From Italy to Montenegro

Leaving Italy

• Residence (habitual abode) for most of the year. You are resident if your habitual abode is in Italy for more than 183 days in the tax year (184 in a leap year), counting fractions of days, under the rules in force since 2024.
• Domicile: centre of personal and family life. Since 2024 domicile means the main centre of your personal and family relationships, which now weigh more than economic interests. Domicile in Italy for most of the year makes you resident.
• Physical presence. New since 2024: simply being physically present in Italy for more than 183 days in the year, including fractions of days, makes you resident.
• Registry of resident population (anagrafe). Being registered as resident for most of the year creates a presumption of residence. Since 2024 it can be rebutted with proof; registering in AIRE (Italians abroad) alone is not enough.

Rules that can follow you after leaving

• Presumption for moves to blacklisted countries. Italian citizens who deregister and move to a country on Italy's tax haven list are presumed still resident unless they prove a genuine move. The burden of proof is on the taxpayer.

Exit tax in Italy

No exit tax for private individuals

Individuals holding shares or other assets privately are not taxed on unrealised gains when they leave Italy. The exit tax in article 166 TUIR applies only to businesses (companies and sole traders carrying on a commercial business) that transfer residence or assets abroad.

Exit tax → · Am I still resident? →

Arriving in Montenegro

Personal income: 9–15% · Company tax: 9–15%

Temporary residence permit through your own company or a property purchase.

183 days a year.

Income tax 9%, 15% on the top band; companies 9% to 15% depending on profit. Dividends at 15%. Uses the euro.