Few phrases worry people moving abroad as much as "double taxation". The fear is understandable, but it is often aimed at the wrong target. Many believe that without a tax treaty they will automatically be taxed twice, and that with one they are automatically protected. Both views are too simple. This guide shows which of eleven home countries (the United States, Canada, the UK, Ireland, Australia, New Zealand, Sweden, Norway, Denmark, Finland and the Netherlands) actually have an income tax treaty or a social security agreement with the twelve Latin American countries we cover, what a treaty does, and what it does not do.
The short version: Mexico has a treaty with all eleven, Chile with ten, and Paraguay, Costa Rica and El Salvador with none. Whether that matters for you depends far less on the treaty than on two other questions, which I come to at the end.
What a tax treaty actually does First, the principle. An income tax treaty is an agreement between two states that decides which of them may tax which income , so that the same income is not fully taxed twice. Sometimes only the country of residence may tax, sometimes only the source country, sometimes both, with the residence country then giving relief.
The second job of a treaty is to settle dual residence . If both countries consider you resident under their own law, the treaty's tie-breaker article decides where you are resident for treaty purposes. Ireland's Revenue says this plainly: where you are resident in both countries, the treaty tie-breaker (Article 4) decides. The Finnish Tax Administration describes the order: permanent home first, then centre of vital interests. In Canada, a tie-breaker that assigns your residence to the other country makes you a deemed non-resident. In Norway, you can claim treaty residence in the other country with a certificate of residence.
The third job is to cap withholding on income paid across the border, such as pensions, dividends and interest. That is where most people notice a treaty in their wallet.
What a treaty does not do A treaty does not end your residence at home on its own. It only applies once two countries both have a claim, and it needs a genuine residence in the other country to work with. A treaty also cannot help where none exists, and as you will see, that is the normal case for several popular destinations.
Some rules apply regardless of the treaty:
United States: treaty saving clauses generally keep US tax on citizens. For an American, a treaty rarely changes the basic picture of worldwide taxation.Sweden: moving outside the EEA triggers taxation of a capital gain deferred on an earlier share-for-share exchange, and a treaty does not stop that .Finland: some treaties, including the one with Brazil, let the former residence state tax later share gains of an emigrant who had been resident there long enough (generally 5 years). Here the treaty preserves the home country's claim.Denmark: Skattestyrelsen notes that Denmark may keep the taxing right on pensions where it gave the deduction for contributions.And a tax information exchange agreement is not a tax treaty. Many of the countries below have exchange agreements with Uruguay, Costa Rica or Panama, for example, but these only let tax offices share information. They do not allocate taxing rights or reduce withholding.
The treaty map: who has a treaty with whom Here is the picture for comprehensive income tax treaties in force, as published by each home country's own authorities:
Destination Income tax treaty in force with Social security agreement in force with Mexico All 11 Canada Chile US, Canada, UK, Ireland, Australia, New Zealand, Sweden, Norway, Denmark, Netherlands US, Canada, UK (contributions only), Australia, Sweden, Norway, Denmark, Finland, Netherlands Argentina Canada, UK, Australia, Sweden, Norway, Denmark, Finland, Netherlands Netherlands Brazil Canada, Sweden, Norway, Denmark, Finland, Netherlands US, Canada Panama UK, Ireland, Netherlands Netherlands (benefit export treaty) Uruguay UK, Finland US, Canada, Netherlands Colombia Canada, UK None Ecuador Canada, UK Netherlands (benefit export treaty) Peru Canada, UK Canada Paraguay None Netherlands (benefit export treaty) Costa Rica None None El Salvador None None
A few details matter:
United States: only two comprehensive treaties in the region, with Mexico (in force since 1993) and Chile (in force since 2023, effective from 2024). The other ten destinations are absent from the IRS treaty list .Canada: seven treaties (Mexico, Colombia, Brazil, Argentina, Chile, Ecuador, Peru). The Department of Finance also lists Brazil as under re-negotiation.United Kingdom: eight treaties in force, the most of the eleven (see the HMRC treaty collection ). The Peru treaty is new : effective in the UK from 6 April 2026 and in Peru from 1 January 2027. The Brazil treaty was signed in 2022 but is not yet in force.Ireland: Panama, Mexico and Chile. Revenue says negotiations for a treaty with Uruguay have concluded, but nothing is signed.Netherlands: five treaties; the Colombia treaty is signed but has no in-force date.Sweden: the 1966 treaty with Peru was terminated and ceased to apply at the end of 2006. For Paraguay, Colombia, Ecuador and El Salvador no treaty was found, but Skatteverket's official list could not be fetched, so treat that status as provisional.Norway: the Brazil treaty in force since 2024 replaces the 1980 convention.Your home country
Tax treaties and social security agreements
Moving does not by itself end your obligations at home. Pick your country below: each answer is checked against the law and the tax or pension authority of that country.
