letting excludes the relief regardless.

On rental income the treaty gives Italy the taxing right. The cedolare secca flat tax of 21 percent contains no residence condition in its text, but an explicit confirmation from the Agenzia delle Entrate that non-residents may elect it was not obtainable. Treat that as arguable rather than settled.

Inheritance is cleaner. Italian inheritance and gift tax attaches to the residence of the deceased or donor, and where that person was not resident in Italy, only Italian-situs assets are taxed. Dubai property, UAE accounts and shares in UAE companies fall out. The Italian flat and shares in Italian companies stay in. There is no trailing period, the law looks only at the date of death or gift.

One date to diary for later

The old income tax code has been replaced by a new consolidated text that applies from 1 January 2027, repealing the old articles 1 to 191 on that date. The substance was carried over. Every article number changes. Any memo written this year and filed away will cite numbers that no longer exist in 2027.

What this means in practice

Italy is the country where the paperwork is easy and the evidence is hard. The order that works:

1. Register with AIRE within ninety days, through the consulate, and treat it as the start of the process rather than the end.
2. Move the family, or accept that you have not moved. Since 2024 domicile is defined by personal and family ties, and it is the single most decisive factor.
3. Count days properly, including arrival and departure days. More than 182 in Italy and the rest of the argument is academic.
4. Build the evidence file from day one and keep it. You will be asked for it years later, not weeks later.
5. Arrange private health cover before you leave. There is no safety net and no emergency exception.

The Dubai side is the simple half. A company, a residence visa, an Emirates ID, a corporate tax registration, each with a published fee and a fixed deadline, and you can work the cost out yourself in our company cost calculator. For a country that takes the opposite approach, taxing on citizenship rather than arguing about residence, see leaving the US for Dubai.

We handle that half, the accounting, the tax registrations and the deadlines here. The Italian half belongs with an Italian adviser who has argued a residency case against the Agenzia delle Entrate, and it belongs there before the move rather than after it.

This article is part of a series comparing what leaving costs across fifteen countries. The overview, with a table of every exit charge and how long each tail runs, is in what leaving costs, by country.