An exit tax is a charge on gains you have not yet realized, triggered when you stop being tax resident in a country. The law treats you as if you sold certain assets the day before you left, so the country can tax the growth that happened while you lived there. In the United States, the trigger is giving up citizenship or a long-held green card instead.
Exit taxes are more common than many people think. Most large economies in Europe and North America have one, and they differ a lot in who they reach, which assets they cover and whether payment can be deferred. The list below covers the main countries as of October 2026, with the official source for each where one is available.
Key takeaways
- The trigger is losing tax residence (or US citizenship), not buying a property abroad or getting a second passport.
- Some exit taxes catch almost all assets (Canada, Australia), while others catch only shares above a threshold (Germany, France, Norway, Spain).
- Moves within the EU and EEA usually get automatic or interest-free deferral, because of EU free movement rules.
- Several countries cancel the tax if you return within a set period, typically between 2 and 12 years.
- The UK and Italy have no general exit tax for individuals, although the UK taxes some gains if you return within five years.
How exit taxes work
Most exit taxes follow the same pattern. On the day before residence ends, the person is deemed to have sold covered assets at market value. The gain is added to that year's income, and the country's normal capital gains rules apply.
The differences lie in four areas:
- Who is caught. Many countries only apply the tax after several years of residence, such as 6 of the last 10 years in France or 7 of the last 12 in Germany.
- What is covered. Some countries cover all property with a few exclusions. Others target only shares, funds or large holdings.
- Thresholds. France starts at €800,000 in securities, Norway allows NOK 3 million of gain, and Japan applies only above ¥100 million in covered assets.
- Deferral and forgiveness. Payment can often be deferred until a real sale, sometimes with security, and some countries cancel the tax after a holding period or on return.
The new country you move to may or may not give a "step-up" in cost basis on arrival. If it does not, the same gain can be taxed again when you sell, and a foreign tax credit may or may not be available. This is one reason the destination matters as much as the departure.
Exit taxes at a glance
| Country | Who is caught | What is taxed | Main relief |
|---|---|---|---|
| United States | Citizens who renounce and long-term green card holders who are "covered expatriates" | Worldwide assets, marked to market | $910,000 gain exclusion for 2026, election to defer with security |
| Canada | Residents who emigrate | Most property at fair market value | Canadian real estate and registered plans excluded, deferral with security |
| Australia | Residents who stop being resident | Assets that are not taxable Australian property | Election to defer until a real sale |
| Germany | People taxable for 7 of the last 12 years | Shares of 1% or more in a company, some fund holdings | Seven annual installments, lapses on return within 7 years |
| France | People resident 6 of the last 10 years | Securities worth over €800,000, or 50% of a company's profits | Deferral, cancellation after 2 or 5 years |
| Spain | People resident 10 of the last 15 years | Shares or funds over €4 million, or stakes above 25% worth over €1 million | EU/EEA rules, deferral for work moves |
| Netherlands | Holders of a substantial interest | Shares of 5% or more in a company | Protective assessment, collected on later sale |
| Norway | Residents who move abroad | Shares, funds and similar assets | NOK 3 million deduction, 12-year deferral |
| Denmark | People taxable on share gains for at least 7 years | Shares worth DKK 100,000 or more | Deferral with annual reporting |
| Austria | Anyone moving abroad | Capital assets, including securities | Indefinite deferral for EU/EEA moves |
| Japan | People resident more than 5 of the last 10 years | Securities and derivatives if total is ¥100 million or more | Deferral up to 10 years, cancellation on return |
Country notes
United States
The US is unusual because the exit tax applies when a person gives up citizenship or a green card held in at least 8 of the last 15 years, not when they move. According to the IRS expatriation tax page, you are a covered expatriate if your net worth is $2 million or more, your average annual net income tax for the past five years is above the inflation-adjusted threshold ($211,000 for 2026), or you cannot certify five years of compliance. Our guide to renouncing US citizenship covers the full rules.
Canada
When you emigrate, you are treated as having sold most property at fair market value. The Canada Revenue Agency excludes Canadian real property, Canadian business property, and pensions and registered plans such as RRSPs, RRIFs and TFSAs. You can elect to defer the tax without interest until a real sale, but security is required if the deferred federal tax is more than $16,500. Our article on Canada's departure tax goes into more detail.
Australia
Under CGT event I1, a person who stops being an Australian resident is deemed to dispose of assets that are not "taxable Australian property." Australian real estate stays within the tax net anyway. An individual can choose to defer, but then those assets are treated as taxable Australian property until sold. Our guide to leaving Australia explains how the residency tests interact with this.
Germany
Germany's rule in section 6 of the Foreign Tax Act applies to people who were taxable in Germany for at least seven of the twelve years before leaving and who hold at least 1% of a company. Since 2025, large holdings in investment funds can also be caught. The tax can be paid in seven equal annual installments, usually against security. If you return within seven years, which can be extended by up to five more, the claim can lapse.
