Italian exit tax: art. 166 TUIR and the move to Switzerland
What triggers the Italian exit tax, how it is calculated, when paid, how it is staggered for those moving to CH.
When it triggers
Art. 166 TUIR taxes latent gains on qualified shareholdings at the time of transfer of tax residence abroad. For Switzerland (non-EU), an instalment regime with security applies.
What is taxed
Qualified shareholdings (above 25% of capital or 20% of voting rights in non-listed; above 5% capital or 2% voting in listed). Market value at transfer minus historical tax cost.
Instalments
Payment can be spread over several years, with a proportionate bank guarantee. The structure of the guarantee (autonomous, callable on first demand) requires negotiation with an Italian bank.
Swiss coordination
An information dossier for the Ticino Tax Division avoids a double declarative short-circuit. Coordination between Italian accountant and Ticino fiduciary: no improvisation.
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