Exit Tax

A tax on unrealised capital gains or accumulated wealth imposed when a person ceases to be tax resident of a country. Different countries use different mechanisms: the US §877A exit tax for covered expatriates renouncing citizenship; Germany's Wegzugsteuer on 1%+ private shareholdings; the Netherlands' conserverende aanslag on 5%+ substantial interest; France's exit tax on unrealised gains above EUR 800k portfolios or 50%+ ownership; Australia's Div 855 deemed disposal on departure; Canada's deemed-disposition rules for departing tax residents. Most EU regimes defer payment for EU/EEA moves under freedom-of-movement jurisprudence; third-country moves typically require immediate payment or a bank guarantee. Exit taxes are a material planning consideration for HNW cross-border relocations.