Tax treaty with Paraguay Uruguay Costa Rica Panama Mexico Colombia Brazil Argentina Chile Ecuador Peru El Salvador United States No No No No Yes No No No Yes No No No Canada No No No No Yes Yes Yes Yes Yes Yes Yes No United Kingdom No Yes No Yes Yes Yes Signed Yes Yes Yes Yes No Ireland No No No Yes Yes No No No Yes No No No Australia No No No No Yes No No Yes Yes No No No New Zealand No No No No Yes No No No Yes No No No Sweden No No No No Yes No Yes Yes Yes No No No Norway No No No No Yes No Yes Yes Yes No No No Denmark No No No No Yes No Yes Yes Yes No No No Finland No Yes No No Yes No Yes Yes No No No No Netherlands No No No Yes Yes Signed Yes Yes Yes No No No
Comprehensive income tax treaties only (information exchange agreements do not count). Yes: in force. Signed: signed, not yet in force.
United StatesExpatriation tax when renouncing (covered expatriates) › Exit or departure tax
Sections 877 and 877A impose an expatriation tax on citizens who renounce and on long-term residents (green card holders in at least 8 of the last 15 years) who end residence; moving abroad alone does not trigger it. A covered expatriate (average annual net income tax above $211,000 for 2026, net worth of $2 million or more, or no 5-year compliance certification on Form 8854) is taxed as if all property were sold the day before expatriation, with gain reduced by $910,000 for 2026 ($890,000 for 2025). IRAs and similar accounts are treated as fully distributed, eligible deferred compensation is subject to 30 percent withholding, and 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.
Sources: IRS: Expatriation tax · 26 U.S.C. 877, Expatriation to avoid tax (govinfo) · IRS Revenue Procedure 2025-32 (2026 inflation adjustments) · IRS 2025 Instructions for Form 8854, Initial and Annual Expatriation Statement · 26 U.S.C. 877A, Tax responsibilities of expatriation (govinfo)
Private and occupational pensions
US pensions and annuities paid to a US citizen abroad remain taxable in the US, and a citizen or resident cannot opt out of federal withholding on payments delivered outside the United States (section 3405(e)(13)); for lump sums delivered abroad the rate cannot be set below 10 percent. Nonresident aliens owe 30 percent on US-source annuities under section 871(a), withheld on the gross amount, unless a treaty reduces it; Publication 515 notes most treaties exempt non-government pensions but not always lump sums. A covered expatriate is treated as receiving IRAs in full the day before expatriation and suffers 30 percent withholding on eligible deferred compensation.
CanadaDeparture tax: deemed sale of most property › When your tax residence ends
Canada taxes residents on worldwide income (section 2(1) of the Income Tax Act); no particular length of stay abroad by itself makes you non-resident. The CRA treats you as non-resident from the latest of your departure, your spouse's or dependants' departure and your becoming resident abroad, provided you sever your significant residential ties (home, spouse or partner, dependants) and most secondary ties such as provincial health cover, a driver's licence and bank accounts. Someone who is not factually resident but stays 183 days or more in a calendar year is deemed resident for that whole year (paragraph 250(1)(a)), and a treaty tie-breaker that assigns residence to the other country makes you a deemed non-resident under subsection 250(5).
