From France to Italy

Leaving France

• Home (foyer) or main place of stay. You are resident if your household (spouse, children) habitually lives in France, or, failing that, if France is where you spend most of your time.
• Main professional activity in France. You are resident if your main work activity is in France, unless it is ancillary. Executives of French-headquartered companies with turnover above EUR 250 million are presumed to work mainly in France.
• Centre of economic interests. You are resident if France is the centre of your economic interests, for example your main investments, business seat or the source of most of your income.

Rules that can follow you after leaving

• French nationals in Monaco remain taxable in France. Under the 1963 France-Monaco tax convention, French nationals living in Monaco are generally taxed in France as if resident, unless they lived there before 13 October 1957 (five years' residence by 1962).

Exit tax in France

Exit tax (article 167 bis CGI)

• Tax resident in France for at least 6 of the 10 years before leaving.
• Securities and company rights worth at least EUR 800,000 in total, OR at least 50% of the profits of a company.

Unrealised capital gains (and earn-out receivables and previously deferred gains) are taxed on departure as if realised, at the flat tax (12.8% income tax plus social charges) or progressive rates if elected.

Exit tax → · Am I still resident? →

Arriving in Italy

Personal income: €300k flat · Company tax: 24%

Opt into the new residents regime when you move.

Tax residency in Italy; not resident there in 9 of the last 10 years.

From 2026, €300,000 a year on foreign income (€50,000 per family member). Only pays off with income in the millions.