Wealth management in Italy

“Alexis, we want to settle in a village in Puglia to benefit from the 7% rate on pensions. Will my whole pension be taxed at 7%?”

No — and that is the point the brochures leave out. The France–Italy treaty provides that pensions paid under a state's social security system — including the general scheme and Agirc-Arrco — remain taxable in that state. France therefore continues to tax these pensions; Italy also taxes them and grants a tax credit.

Italy had 35,432 French nationals on the consular register at 31 December 2025, compared with 34,804 a year earlier, which is +1.8% over one year.

Two treaties apply: the treaty of 5 October 1989 on income and wealth, and the treaty of 20 December 1990, which covers inheritance and gifts. At Balmont Conseil, we read them alongside the Italian regimes currently in force.

1. Why seek expert wealth management in Italy?

Four points determine your situation.

Your basic and supplementary pensions remain taxable in France. Article 18 § 2 of the treaty and the 2000 exchange of letters expressly cover the general scheme and Agirc-Arrco. Government service pensions, by contrast, are taxed only in France.
The 7% regime. It targets retirees who move to a small municipality in southern Italy, for ten years, on their foreign-source income. It does not take away France's right to tax your social security pensions.
The new residents' flat-tax regime. It rises to €300,000 a year for people moving there from 2026, for fifteen years. It is of interest to very large fortunes, and must be read together with the treaty.
A treaty that also covers gifts. Real property falls to the state where it is located, other assets to the state of domicile of the deceased or donor, with a tax credit to avoid double taxation.

2. The France ↔ Italy framework in five verified points

Here is the applicable framework, checked against official sources as at 1st October 2026.

French nationals on the register	35,432 at 31 December 2025 (+1.8% over one year).
Income tax treaty	Yes — treaty of 5 October 1989, supplemented by exchanges of letters, including that of 20 December 2000 on pensions. It covers income tax and wealth tax.
Estate tax treaty	Yes, inheritance and gifts — treaty of 20 December 1990. Real property falls to the state where it is located, other assets to the state of domicile of the deceased or donor.
Exit tax — deferral of payment	Automatic deferral of payment, Italy being a member state of the European Union.
CSG and CRDS on property income and capital gains	7.5% for a person covered by the Italian social security system: only the solidarity levy is due, on rents and on real estate capital gains from French sources.

Sources: list of tax treaties concluded by France (BOI-ANNX-000306, updated 29 April 2026); exchange-of-information and recovery-assistance clauses (BOI-ANNX-000508, position at 8 October 2025); register of French nationals living outside France at 31 December 2025 (Ministry for Europe and Foreign Affairs); text of the treaty published by impots.gouv.fr; impots.gouv.fr for non-residents' social charges. Position as at 1st October 2026.

On pensions. The French tax authorities confirmed in 2023 that the general scheme, special schemes, Agirc-Arrco, schemes for the self-employed and mandatory supplementary pensions fall under the social security rule: taxable in France, and in Italy with a tax credit.

On the 7% regime. It requires not having been resident in Italy in the previous five years and moving to a municipality of no more than 20,000 inhabitants in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia. The calculation must include the French tax still due on your pensions.

On exit tax. The deferral is automatic, but the declaration remains compulsory: in the year of departure, then every year as long as the deferral runs.

What we do not show. The Italian tax scale and local taxes on assets held abroad are handled with a qualified adviser in Italy, whom we coordinate.

3. Our services: 360° support for expatriates and investors

Three workstreams, in the order in which they are decided.

Your pensions between the two countries

We classify each of your pensions under the treaty, calculate what France continues to levy, then what the chosen Italian regime costs — progressive scale, 7% or flat tax. It is the only way to know whether the move pays off.

Social security pensions, private and public.
7% regime: conditions and actual calculation.
New residents' flat tax for large fortunes.

Departure: residence and exit tax

We date your departure from French tax matters and your arrival in Italy. If your securities exceed €800,000 or if you hold at least 50% of the profits of a company, we file the exit tax declaration (Article 167 bis of the General Tax Code).

Your assurance-vie contracts are viewed at the same time; a Luxembourg assurance-vie contract may be considered, case by case.

Inheritance and gifts

We establish, asset by asset, which state would tax your estate or your gifts under the 1990 treaty, and we time the gifts accordingly.

4. Methodology: our way of working

We work in four stages, and at each stage you know where you stand.

The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.

5. What the firm offers you

What concretely sets our work apart.

Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.

Frequently asked questions on Italy

Will my general scheme pension be taxed in Italy or in France?

In both. Article 18 § 2 of the treaty of 5 October 1989 reserves to France the right to tax pensions from its social security system, including the general scheme and Agirc-Arrco; Italy taxes them too and grants a tax credit.

Does the 7% regime apply to my whole pension?

On the Italian side, it applies to your foreign-source income for ten years, if you move to an eligible municipality in the south. On the French side, it changes nothing: your social security pensions remain taxable in France.

Does the treaty with Italy cover gifts?

Yes. The treaty of 20 December 1990 covers inheritance and gifts: real property in the state where it is located, other assets in the state of domicile of the deceased or donor, with a tax credit.

Will I pay social charges on my French rental income?

If you are covered by the Italian social security system, only 7.5%, for both unfurnished and furnished lettings. Otherwise, 17.2% for unfurnished lettings and 18.6% for furnished lettings, from 2025 income onwards.

Does the exit tax apply if I go to Italy?

If your securities exceed €800,000 or if you hold at least 50% of a company's profits, then yes (Article 167 bis of the French General Tax Code). Payment is automatically suspended, but filing a declaration is mandatory.

In summary

In Italy, your social security pensions remain taxable in France, regardless of the Italian scheme chosen. However, the treaty covers inheritances and gifts.

The choice of regime, the municipality and the passing on of your wealth are all costed before departure.

Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.