DT10156 - Italy: Notes You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals. Capital Gains (Article 13) Whereas capital gains are generally taxable only in the state of residence of the person making the disposal, the provisions of paragraph 5 allow Italy to tax gains from the alienation of any property where a UK resident has been a resident of Italy at any time during the five years immediately preceding the alienation of the property, and they are not subject to tax on those gains in the UK.