Leaving France for Italy: Italian residency, exit tax and procedures

Moving to Italy only solves half the problem. Italy considers you a tax resident as soon as one of the following criteria is met: registration with the local civil registry, domicile, residence, or presence of at least 183 days per year. France, for its part, retains the right to review your tax status as long as one of these three domicile criteria remains. If you hold securities, the exit tax may also apply upon your departure.

Italy: a single criterion is enough, and the days don't tell the whole story.

The website of the French Embassy in Italy (August 11, 2026) is clear: an Italian tax resident is someone who resides there "for the greater part of the tax year, that is, at least 183 days per year" (184 days in a leap year). The same page specifies that only one criterion is required: registration with the tax authorities, domicile, or residence as defined by the Italian Civil Code.

The Agenzia delle Entrate (Luxembourg Revenue Agency) commented on these rules in its circular of November 4, 2024, applicable from 2024. Its statement highlights two points of interest for those arriving:

• the concept of domicile is primarily linked to personal and family ties («relazioni personali e familiari»); ;
• Registration with the civil registry is no longer an absolute presumption: it is "una presunzione relativa (e non più assoluta) di residenza fiscale in Italia". You can therefore provide evidence to the contrary.

The day count includes fractions of a day, according to the press release. Our numerical example below shows why counting alone is insufficient.

If both France and Italy consider you a resident

The Franco-Italian convention, signed on October 5, 1989, settles the matter in Article 4, paragraph 2, in this order:

1. the state where you have a permanent home; if you have one in both, the one with which your personal and economic ties are closest (centre of vital interests); ;
2. failing that, the State where you habitually reside; ;
3. then the State of which you are a national; ;
4. Finally, an agreement between the authorities of the two states.

The concept of resident status under the convention takes precedence over domestic tax domicile. The entire text should be read before any partial departure: our pages on the convention and on Article 4B detail both aspects.

The French criteria: to leave, not just to declare

The BOFiP (BOI-IR-CHAMP-10) considers the home or principal residence, the main professional activity, and the center of economic interests. "It is sufficient for one of these criteria to be met." A presence of more than six months in France "is not an absolute criterion": the reverse is also true. Maintaining a residence in Lyon or managing a company from France are factors that the tax authorities may examine with regard to home, principal activity, or center of economic interests.

Exit tax: issues to resolve before departure

The instructions for form 2074-ETD (transfers in 2025) stipulate two cumulative conditions: having been a tax resident in France for at least six of the ten years preceding the transfer, and holding at least 50% of the profits of a company or a securities portfolio exceeding €800,000. The public information sheet states "at least €800,000": the exact threshold should be verified on your file.

The list of non-cooperative states is checked on the date of departure. The Italian Ministry of the Interior outlines the residency rules for EU citizens, detailed below. Information on the forms can be found on our pages about exit tax.

The formalities of settling in Italy

• Less than three months. A valid national identity card or passport is sufficient (France Diplomacy, 15/09/2026).
• More than three months. The Italian Ministry of the Interior requires that you be employed or self-employed in Italy, or have sufficient resources with health insurance, or be a student. You register at the town hall of your usual residence, either in person or online; the town hall will then issue a certificate of registration.
• Time limit and penalty. The page states: "There is no time limit for registering with the public records office" and "You cannot be fined under any circumstances." However, without proof of registration, the authorities may ask you to demonstrate that you meet the residency requirements.
• Health. The Cleiss website describes the registration process with the National Health Service through the ASL (Local Health Association) of your place of residence, which issues your health card (tessera sanitaria). These rules should be consulted on the Cleiss website before proceeding; the current page is a 2024 edition.

This page does not deal with the tax code: no official source consulted describes how to obtain it.

What France continues to impose, what the convention distributes

Once you are a non-resident, you are only taxed in France on your French-source income, subject to the tax treaty. Here are the limits and rules outlined in the 1989 treaty:

French domestic law provides for an exception: the BOFiP (BOI-RPPM-PVBMI-10-30-20) applies to transfers of a stake exceeding 25% of the rights to company profits over the last five years, with a levy of 12.8%. The text of the convention must be read in this context: Article 13 §4 refers to the State of residence. For a resident of France, Article 24 §1 a) grants a tax credit against French tax for Italian-source income taxable in Italy.

The year of departure: one or two statements

According to impots.gouv.fr (page dated December 17, 2025), income from the year of departure is declared the following year. Form 2042 includes income from January 1st to the departure date; form 2042-NR includes only French-source income taxable in France, from the departure date to December 31st. If the SIPNR (French National Taxpayer Service) becomes your tax administration office, the file is automatically transferred to them. On the Italian side, the embassy website indicates form 730 before September 30th and form Redditi PF before November 30th, without specifying the target audience.

Date of arrival in Italy and the 183-day threshold: numerical example (fictitious profile)

Situation. A fictional Lyon-based executive moves to Italy on September 1, 2026. He registers with the Italian government on the day of his arrival and rents an apartment.

Issue. He believes he will only be an Italian tax resident from 2027 onwards, as he will not reach 183 days of presence in Italy in 2026.

Strategy. He counts his days, then rereads the other criteria: registration with the anagrafe, domicile and residence, which are alternative.

Result. From September 1st to December 31st, 2026, he spends 122 days in Italy, 61 days less than the 183-day threshold. With an arrival on May 1st, he would have spent 245 days in Italy, 62 more than the threshold. Therefore, the length of stay alone is insufficient to determine residency: his registration and residence still need to be examined, and the convention will determine whether France also considers him a resident.

What changes depending on your situation

• Your home, your business and your economic interests: these determine whether France remains your tax residence.
• The nature of your income and the country that pays it.
• A portfolio of securities or a company held: the exit tax is calculated before departure.
• Your date of registration with the anagrafe and your family ties: they weigh on the Italian analysis.
• Schemes for new arrivals: our page on Italian new residents details the €300,000 package applicable since January 1, 2026.

No results can be announced without reviewing your file.