Exit Tax by Country

Exit tax (also called departure tax or deemed-disposition tax) can be triggered when a person leaves a country's tax residence — and in the US case, also when citizenship is renounced. The mechanics, thresholds, and treaty-relief options vary widely. This reference covers the major countries that levy exit tax, the partial regimes that apply only at corporate level, and the major destinations that have none.

Last reviewed: 2026-05-09. Exit-tax rules are highly technical and personal to each taxpayer's situation — this is general information, not legal or tax advice.

Exit-tax presence, triggering threshold, and asset categories covered by country
Country	Exit tax	Trigger	Threshold	Assets covered / notes
Australia	Yes	Ceasing Australian tax residence — most resident departures.	No threshold — applies on all departures with limited exclusions.	Deemed disposition at FMV (CGT event I1) on most CGT assets. Taxable Australian property (Australian real estate, interests in Australian land-rich entities, mining rights) is excluded — remains subject to Australian CGT on actual disposal as non-resident. Choice election available: continue treating non-Australian assets as taxable Australian property (avoiding immediate CGT but retaining CGT exposure on later disposal). Most departing residents make the choice for offshore-listed shares and other non-Australian investments. https://www.ato.gov.au/individuals-and-families/coming-to-australia-or-going-overseas/leaving-australia
Austria	Yes	Ceasing Austrian tax residence while holding capital assets (securities, other financial instruments) or business assets (Wegzugsbesteuerung, Income Tax Act §27(6) and §6(6)).	No minimum shareholding threshold for the capital-assets exit tax (unlike Germany's 1% corporate-shareholding rule) — it applies to unrealised gains on securities generally.	Deemed disposal of securities/financial capital assets and business assets at fair market value on departure. Real estate is not covered — it remains taxable on actual disposal. EU/EEA departures qualify for non-interest-bearing deferral, payable in instalments since a 2016 reform, until the assets are actually sold; non-EU/EEA departures generally require immediate payment or security. https://www.bmf.gv.at/
Canada	Yes	Ceasing Canadian tax residence — applies to all Canadian tax residents, citizens or non-citizens.	No threshold — applies on all departures (subject to property-by-property exclusions).	Deemed disposition at FMV of most capital property — taxable capital gains immediately recognised. Excluded: Canadian real estate (taxable on actual sale via non-resident withholding), RRSP/RRIF, business property held in Canadian permanent establishment, certain employee stock options. Departing Canadians can elect to defer the exit-tax liability by posting security with the CRA (typically by holding the asset and filing Form T1244). Canadian deemed disposition is broader than US Section 877A in scope but applies regardless of net-worth threshold. https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-or-entering-canada-establishing-residency.html
Denmark	Yes	Loss of Danish tax residence by individual.	Latent capital gain on shares with cumulative ≥7-year Danish-residence period.	Latent capital gains on shares (listed and unlisted). Real estate and other assets outside scope. Deferred payment available with collateral; deferred liability cancels on actual sale or after 5 years (subject to extension applications). https://www.skat.dk/
France	Yes	French tax resident with ≥6 of last 10 years residence transferring tax domicile abroad.	Securities portfolio worth ≥€800,000 OR holding ≥50% in any single company.	Latent capital gains on share portfolios subject to taxation on departure. Real estate excluded (remains French-source, taxed on actual disposal). Tax automatically deferred for EU/EEA departures (no security required), and on application for non-EU/EEA departures (security typically required). Deferral lapses on actual sale. Returning to France within 15 years (8 years for EU/EEA returns) generally cancels the exit-tax liability. https://www.impots.gouv.fr/