Sources: Income Tax Act, section 2 (Justice Laws, current to 2026-09-30) · CRA, Leaving Canada (emigrants) (page date 2026-09-17) · CRA Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status · Income Tax Act, section 250 (Justice Laws)
Exit or departure tax
Section 128.1(4) of the Income Tax Act deems you to sell most property at fair market value immediately before you leave (departure tax), with the gain reported on Form T1243. Excluded are Canadian real estate, business property of a Canadian permanent establishment, registered plans and pensions (RRSP, RRIF, TFSA, pension plans), and, for people resident in Canada 60 months or less in the previous 10 years, property brought in or inherited. If your property is worth more than CAD 25,000 you must file Form T1161 even without a return. You can defer payment interest-free until actual sale by electing on Form T1244 (subsection 220(4.5)) by April 30 of the following year, with security required above CAD 16,500 of federal tax.
Sources: CRA, Leaving Canada (emigrants) (page date 2026-09-17) · Income Tax Act, section 128.1 (Justice Laws, current to 2026-09-30) · CRA, Dispositions of property for emigrants of Canada · Income Tax Act, section 220 (Justice Laws)
State pension paid abroad
CPP is payable abroad after at least one valid contribution and rises each January with the Consumer Price Index. OAS is payable abroad only after 20 years of residence in Canada after age 18 (or 20 years combined with a social security agreement country); otherwise it can stop after six months abroad, and GIS and the Allowances stop after six months. OAS rises each January, April, July and October. Both are subject to 25% non-resident tax unless a treaty reduces it: Service Canada lists 15% for Argentina, Colombia, Ecuador (first CAD 12,000 of Canadian pensions exempt with Form NR5), Mexico and Peru, 25% or 0% for Brazil (0% only for Brazilian nationals resident there), and 25% for all countries not listed, which includes Chile, Uruguay, Paraguay, Costa Rica, Panama and El Salvador. Non-resident OAS recipients must file the OAS Return of Income for the recovery tax unless a treaty limits it.
Sources: CRA, Non-residents of Canada · Income Tax Act, section 212 (Justice Laws) · Service Canada, Taxes: Foreign and Canadian pensions and benefits (non-resident tax rates by country) · CRA, Pensions and similar payments (Part XIII special payments) · CRA, Electing under section 217 · CRA, IC76-12 Applicable rate of Part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention
Private and occupational pensions
Pension benefits, RRSP and RRIF payments and retiring allowances paid to a non-resident bear 25% Part XIII withholding under subsection 212(1) of the Income Tax Act, which is usually the final Canadian tax, unless a treaty reduces the rate. A treaty reduction or exemption is claimed on Form NR5 (filed every five years) and applies only after written CRA authorization; alternatively a section 217 election lets the non-resident file a return and pay tax at resident rates. RRSPs, RRIFs, TFSAs and pension rights are not subject to the departure deemed disposition, and a TFSA can be kept but not contributed to while non-resident.
Public health cover
Public health insurance is provincial: each province decides who is an eligible resident and how many days a year must be spent there, and most provincial plans give little or no cover for care outside Canada. In Ontario, for example, cancelling the health card on a move out of the province keeps OHIP for the allowable period, generally 90 days, and the extended two-year absence rules apply only to temporary absences. On a later return, re-registration can involve a wait of up to three months. Keeping provincial health cover also counts as a secondary residential tie for tax residence.
