"One day I will move abroad." It is one of the most common sentences among successful business owners and investors, and it sounds harmless. One day. When the children have left home, when the business runs itself, when the time is right.
The problem with "one day" is that the tax rules do not wait for you. In several countries, leaving is itself a taxable event: the state treats you as if you had sold your shares, your funds or your whole portfolio the day before you left, and taxes a gain you have never actually received. The longer your assets grow while you plan, the larger that gain becomes. This guide shows which of eleven home countries charge an exit tax, how it works, how payment can be deferred, and which countries have no exit tax but other rules that bite.
What an exit tax is
An exit tax, also called a departure tax, treats your departure as a deemed disposal: your assets are valued at market price on the day you stop being resident, and the difference from what you paid is taxed as a gain. No sale, no cash, but a tax bill. The logic from the state's point of view is simple: the gain was built up while you lived there, and once you have left, it can no longer reach it.
Not every country does this, and those that do differ widely in what they catch. Some tax almost everything, some only larger shareholdings, some only very specific deferred gains. Here is the picture, country by country, from the authorities' own sources.
United States: the expatriation tax
Americans are a special case, because moving abroad does not trigger anything. The US taxes its citizens wherever they live, so the exit tax only applies when you give up citizenship, or when a long-term green card holder (at least 8 of the last 15 years) ends residence. Under sections 877 and 877A, a covered expatriate is taxed as if all property were sold the day before expatriation. You are covered if your average annual net income tax is above USD 211,000 for 2026, your net worth is USD 2 million or more, or you fail to certify 5 years of tax compliance on Form 8854.
The gain is reduced by an exclusion of USD 910,000 for 2026 (USD 890,000 for 2025). IRAs and similar accounts are treated as fully distributed, and eligible deferred compensation is subject to 30% withholding. The tax on deemed sales can be deferred with interest and security. Exceptions from the tax and net-worth tests exist for certain dual citizens from birth and for minors under 18 and a half. Renunciation itself takes place before a US consular officer abroad (fee USD 450), and not filing Form 8854 carries a USD 10,000 penalty. The IRS expatriation tax page is the starting point.
Canada: the departure tax
Canada has one of the broadest rules. Section 128.1(4) of the Income Tax Act deems you to sell most property at fair market value on the day you leave, with the gain reported on Form T1243. Canadian real estate, business property of a Canadian permanent establishment, and registered plans and pensions such as RRSPs, RRIFs, TFSAs and pension plans are excluded. People resident in Canada for 60 months or less in the previous 10 years are also exempt for property they brought in or inherited.
If your property is worth more than CAD 25,000, you must file Form T1161 even without a return. Payment can be deferred interest-free until the actual sale by electing on Form T1244 by 30 April of the following year, with security required above CAD 16,500 of federal tax. The CRA's page on dispositions for emigrants sets out the details.
Australia: CGT event I1
Australia's version is CGT event I1: it happens when you stop being an Australian resident, and a capital gain or loss is worked out on each asset you own just before then. Taxable Australian property, such as Australian real estate, and assets acquired before 20 September 1985 are excluded.
The important twist is the choice. Instead of paying, you can choose to disregard the gains and losses on all assets covered by the event. Those assets then stay within Australia's CGT net as taxable Australian property until you dispose of them or become resident again. The choice must be made by the day the income tax return for the departure year is lodged. It is not a free pass, but it turns an immediate bill into a deferred one.
Norway: the NOK 3 million rule
As Skatteetaten describes it, Norway taxes shares and similar assets (Norwegian and foreign shares, fund units, share savings accounts, options and derivatives on such assets, capital insurance) as if they were sold the day before you leave. Only the part of the total net gain above NOK 3 million is taxed, and only value built up while you were resident counts. For moves outside the EEA, losses are not netted.
Payment can be deferred for 12 years, normally against security, and deferral ends on sale, death (unless heirs take over), transfer, and partly on dividends. The tax lapses if you become resident in Norway again within 12 years. These rules apply to emigrations from 20 March 2024. Remember also that a Norwegian resident of ten years or more stays tax resident until the end of the third income year after departure.
Denmark: shares from DKK 100,000
Denmark treats assets leaving Danish taxation as sold at market value when your liability ends. Shares are taxed if their total market value is DKK 100,000 or more per person and, as a rule, you were liable to Danish tax for at least 7 of the last 10 years. Claims and financial contracts follow the same threshold, and crypto-assets are deemed sold on the day of departure.
Payment of the share tax can be deferred, provided the departure information and a holding statement are filed on time. For a move to Latin America, adequate security must also be given, and the deferred tax falls due as dividends are received and shares are sold where the new country taxes less. Large employer pension contributions in the 5 years before departure can also be taxed after the event.