Germany	Yes	Permanent move abroad of long-term resident (10+ of last 12 years) holding ≥1% interest in a corporation.	Holding ≥1% in any corporation (German or foreign) — captures most founders, executives, and HNWIs.	Deemed sale of corporate shareholding (Wegzugsteuer / Außensteuergesetz § 6). Other assets generally not subject to German exit tax. EU intra-Member State departures used to qualify for permanent indefinite deferral; the 2022 reform removed that — now only a 7-year instalment plan is available (vs immediate payment for non-EU departures, with limited deferral via security posting). Major German entrepreneur tax-planning topic. https://www.bzst.de/EN/
Israel	Yes	Loss of Israeli tax residence — individuals.	No specific threshold — applies to all residents leaving.	Deemed disposition at FMV (Section 100A). Israeli real estate excluded (remains subject to Israeli capital-gains tax on actual sale). Israeli new-immigrant/returning-resident regime grants 10-year exemption on foreign-source income — exit-tax planning interacts with this regime. Israelis emigrating before completing 10-year new-immigrant period typically face fewer exit-tax consequences as foreign-source asset gains are pre-exempted. https://www.gov.il/en/Departments/israel_tax_authority/
Japan	Yes	Departure from Japan by an individual holding significant financial assets who has had a Japan address for more than 5 of the past 10 years (also applies on gift/inheritance of such assets to a non-resident).	Aggregate fair market value of applicable financial assets (listed/unlisted securities, unrealised gains on certain derivatives and other specified financial instruments) of ¥100 million or more.	Deemed sale of securities and certain other specified financial instruments at fair market value on the day before departure (kokugai tenshutsu-ji kazei — national exit taxation). In force since July 2015. Deferral of up to 5 years (extendable to 10) is available if the taxpayer posts security and files annually; the liability is cancelled if the assets are still held and the taxpayer resumes Japanese tax residence within the deferral period. Real estate and most non-financial assets are outside scope. https://www.nta.go.jp/
Netherlands	Yes	Departure of substantial-interest shareholder (≥5% holding) from Dutch tax residence.	≥5% shareholding in any company (substantial interest / aanmerkelijk belang).	Latent capital gain on substantial-interest shares — protective assessment issued at departure, payable when shares are sold. Conservation assessment (conserverende aanslag) issued at departure — collection only triggers on actual share disposal. Box-3 assets (regular investments below 5%) not subject to exit tax. EU/EEA departures benefit from automatic 10-year preservation; non-EU departures may require security. https://www.belastingdienst.nl/
Norway	Yes	Loss of Norwegian tax residence by previously-resident shareholder.	Latent capital gain on listed-share holdings ≥ NOK 500,000 (~$45,000).	Latent capital gains on listed and unlisted shares. From November 2022 reform, unrealised gains accrued during Norwegian residence are taxed regardless of when departure occurs. The 2022 reform eliminated the prior 5-year limit — gains accrued during Norwegian residence now stay taxable indefinitely after departure. Combined with the 1.1% wealth tax, has driven measurable HNWI emigration from Norway since 2022. https://www.skatteetaten.no/en/
Poland	Yes	An individual or company transferring assets outside Poland, or an individual ceasing Polish tax residence, where Poland would lose the right to tax future gains on those assets.	For individuals, applies where the aggregate market value of assets subject to the tax exceeds PLN 4,000,000.	Unrealised gains on business assets and financial assets, deemed disposed of at fair market value. Rate is generally 19%, or 3% where the asset's tax cost basis cannot be established. Poland extended exit tax to individual taxpayers from 1 January 2019 — going beyond the EU ATAD's corporate-only minimum requirement, making it one of the more assertive individual exit-tax regimes in the EU. Deferred payment (up to 5 years, in instalments) is available for EU/EEA departures. https://www.podatki.gov.pl/
South Africa	Yes	Loss of South African tax residence — individuals and trusts.	No threshold — all departing residents subject.	Deemed disposition at FMV of most capital assets. Excluded: South African immovable property, interest in trading partnerships, retirement-fund interests. South Africa formally requires a 'financial emigration' procedure with SARS to confirm departure of tax residence. Combined with the 2024-25 abolition of the formal Reserve Bank exchange-control emigration process, the SARS tax-clearance certificate is now the principal mechanism. Substantial pre-emigration tax planning typical for HNWIs. https://www.sars.gov.za/
