An exit tax is a tax some countries charge when you stop being tax resident or give up citizenship, treating you as if you sold certain assets at market value on the way out. The US, Canada, Australia, Germany, the Netherlands, France, Spain, Norway, Denmark, Japan and South Africa all have a version, while the UK and New Zealand have no general exit tax.
Last checked: September 2026
In short:
- An exit tax charges tax on unrealised gains built up while you were resident, even though you haven’t sold anything.
- For 2026, a US covered expatriate is taxed as if they sold everything the day before expatriating, and the first $910,000 of gain is excluded.
- Several countries let you defer the bill, but that usually means filing an election on time and sometimes putting up security.
What an exit tax actually is
Capital gains are normally taxed when you sell. An exit tax (also called a departure tax or deemed disposal) treats you as having sold certain assets at fair market value when you stop being resident, so the country you’re leaving taxes the gain built up on its watch. Scope varies: Canada, Australia and South Africa catch most assets, while Germany, the Netherlands, France and Spain focus on company shareholdings. The US version applies only when a citizen renounces or a long-term green card holder gives up status, and only to “covered expatriates”.
Country comparison
| Country | What triggers it | What’s caught | Key thresholds / relief |
|---|---|---|---|
| United States | Renouncing citizenship, or ending long-term residence (green card in 8 of the last 15 years) | All property, deemed sold at fair market value the day before expatriation (IRC 877A) | Covered if net worth $2m+, 5-year average annual net income tax over $211,000 (2026), or no 5-year compliance certification. 2026 exclusion: $910,000. Deferral election on Form 8854 |
| Canada | Ceasing residence | Most property at fair market value | Excludes Canadian real property, business property of a Canadian permanent establishment, and registered plans. Deferral election by April 30 of the following year; security needed if federal tax exceeds $16,500 |
| Australia | Ceasing residence (CGT event I1) | Assets that are not taxable Australian property | Australian real property excluded. You can choose to disregard the gains; the assets then stay taxable in Australia until sold |
| Germany | Ceasing residence after being fully taxable for 7 of the last 12 years (§6 AStG) | Shareholdings of at least 1% (§17 EStG) | Tax can be paid in 7 annual instalments, usually against security. Liability falls away if you return within 7 years (extendable to 12) |
| Netherlands | Emigration | Substantial interest (5%+), plus Dutch pension and annuity rights | Protective assessment: indefinite for shareholdings (due on sale or dividends), typically 10 years for others |
| France | Moving tax residence abroad after 6 of the last 10 years resident (art. 167 bis CGI) | Latent gains on holdings over 50% of a company’s profits or worth over €800,000 in total | Automatic deferral to EU/EEA and qualifying treaty states. Relief after 2 years, or 5 years if holdings exceed €2.57m |
| Spain | Losing residence after 10 of the last 15 years (art. 95 bis LIRPF) | Shares | Applies if shares exceed €4m, or €1m where you hold more than 25% of a company |
| Norway | Emigration | Shares, fund units, employee options and more | NOK 3m basic deduction from 20 March 2024. From 20 November 2024, tax must be paid within 12 years unless you move back |
| Denmark | Moving away after at least 7 years liable to Danish share tax | Shares | Shares worth DKK 100,000+. Interest-free deferral via form 04.065 by 1 July the year after moving; security needed outside the EU/Nordics |
| Japan | Leaving after more than 5 of the last 10 years resident | Securities and derivatives | Applies at ¥100m or more. Payment can be deferred 5 years (up to 10) with a tax agent and collateral |
| South Africa | Ceasing tax residence | Worldwide assets at market value on the day before | Excludes SA immovable property and approved retirement fund interests |
| United Kingdom | No general exit tax | n/a | Temporary non-residence rule: return within 5 years (after sole UK residence in 4 of the prior 7 tax years) and gains on assets held before leaving are taxed in the year you return |
| New Zealand | No exit tax | n/a | No comprehensive capital gains tax; no deemed disposal on departure found in the sources we checked |
Planning points that actually matter
Timing. The deemed sale is usually priced on your departure date (or the day before). For shares in your own company, that valuation sets the bill. Any pre-departure restructuring has its own tax consequences, so get advice before you go.