Netherlands: the conservatory assessment
The Netherlands has no general deemed disposal of all assets, but on emigration it issues a conservatory assessment on three things: pension rights, deducted annuity premiums and a substantial interest (generally 5% or more of a company), taxed at the highest rate. It is issued after the return for the emigration year.
For pensions and annuities, payment is deferred for up to ten years and the remainder can then be remitted, but the tax becomes payable if you breach the rules, for example by commuting the pension. For a substantial interest held by someone who deregistered after 15 September 2015, the deferral is lifelong with no remission: selling the shares, paying dividends or the company ceasing makes it (partly) payable. Deferral is automatic only within the EU/EEA. Moving to a non-EU country means requesting deferral, and in some cases providing security.
The narrow rules: Sweden, Finland and New Zealand
Three countries have no broad exit tax, but specific rules that catch some people.
No exit tax, but not free: the UK and Ireland
The UK has no exit tax or deemed disposal for individuals who emigrate. Non-residents pay Capital Gains Tax only on UK property and land (and UK branch assets). But the temporary non-residence rule applies: gains made while abroad can be taxed if you return within 5 years. For Inheritance Tax, since 6 April 2025 someone who was UK resident for at least 10 of the previous 20 tax years stays within UK Inheritance Tax on worldwide assets for a tail of 3 to 10 years after leaving.
Ireland has no general exit tax on individuals either; its exit tax rules apply to companies. Instead, section 29A catches an Irish-domiciled person who is outside the Irish tax charge for no more than 5 years: shareholdings of 5% or more of a company, or worth over EUR 500,000, sold in that period are treated as disposed of on the last day of the final year of residence. Non-residents also remain liable to capital gains tax (31% for most gains) on Irish land and buildings, and the three-year ordinary-residence tail keeps worldwide gains taxable after you leave.
The overview: charge and deferral
| Country | What is taxed on leaving | Deferral |
|---|---|---|
| United States | All property of a covered expatriate (on renouncing or ending long-term residence) | With interest and security |
| Canada | Most property, deemed sold at fair market value | Interest-free until sale (T1244), security above CAD 16,500 |
| Australia | Each CGT asset (CGT event I1), except Australian property | Choice to disregard; assets stay in the CGT net |
| Norway | Shares and similar assets, net gain above NOK 3 million | Up to 12 years, normally against security |
| Denmark | Shares from DKK 100,000, claims, crypto | Possible; security required for Latin America |
| Netherlands | Pension rights, annuities, 5% stakes (conservatory assessment) | On request outside the EU; security in some cases |
| Sweden | No general charge; ten-year rule on share sales | Not applicable |
| Finland | Deferred share-swap gains within 5 years | Not applicable |
| New Zealand | FIF interests deemed sold | Not applicable |
| United Kingdom | No exit tax; 5-year return rule; IHT tail | Not applicable |
| Ireland | No exit tax; 5-year rule on large shareholdings | Not applicable |
Why timing matters
Exit taxes are built on value, and value grows. Every year you wait, the gain that would be taxed on departure can become larger. Thresholds and tests also move: the US exclusion is adjusted every year, the UK's long-term residence test for Inheritance Tax has applied since 6 April 2025, Norway's current rules apply to emigrations from 20 March 2024, and a 2022 Swedish directive asked an inquiry to consider general exit rules. Some tests also depend on how long you have lived in the country: Denmark's share rule generally needs 7 of the last 10 years, and Canada exempts brought-in property for people resident 60 months or less in the previous 10 years.
The point is not to panic, but to know your number before you decide. An exit tax planned years ahead is a cost you can model, structure and sometimes defer. An exit tax discovered after the move is a bill. Companies, holdings and investment structures need particular care; see my guide to company structures and how crypto gains are treated in Latin America.
Getting the order right before the move
An exit tax is only one part of leaving well. You also need to actually end your tax residence, which is a separate set of rules with its own trailing periods; I explain it in why moving abroad does not end tax residence. And you need a genuine new residence, ideally in a country whose tax system fits your income, which I compare in my guide to territorial tax countries. Whether a treaty then helps is covered in my tax treaty guide.
This is exactly the sequence I work through with my clients: valuation, exit charge, deferral, residence, and only then the move.
If you hold shares, funds, a company or a large portfolio and are thinking about "one day", let us look at your exit tax now, while you can still plan it. Book a call with me; the link is right below.
👉 Book a consultation with Harley
Carpe Diem. Life is short and fleeting. One shot. Make it count.