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.
| 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. |
| 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. |
| 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). |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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 |
| 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. |
| 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. |
| 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. |
| 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. |
| 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.
See also: Guide: Countries with exit tax explained · Tax residency matrix · Inheritance tax matrix.