Spain	Yes	Loss of Spanish tax residence after ≥10 of last 15 years residence.	Securities portfolio ≥€4 million OR ≥25% holding in a single company worth ≥€1M.	Latent capital gains on shares. Real estate and other assets outside scope. EU/EEA departures permit deferral and 10-year extinction if shares not sold. Non-EU/EEA departures require immediate payment unless security is posted. Beckham-regime taxpayers are not subject to exit tax during the 6-year regime period — they exit before ever becoming standard residents. https://sede.agenciatributaria.gob.es/
United States	Yes	Citizenship renunciation OR long-term green-card holders (8+ of last 15 years) abandoning resident status, IF classified 'covered expatriate'.	Net worth ≥ $2M, OR average annual federal income tax ≥ $206,000 (2024), OR failure to certify 5-year tax compliance on Form 8854.	Mark-to-market deemed sale of all worldwide assets at FMV. Pension/IRA distributions taxed at 30% withholding upon future distribution. Only the gain above $866,000 (2024 inflation-adjusted exclusion) is taxable. Section 877A also imposes a 30% withholding tax on inheritances/gifts received by US persons from covered expatriates (Section 2801 — finalised regulations issued 2024). Taxpayers in long-term green-card status who never naturalise can be the most affected — many do not realise their decade-plus holding triggers expat status. https://www.irs.gov/individuals/international-taxpayers/expatriation-tax
Belgium	Limited / corporate-only	Corporate exit tax under EU ATAD (companies transferring assets, a business, or their tax residence abroad). No general personal exit tax for individuals leaving Belgium.	Corporate asset/residence transfer.	Corporate-level deemed disposition only. Belgium does not tax private individuals' departure on ordinary portfolio-investment gains. A narrow anti-abuse rule (Article 90, 9° CIR92) can tax gains on substantial shareholdings (broadly ≥25%) sold shortly after emigration to certain non-EEA purchasers, but this is not a general deemed-disposition exit tax. https://finances.belgium.be/
Croatia	Limited / corporate-only	Corporate exit tax under EU ATAD. No general personal exit tax for individuals.	Corporate asset/residence transfer.	Corporate-level deemed disposition only. Croatia, like most smaller EU member states, has not extended exit tax beyond the ATAD-mandated corporate minimum to individual taxpayers. https://www.porezna-uprava.hr/
Czech Republic	Limited / corporate-only	Corporate/business-asset exit tax under EU ATAD (transfer of assets, a permanent-establishment business, or tax residence abroad by a company). No general personal exit tax for individuals.	Corporate or business-asset transfer.	Corporate-level deemed disposition of the transferred business assets only. The Czech Republic does not tax individuals' departure-triggered capital gains on personal investment portfolios — only the ATAD-mandated corporate/business exit tax applies. https://www.mfcr.cz/
Greece	Limited / corporate-only	Corporate exit tax under EU ATAD. No general personal exit tax for individuals leaving Greek tax residence.	Corporate asset/residence transfer.	Corporate-level deemed disposition only. Greece has no personal exit tax — relevant for participants in Greece's non-dom flat-tax regime for HNWIs and pensioners, who can end the regime or leave Greek residence without a departure capital-gains charge on personal investments. https://www.aade.gr/
Hungary	Limited / corporate-only	Corporate exit tax under EU ATAD. No general personal exit tax for individuals.	Corporate asset/residence transfer.	Corporate-level deemed disposition only. Hungary has no personal departure tax on individual investment portfolios — relevant for anyone on Hungary's flat-rate personal income tax regime considering relocation. https://nav.gov.hu/
Ireland	Limited / corporate-only	Corporate exit tax under EU ATAD (companies migrating residence).	Corporate residence change.	Corporate-level only — Section 627 TCA. No personal exit tax for individuals. Ireland has no personal exit tax. Individuals leaving Ireland have no immediate tax consequence on Irish-resident-period gains (subject to specific anti-avoidance rules on close-company and similar structures).