Sources: Health Canada, How publicly funded health care coverage works · Global Affairs Canada (travel.gc.ca), Retiring outside Canada · Government of Ontario, Replace, cancel or change information on your health card · Government of Ontario, OHIP coverage while outside Canada · CRA Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status
Quebec
Revenu Québec applies its own residence test: while you stay outside Quebec and Canada you generally remain a Quebec resident, but if you move out of Canada and sever all residential ties with Quebec you will likely cease to be one, judged on your residential ties, the regularity and length of your visits to Quebec and whether a return is foreseen (interpretation bulletin IMP. 22-3/R2). Quebec income tax is due from individuals resident in Quebec on the last day of the year (Taxation Act, s. 22), and for someone who ceases to reside in Canada that day is the last day of residence in Canada (s. 23). In the departure year you pay Quebec tax on worldwide income for the period of residence in Canada, and for the rest of the year as a non-resident of Canada. Someone ordinarily resident outside Canada who sojourns in Quebec 183 days or more in a year is deemed to have resided in Quebec for the whole year (s. 8). Quebec has its own deemed disposition: under section 785.2 of the Taxation Act an emigrant is deemed to dispose of each property at fair market value immediately before leaving Canada, except Canadian real estate, capital property of a business carried on through a Canadian establishment, excluded rights such as RRSPs, RRIFs, TFSAs and pension plans (s. 785.0.1) and, for someone resident in Canada 60 months or less in the previous 120, property owned on arrival or inherited; the gain is computed on form TP-1033.2.A. If reportable property is worth more than CAD 25,000 in total, form TP-785.2.5 listing it must be filed by the filing due date even without a return, on pain of CAD 25 per day up to CAD 2,500 (s. 785.2.5). Payment of the Quebec tax can be deferred by electing on form TP-1033.2 (s. 1033.2), sent with the return by April 30 of the year after emigration; while accepted security covers the tax, interest and penalties are computed as if it had been paid. Security is required when that tax exceeds CAD 12,875 (form TP-1033.2, version 2021-03): an irrevocable bank letter of guarantee, a conventional immovable hypothec on Quebec property or certificated shares of Canadian private corporations. For the federal deferral, former Quebec residents must give security above CAD 13,777.50 of federal tax.
Sources: Revenu Québec, Vous avez quitté le Québec (live page) · Revenu Québec, Leaving Québec (live page) · LégisQuébec, Loi sur les impôts (chapitre I-3), à jour au 12 août 2026 (Internet Archive snapshot 2026-10-21 of the official text; live LégisQuébec returned HTTP 502/403) · LégisQuébec, Règlement sur l'admissibilité et l'inscription des personnes auprès de la Régie de l'assurance maladie du Québec (chapitre A-29, r. 1), à jour au 1er décembre 2025 (Internet Archive snapshot 2026-04-11 of the official text; live LégisQuébec returned HTTP 502/403) · RAMQ, Déménagement hors Québec (live page) · RAMQ, Moving outside Québec (live page)
United KingdomNo exit tax; inheritance tax tail of 3 to 10 years › When your tax residence ends
UK tax residence is decided tax year by tax year (6 April to 5 April) under the Statutory Residence Test in Schedule 45 to the Finance Act 2013. A leaver who was UK resident in any of the previous 3 tax years is automatically non-resident with fewer than 16 UK days, or with fewer than 91 days while working full-time abroad; otherwise the sufficient ties test applies, where the more UK ties (family, accommodation, work, 90-day, country) a person keeps, the fewer days they can spend in the UK. Split year treatment (Cases 1 to 3) can make a person non-resident from the day after departure, for example when they cease to have any UK home and set up a sufficient link abroad within 6 months. Under the temporary non-residence rules, someone who returns within 5 years or less (and had sole UK residence in 4 of the 7 years before leaving) can be taxed on return on certain gains, pension lump sums and company distributions received while abroad.