France
Under Article 167 bis of the French tax code, the exit tax applies to people who were tax resident for at least six of the ten years before leaving and whose securities are worth over €800,000, or who hold at least 50% of a company's profits. Moves to the EU, EEA and qualifying treaty countries get automatic deferral. For others, deferral is available on request with guarantees. The tax is canceled if the securities are still held two years after departure, or five years when the holdings exceed €2.57 million.
Spain
Spain applies its exit tax to people who were resident for at least 10 of the 15 years before leaving and who hold shares or fund units worth more than €4 million, or a stake of more than 25% worth over €1 million, under Article 95 bis of the Spanish income tax law. Special rules apply to moves within the EU and EEA. Moves for work to a treaty country can be deferred, and the debt can be waived if the person becomes resident again within the deferral period. Spain also keeps nationals who move to listed tax havens as taxpayers for the year of the move and four more years.
Netherlands
The Netherlands taxes gains on a "substantial interest," generally 5% or more of a company's shares, in Box 2. When a holder emigrates, the tax authority issues a protective assessment on the gain built up so far, which generally becomes payable if the shares are later sold.
Norway
Norway's exit tax has changed several times since 2022. According to the Norwegian Tax Administration, for moves from 20 March 2024 there is a basic deduction of NOK 3 million, and the tax can be paid at once, in installments over 12 years, or deferred for 12 years, usually with security outside the EEA. If you return within 12 years, the liability generally lapses. While tax is deferred, 70% of any distribution you receive must go toward it. The effective rate on share gains is 37.84%.
Denmark
Denmark taxes unrealized gains on shares on departure if you were liable to Danish tax on share gains for at least seven years and your shares are worth DKK 100,000 or more. The Danish Tax Agency lets you defer without interest by reporting each year, with collateral needed only for moves outside the Nordic region and the EU.
Austria
Austria treats any event that ends its right to tax a capital gain, including a move abroad, as a disposal at market value. Capital gains are generally taxed at a special rate of 27.5%. People moving to an EU or EEA state can request deferral until an actual sale.
Japan
Japan's departure tax, in place since 2015, applies to people who leave with ¥100 million or more in securities, silent partnership interests and open derivatives, and who lived in Japan for more than five of the previous ten years. According to the National Tax Agency, payment can be deferred for five years, extendable to ten, if you appoint a tax agent and provide collateral. Returning within the period with the assets still held allows the tax to be canceled.
Other countries with departure rules
- Israel: assets are deemed sold the day before residence ends, with the option to pay when the assets are actually sold.
- South Africa: qualifying worldwide assets are deemed disposed of the day before a person ceases to be tax resident.
- Poland: an exit tax applies to assets worth more than PLN 4 million, generally at 19%.
- New Zealand: people with foreign investment fund interests are treated as selling them at market value when they become non-resident.
Countries without a general exit tax
The UK has no general exit tax for individuals, although its temporary non-residence rule taxes some gains if you return within five years. Our article on whether the UK has an exit tax explains the details. According to research by the UK's Centre for the Analysis of Taxation, Italy is the only other G7 country without one.
Many countries with no capital gains tax at all, such as the UAE, also have no exit tax. That does not stop your old country from applying its own exit tax when you move there.
Questions to answer before a move
- Will I stop being resident under my current country's domestic law, and in which year?
- Does a treaty tie-breaker change that answer? Our guide to tie-breaker rules explains how this works.
- Which of my assets are covered, and what are they worth today?
- Can I defer payment, and is security required for my destination?
- Does my new country reset the cost basis on arrival, or will it tax the same gain later?
- If I hold crypto, does the exit tax cover it? Our guide to crypto taxes when you move abroad covers that question.
Frequently asked questions
Which countries have an exit tax?
Countries with a general exit tax for individuals include the United States, Canada, Australia, Germany, France, Spain, the Netherlands, Norway, Denmark, Austria and Japan. Israel, South Africa, Poland and New Zealand also have departure rules. The scope and thresholds vary widely.
Does buying a golden visa or second passport trigger an exit tax?
No. Exit taxes are triggered by losing tax residence, or in the US by giving up citizenship or a long-term green card. Getting a new residence permit or passport does not by itself end tax residence anywhere.
Can I avoid an exit tax by moving within the EU?
Moving within the EU or EEA usually does not remove the tax, but it often allows automatic deferral without security. The tax may then become payable if you sell the assets or move outside the bloc.
Is crypto covered by exit taxes?
It depends on the country. Some exit taxes cover all assets, which can include crypto, while others cover only shares and funds. Japan's departure tax, for example, applies to securities and derivatives.
Does the UK have an exit tax?
Not a general one, as of October 2026. Gains realized abroad can still be taxed if you return within five years, and UK property stays within capital gains tax for non-residents.
Important: This article is general information, not tax, legal or financial advice. Rules change often and depend on your personal circumstances. Speak with a qualified professional in each relevant country before you act.