2027 Budget Law: Business Property, Exit Tax and Other New Measures

With the publication of the text of the 2027 budget bill, now before the Chamber of Deputies, it is possible to examine in more detail certain measures that the Government's official statement had left in the background and which, for that reason, we had not covered in our first commentary. These are the reopening of the relief for the assignment, sale and transformation of companies that own property, the revaluation of business property and the new exit tax for those who transfer their residence abroad. In addition, a review of the text of the bill allows us to add some clarifications on the flat-rate regime, the flat-rate rental tax for shops and the first-home relief.

Assignment, sale and transformation on favourable terms

The bill reproposes, with the deadlines moved forward by one year, the relief provided by the 2026 Budget Law: by 30 September 2027, companies will be able to assign or sell to their shareholders property not used in the business, such as let property, and non-business vehicles or, if they merely manage such assets, transform into a simple partnership (società semplice).

An 8% tax is payable on the difference between the value of the asset, which for property may be its cadastral value, and its tax cost, rising to 10.5% for non-operating companies (società di comodo), with registration tax halved, mortgage and cadastral taxes at a fixed amount and 13% taxation of the tax-suspended reserves cancelled. The relief is available to companies whose shareholders were entered in the shareholders' register, where required, at 30 September 2026, or are entered within thirty days of the law coming into force on the basis of a deed bearing a certain date prior to 1 October 2026.

Compared with last year, however, the payment changes: whereas the 2026 Budget Law required 60% of the tax to be paid by 30 September and allowed the remaining 40% to be paid by 30 November, the bill provides for a single deadline, 30 September 2027, coinciding with the date by which the transaction must be completed. Sole proprietors, on the other hand, will be able to remove from the business, again with the 8% tax, business property held at 30 September 2026, in a transaction to be carried out between 1 January and 31 May 2027, with payment still divided into two instalments, due on 30 November 2027 and 30 June 2028.

Revaluation of business property

For those who prefer to keep property within the company, the revaluation returns, allowing companies and commercial entities that do not adopt international accounting standards to adjust the carrying value of property in their financial statements, excluding building land and property held for sale. The transaction concerns property recorded in the 2025 financial statements, must be carried out in the 2026 financial statements for companies whose financial year coincides with the calendar year and, already for statutory purposes, strengthens shareholders' equity.

To make the higher value relevant for tax purposes as well, a substitute tax of 8% is payable for depreciable property and 4% for other property, giving higher depreciation and lower capital gains from the third subsequent financial year, an advantage that is lost, however, if the property is sold, assigned or allocated to personal use before the sixth subsequent financial year. The reserve to which the higher value must be allocated, which is taxable if distributed, can also be released by paying a 10% substitute tax, and all taxes are paid in a single instalment together with the balance of taxes for the year of the revaluation, hence in 2027 for companies whose financial year coincides with the calendar year.

The new exit tax for individuals

While these measures represent an opportunity, the exit tax in question instead introduces a new cost for those leaving Italy: for transfers taking effect from 1 January 2027, individuals, simple partnerships and non-commercial entities resident in Italy for at least six of the last ten years will be taxed, at the time of departure, on gains accrued but not yet realised on shareholdings, securities, cryptocurrencies and other financial investments, as if they had sold them.

The ordinary rules apply, hence as a rule the 26% rate, which for government bonds is effectively reduced to 12.5%, on the sum of the gains alone, without offsetting against losses. The tax applies only if the assets are worth at least €800,000 in total, a threshold that does not, however, operate as a tax-free allowance, since once it is exceeded all gains are taxed, and provided that, as a result of the transfer, Italy loses the right to tax that income, an aspect to be verified on the basis of the tax treaty with the country of destination.

The tax must be paid within 180 days, but those moving to the European Union or to a country that cooperates with Italy on the exchange of information and tax collection may pay half immediately, providing a guarantee for the remainder, and defer the balance until the assets are sold, paying on the lower of the gain accrued at departure and the gain realised. If, within five years, or ten for non-EU countries, the assets are not sold, are inherited or the taxpayer returns to Italy, the tax is not due and the advance payment is refunded, whereas in the event of a gift or a transfer to family members or controlled companies the tax remains due on the gain accrued at departure.

First home: deadlines standardised at two years

The first-home relief is also affected by an unannounced change, which extends to two years both the deadline for transferring residence to the municipality where the purchased home is located, currently eighteen months, and the deadline within which those who sell the home before five years must buy another in order not to lose the benefit, currently one year.

The same deadline will apply to the tax credit available to those who sell their first home and buy another: in ruling no. 297 of 26 November 2025, the Italian Revenue Agency had in fact ruled out that the two years granted by the 2025 Budget Law to those who buy before selling also applied to the credit, whereas the bill extends it to two years and expressly grants it also to those who sell after buying. The new rules will also apply to transactions already carried out whose deadlines have not yet expired when the law comes into force.

Flat-rate regime: immediate exit above €115,000

The text confirms the increase to €100,000, for income tax purposes, of the threshold for entering and remaining in the flat-rate regime (regime forfettario), and specifies that immediate exit during the year, currently triggered above €100,000, will apply only above €115,000; for VAT, the limits already described in our first commentary remain unchanged. Lastly, for 2027 only, the limit on employment and pension income that prevents access to the regime is set at €35,000.

Flat-rate rental tax on shops and agreed-rent leases

Again in relation to property, the text clarifies the scope of the measures on the flat-rate rental tax (cedolare secca), which in our first commentary we had described on the basis of press reports. For shops, the substitute tax will be 21%, reduced to 10% in municipalities that are the capital of a metropolitan city, such as Milan, but only for premises in cadastral category C/1 with a surface area not exceeding 200 square metres, not counting appurtenances let together with them, and only for contracts entered into in 2027. Excluded, therefore, are existing contracts and those extended or renewed in 2027, new contracts replacing a contract between the same parties and for the same property that was in force at 30 September 2026 and terminated early, and those with tenants who do not use the premises exclusively for their own business or professional activity.

The same provision then reduces, for agreed-rent leases (canone concordato) entered into in 2027, the flat-rate rental tax rate to 5% on rents from 2027 to 2031, a rate that falls to 1% if the tenant is under 36 when the contract is signed. The text clarifies that both reductions also apply to the first renewal of these contracts, but only for rents up to 31 December 2031. Furthermore, to prevent abuse, the benefit is not available if the landlord, after terminating early a contract in force at 30 September 2026, enters into a new one in 2027 for the same property with the previous tenant, with whoever lived there at that date or with members of their household, so as to prevent an existing contract from being replaced for the sole purpose of obtaining the reduced rate.

Next steps

As this is a bill, the text may change during the parliamentary process, which must be completed by 31 December, but for assignments, transformations and revaluations it is in any event advisable to begin assessing their advantages now, also in view of the payment of the tax in a single instalment. The Firm will follow the progress of the law and remains available to assess the impact of the new measures on individual situations.