Italy	Limited / corporate-only	Italian companies relocating tax residence abroad (corporate exit tax). No general personal exit tax.	Corporate residence change.	Corporate-level deemed disposition. Individuals are not subject to general exit tax on personal investments. Italy has no personal exit tax for individuals departing the country (a notable distinction from Germany, France, Spain). Only corporate-level exit tax exists, on companies relocating their tax residence. Individuals on the €100,000/€200,000 HNWI flat-tax regime can leave without any exit-tax consequence. https://www.agenziaentrate.gov.it/
Luxembourg	Limited / corporate-only	Corporate exit tax under EU ATAD. For individuals, a follow-up taxation rule can apply to gains on substantial shareholdings (broadly ≥10%) sold within several years after ceasing Luxembourg residence.	Substantial shareholding (≥10%) for the individual follow-up rule; corporate residence/asset transfer for the ATAD exit tax.	Corporate-level deemed disposition under ATAD. The individual follow-up rule taxes actual realised gains on substantial participations after departure, rather than deeming an immediate disposal at the moment of leaving. Luxembourg has no general deemed-disposition exit tax charged at the moment of departure for individuals — unlike Germany, France, or the Netherlands, ordinary investment portfolios leave Luxembourg tax scope without an immediate exit charge. https://impotsdirects.public.lu/
Portugal	Limited / corporate-only	Companies migrating tax residence (corporate exit tax — Article 83 CIRC).	Corporate residence change.	Corporate-level only. No general personal exit tax for individuals. Portugal has no personal exit tax for individuals. NHR/IFICI residents departing within the regime period have no exit consequence on foreign-source assets.
United Kingdom	Limited / corporate-only	Specific anti-avoidance: 5-year temporary non-residence rule.	UK tax resident at least 4 of last 7 years departing for less than 5 complete tax years.	Capital gains realised during the 5-year absence are taxed on the year of return (treated as if realised in the year of return) — not a true exit tax but a deferred capture mechanism. The UK does not have a classical exit tax. The 5-year temporary non-residence rule prevents short departures aimed solely at realising untaxed gains. Long-term emigrants (>5 years abroad) escape UK CGT on non-UK-situs assets entirely. The April 2025 IHT reform shifted IHT exposure to a 10-year residence trigger but did not introduce CGT exit tax. https://www.gov.uk/tax-foreign-income/residence
Argentina	None	—	—	— Argentina has no deemed-disposition exit tax. Ceasing Argentine tax residence switches the individual to non-resident status, taxable only on Argentine-source income and gains going forward — unrealised gains on assets held at departure are not deemed realised. https://www.afip.gob.ar/
Brazil	None	—	—	— Brazil has no deemed-disposition exit tax on unrealised gains. Departing taxpayers must file a Declaração de Saída Definitiva do País (Definitive Country-Exit Declaration) with Receita Federal, settling tax on income and gains actually realised up to the departure date — but unrealised appreciation in assets retained after departure is not taxed at the point of leaving. https://www.gov.br/receitafederal/
Chile	None	—	—	— Chile has no exit tax or deemed-disposition rule triggered by ceasing Chilean tax residence. Non-residents remain subject to Chilean tax (including additional/withholding tax) on Chilean-source income and gains only. https://www.sii.cl/
China	None	—	—	— China has no deemed-disposition exit tax. Non-domiciled foreign individuals are shielded from worldwide-income taxation on foreign-source income unless they accumulate six consecutive full years of Chinese tax residence without a qualifying break (the 'six-year rule') — departing before that threshold, or taking a sufficient absence, resets it. No charge applies to unrealised gains on departure. https://www.chinatax.gov.cn/
Hong Kong	None	—	—	— Hong Kong has no capital gains tax and no exit tax. Departure of tax residence has no tax consequence on investment holdings.