Know your residence end date. Everything hangs on the date you stop being resident. Keep evidence: lease end, flights, new lease, deregistration.
Valuation evidence. For private company shares, crypto or property, get a defensible valuation dated close to departure. You will likely need it twice: once for the exit return, and again when the new country asks about your base cost.
Deferral elections. Canada (April 30 deadline), Australia (choice to disregard), Denmark (form by 1 July), the US (Form 8854) and Japan all have deferral options, but they’re elections, not defaults. Miss the deadline and the tax is due now, and security can tie up cash.
Treaty relief and step-up. The big risk is double tax: your old country taxes the deemed gain, then your new country taxes the real gain on sale using your original cost. Check whether a treaty or your new country’s domestic rules give a credit or a step-up to market value before assuming you’re covered. Germany and the UK also have rules tied to returning within a set period, so factor in any chance you’ll move back.
Related: Tax residency explained: why the 183-day rule is a myth for most countries · Tax-free countries (2026): no income tax countries you can actually live in · How to leave the US (2026): a checklist for moving out of the US · US expat taxes (2026): filing, FEIE, FBAR and catching up
Related guides: Second passport (2026): how to get one by descent, residency or investment · Leaving the UK (2026): Statutory Residence Test, split year and FIG regime · France committee votes to extend exit tax to crypto above €800,000
Quick answers
Q: Does the US have an exit tax for renouncing citizenship?
Yes, for covered expatriates. For 2026 you’re covered if your net worth is $2m or more, your average annual net income tax over the previous five years exceeds $211,000, or you can’t certify five years of tax compliance. Your property is treated as sold the day before expatriating, with $910,000 of gain excluded.
Q: Do I pay tax on my shares when I leave Australia?
Possibly. When you stop being resident, CGT event I1 treats assets that aren’t taxable Australian property (broadly, anything other than Australian real property and business assets used through an Australian permanent establishment) as sold at market value. You can choose to disregard those gains instead, which keeps the assets in the Australian tax net until you actually sell them.
Q: Does the UK charge exit tax when you move abroad?
No, the UK has no general exit tax for individuals. However, under the temporary non-residence rule, if you were solely UK resident in at least four of the seven tax years before leaving and return within five years, gains on assets held before you left can be taxed in your year of return.
Sources
- IRS, Expatriation tax
- IRS, Rev. Proc. 2025-32 (2026 inflation adjustments, sections 4.37-4.38)
- Canada Revenue Agency, Dispositions of property for emigrants of Canada
- ATO, Guide to capital gains tax 2026, Appendix 1 (CGT event I1)
- ATO, Foreign residents, temporary residents and changing residency
- REB Steuerberatung, Wegzugsbesteuerung nach §6 AStG
- Belastingdienst, Conserverende aanslag bij emigratie
- Van Lanschot Kempen, Conserverende aanslag
- Études fiscales internationales, Régime de l’exit tax (May 2026)
- Agencia Tributaria, Régimen especial de ganancias patrimoniales por cambio de residencia
- Skatteetaten, Exit tax
- Skattestyrelsen, Skat af aktier, hvis du flytter fra Danmark
- National Tax Agency Japan, 国外転出時課税
- Forvis Mazars, What will leaving South Africa cost you
- HMRC, HS278 Temporary non-residents and Capital Gains Tax (2026)
- Russell McVeagh, New Zealand-bound: tax insights for Australian founders
This is general information from the Nomad Forums team, not tax, legal or immigration advice. Rules change; check with a qualified adviser or the official source before acting.
Over to you: Has anyone here actually filed a departure return (Canada’s T1243, Australia’s I1 choice, or Germany’s instalment request), and how did you evidence the valuation? And if you moved somewhere that gave you a step-up in base cost on arrival, which country was it?