Sources: HMRC, RDR3: Statutory Residence Test (SRT) notes · HMRC, RDR3 Statutory Residence Test (landing page) · Finance Act 2013, Schedule 45 (legislation.gov.uk, revised) · GOV.UK, Tax if you leave the UK to live abroad
Exit or departure tax
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 gains made while temporarily non-resident can be taxed if the person returns within 5 years. For Inheritance Tax, since 6 April 2025 a person who was UK resident for at least 10 of the previous 20 tax years is a long-term UK resident under section 6A of the Inheritance Tax Act 1984, so worldwide assets stay within UK Inheritance Tax for a tail of 3 to 10 consecutive non-resident years, depending on how many of the last 20 years they were resident.
Sources: GOV.UK, Tax on your UK income if you live abroad (printable guide) · GOV.UK, Tax if you leave the UK to live abroad · Inheritance Tax Act 1984, section 6A (legislation.gov.uk, revised) · Inheritance Tax Act 1984, section 6 (legislation.gov.uk, revised)
State pension paid abroad
The UK State Pension is paid worldwide, including to residents of all 12 destinations, into a local or UK bank account. It is uprated each year only in the EEA, Switzerland, Gibraltar and listed social security agreement countries; none of the 12 destinations is on that list (the UK-Chile convention covers contributions only), so the pension stays at the rate first paid abroad and rises to the current rate only if the pensioner returns to live in the UK. It is taxable but paid without tax deducted, and HMRC says non-residents do not usually pay UK tax on it; a treaty exempts it from UK tax only if its pensions or other income article covers it.
Sources: DWP, Countries where we pay an annual increase in the State Pension · GOV.UK, State Pension if you retire abroad (printable guide) · GOV.UK, Tax on your UK income if you live abroad (printable guide) · HMRC, Form DT-Individual and notes (PDF) · HMRC, Double Taxation: Treaty Relief (Form DT-Individual) · GOV.UK, Tax codes (printable guide)
Private and occupational pensions
UK occupational and personal pensions paid to a non-resident are taxable in the UK under PAYE unless treaty relief applies; most UK treaties let them be paid without UK tax to a resident of the other country, claimed on form DT-Individual (relief at source, then an NT 'no tax' code, or a repayment). UK government service pensions are usually taxed only in the UK. Without an in-force treaty (Paraguay, Costa Rica, El Salvador, and Brazil until its 2022 treaty enters into force) UK tax stays, with the Personal Allowance available to British citizens on a yearly R43 claim. Pension lump sums received during temporary non-residence of 5 years or less can be taxed on return.
Public health cover
The NHS is residence-based, so a permanent move abroad ends automatic entitlement to NHS treatment under normal rules, and the leaver should ask the GP practice to remove them from the register. The S1 scheme that funds healthcare abroad for UK State Pension recipients applies only in the EU, Iceland, Liechtenstein, Norway and Switzerland, so it does not cover the 12 Latin American destinations.
Sources: NHS website, Planning your healthcare when living abroad
IrelandNo exit tax; 5-year rule on large shareholdings › When your tax residence ends
Under section 819 of the Taxes Consolidation Act 1997 an individual is resident in Ireland for a tax year with 183 days of presence in that year, or 280 days across that year and the previous one; a year with 30 days or less never makes you resident and those days do not count toward the 280. After three consecutive resident years you become ordinarily resident (section 820), and that status continues for three consecutive tax years after you leave: during that tail Irish tax still applies to worldwide income (except foreign employment or trade income and other foreign income of EUR 3,810 or less) and to worldwide gains, subject to any double taxation agreement. Domicile is a separate general-law concept and changes only with clear evidence of a permanent move; an Irish-domiciled person with worldwide income over EUR 1m and Irish property over EUR 5m may owe the domicile levy of EUR 200,000 a year. Where you are resident in both countries, the treaty tie-breaker (Article 4) decides.
