Italians leaving Italy
From the Italian impatriati regime or the new residents regime to the Ticino forfait: for whom it makes sense, and when.
Why move now
The Italian impatriati regime and the new residents regime (amount depending on entry date) remain attractive but are subject to shifting administrative interpretations and a political framework less predictable than Switzerland's. For significant patrimonial profiles, Ticino's institutional stability is worth the fiscal differential.
AIRE registration and tax residence
The transfer requires AIRE registration within 90 days, removal from the Italian registry, and proof that the centre of vital interests lies in Switzerland. Art. 2 TUIR and the Italian Revenue Agency's practice check facts, not declarations.
Black list and burden of proof
Switzerland was removed from the Italian individuals' black list in 2024, but for the first five years the burden of proving actual residence remains reversed. Documentation prepared in advance, not improvised.
Coordination with Italian firms
We work with leading Milan and Rome tax firms for exit planning: capital gains management, exit tax on qualified shareholdings (art. 166 TUIR), property holdings, interests in Italian companies.
Write to us in fluent Italian, English or French. Within the team we also speak German, Spanish, Portuguese, Russian, Chinese and Arabic — available upon request.
The first written exchange checks whether we can help. Personalised advice and coordination require an agreed paid mandate. Please do not send sensitive documents through this form.
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