India	None	—	—	— India has no deemed-disposition exit tax. Certain departing individuals may be required to obtain an income-tax clearance certificate under Section 230 of the Income-tax Act confirming no outstanding liabilities, but this does not tax unrealised gains — Indian-source capital gains remain taxable only on actual disposal, including for non-residents. https://www.incometax.gov.in/
Indonesia	None	—	—	— Indonesia has no exit tax on unrealised gains. Indonesia previously levied a flat 'fiscal exit tax' (fiskal luar negeri) on individuals travelling abroad without a tax ID (NPWP) — a departure fee, not a capital-gains deemed-disposition charge — which was abolished for taxpayers from 2011. https://www.pajak.go.id/
Malaysia	None	—	—	— Malaysia has no exit tax. Malaysia does not generally tax capital gains for individuals (aside from Real Property Gains Tax on Malaysian real estate); ceasing Malaysian tax residence has no deemed-disposition consequence. https://www.hasil.gov.my/
Mexico	None	—	—	— Mexico has no deemed-disposition exit tax. An anti-abuse rule treats a departing individual as still Mexican tax-resident for the year of departure plus the following year if they relocate to a jurisdiction Mexico treats as a preferential/low-tax regime, but this does not create a charge on unrealised gains. https://www.sat.gob.mx/
Philippines	None	—	—	— The Philippines has no exit tax. Filipino citizens who qualify as non-resident citizens (working or residing abroad) are taxed only on Philippine-source income, not worldwide income — ceasing resident status has no deemed-disposition consequence on assets held abroad. https://www.bir.gov.ph/
Russia	None	—	—	— Russia has no exit tax. Ceasing Russian tax residence (based on the 183-day rule) reclassifies the individual as a non-resident, subject to a higher flat withholding rate on Russian-source income (typically 30% vs. 13%/15% for residents) — but there is no deemed disposal of unrealised gains. https://www.nalog.gov.ru/
Singapore	None	—	—	— Singapore has no capital gains tax (with limited exceptions for trader-classified activity), and no exit tax. Departure of tax residence has no immediate tax consequence on personal investments.
Switzerland	None	—	—	— Switzerland has no exit tax. Capital gains on movable property are generally not taxed at all (except for professional traders); on departure there is therefore typically no charge. Real-estate gains are taxed cantonally at the time of actual sale, regardless of residence.
Thailand	None	—	—	— Thailand has no exit tax or deemed-disposition rule. Thai tax residence is based on a 180-day physical-presence test each calendar year; ceasing residence ends worldwide-income exposure with no departure charge on unrealised gains. https://www.rd.go.th/
Turkey	None	—	—	— Turkey has no exit tax or deemed-disposition rule for individuals or companies changing tax residence. Capital gains on Turkish-situs assets (notably real estate and Turkish securities) generally remain taxable on actual disposal under Turkey's source-based rules regardless of the owner's residence. https://www.gib.gov.tr/
United Arab Emirates	None	—	—	— UAE has no personal income tax, no capital gains tax (except 9% federal corporate tax above AED 375,000 for businesses), and no exit tax.

Reading this matrix

Personal vs corporate exit tax. Most EU countries have implemented a corporate-level exit tax under the EU Anti-Tax-Avoidance Directive (ATAD). A smaller set extends exit tax to individuals — Germany, France, Spain, Netherlands, Norway, Denmark, plus the US, Canada, Australia, South Africa, and Israel.
Threshold-based vs universal. The US (Section 877A) and France apply only above net-worth / portfolio thresholds. Canada, Australia, and South Africa apply on all departures regardless of size. Germany applies specifically to ≥1% shareholders.
EU intra-Member State deferrals.Many EU exit-tax regimes allow indefinite deferral on departures within the EU/EEA (often with payment in instalments) and require immediate payment or security only for non-EU departures. Germany's 2022 reform notably tightened the EU deferral.
US exceptionalism. The US is the only major country that taxes its citizens on worldwide income regardless of residence — and the only one with a citizenship- renunciation exit tax (Section 877A). Long-term green-card holders abandoning their resident status face the same regime if they meet the thresholds.
Real estate is typically excluded. Most regimes exclude domestic real estate from exit-tax scope — it remains taxable at actual disposal under non-resident rules. The exit-tax mechanism captures movable wealth (shares, securities) where there would otherwise be no future taxing right.