From Netherlands to Italy

Leaving Netherlands

• Facts and circumstances (article 4 AWR). There is no day count. Residence depends on durable personal ties (and to a lesser extent economic ties): where your home, family, work, registration, bank accounts and assets are, and how long you intend to stay.
• Return within one year. If you leave and come back within one year without having lived in another country, you are treated as having stayed resident the whole time.

Rules that can follow you after leaving

• Residence fiction on return within 1 year (article 2.2 Wet IB 2001). Leaving and returning within a year without living elsewhere keeps you resident. It does not apply if you prove you were taxed as resident in an EU/EEA state, Switzerland or a designated treaty state.
• Dutch nationals stay in Dutch inheritance and gift tax for 10 years. Dutch nationals who lived in the Netherlands are treated as resident for inheritance and gift tax for 10 years after emigrating (1 year for gift tax for non-nationals).

Exit tax in Netherlands

Conservatory assessment (conserverende aanslag) on emigration

• Substantial interest: you (with partner or close relatives) hold at least 5% of the shares, or a class of shares, of a company.
• Also applies to Dutch pension rights and annuities where premiums were tax-deductible, and some home-related savings products.

On emigration the substantial interest shares are deemed sold; the gain is taxed in box 2 (24.5% up to EUR 68,843, 31% above in 2026) and a conservatory assessment is issued instead of immediate payment.

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.