Sources: Revenue: How to know if you are resident for tax purposes · Revenue Tax and Duty Manual Part 34-00-01 · Revenue: How to know if you are ordinarily resident for tax purposes · Revenue: What is domicile and the domicile levy? · Revenue: Tax and tax credits for non-residents
Private and occupational pensions
A private-sector occupational pension paid to a non-resident is taxed only in the country of residence when that country has a double taxation agreement with Ireland, and a PAYE Exclusion Order can stop Irish deduction; in a country without a DTA it stays taxed in Ireland. Of the 12 destinations, the treaties with Mexico and Panama give the residence country sole taxing rights over private pensions, while the Chile treaty lets the source state tax pensions at up to 10% of the gross amount. Public-sector pensions are generally taxed in Ireland, and withdrawals from ARFs and vested PRSAs, and a fund balance taken as a taxable lump sum, are taxed at source regardless of residence with no PAYE Exclusion Order.
Public health cover
Eligibility for an Irish medical card is tied to living in Ireland: the HSE says anyone who lives in the Republic of Ireland and plans to live there for at least one year can apply. The HSE pages consulted do not set out what happens to an existing medical card or to public hospital entitlement after emigration.
Sources: HSE: What the medical card covers
AustraliaCGT event I1 on departure, deferral by choice › When your tax residence ends
Under section 6(1) of the Income Tax Assessment Act 1936 an individual is an Australian resident if they reside in Australia, or if one of three extensions applies: an Australian domicile (unless the Commissioner is satisfied their permanent place of abode is outside Australia), presence in Australia for more than half the income year (unless their usual place of abode is outside Australia and they do not intend to take up residence), or membership of the Commonwealth superannuation schemes under the Superannuation Act 1990 or 1976 (which also covers a spouse and children under 16). Residence therefore ends only when none of these tests is met; for someone who keeps an Australian domicile, this means establishing a permanent place of abode abroad. The definition contains no day count that ends residence and no extended liability for nationals who leave. A foreign resident is taxed only on Australian-source income (section 6-5 of the Income Tax Assessment Act 1997), at non-resident rates with no tax-free threshold.
Sources: Income Tax Assessment Act 1936, Compilation No. 193 (1 October 2026), Volume 1, s 6(1) · Income Tax Assessment Act 1997, Compilation No. 268 (1 October 2026), Volume 1, s 6-5 · Income Tax Rates Act 1986, Compilation No. 66 (1 July 2026)
Exit or departure tax
Australia has a departure CGT rule: CGT event I1 (section 104-160 of the Income Tax Assessment Act 1997) happens when an individual stops being an Australian resident, and a capital gain or loss is worked out on each CGT asset owned just before then by comparing its market value with its cost base. Taxable Australian property (for example Australian real estate) and assets acquired before 20 September 1985 are excluded. Under section 104-165 an individual can instead 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 they are disposed of or the person becomes resident again. The choice must be made by the day the income tax return for the departure year is lodged (section 103-25).
Sources: Income Tax Assessment Act 1997, Compilation No. 268 (1 October 2026), Volume 3, ss 103-25, 104-160, 104-165
State pension paid abroad
The Age Pension requires pension age and, in general, 10 years of qualifying Australian residence, and the Social Security Act 1991 gives it an unlimited portability period, so it can continue to be paid to a resident of any of the 12 countries. After more than 26 weeks of continuous absence the rate is the domestic rate multiplied by a residence factor: 1 (full rate) with 35 years (420 months) or more of Australian working life residence between age 16 and pension age, and proportionally less below that. A pension granted within 2 years of returning to Australia is not payable abroad if the person leaves again within those 2 years. Where a social security agreement applies it overrides these portability rules; the only one in force with a portfolio country is Chile (in force 1 October 2009), which counts Chilean insurance periods toward Australian minimum qualifying periods, while the agreement with Uruguay is signed but not yet in force. How Australia taxes an Age Pension paid to a non-resident, and the treaty rules for such pensions, could not be verified at a primary source.
Sources: Social Security Act 1991, Compilation No. 234 (20 September 2026), Volume 1, s 43 · Social Security Act 1991, Compilation No. 234 (20 September 2026), Volume 4, Part 4.2 (ss 1211 to 1221) · Social Security (International Agreements) Act 1999, Compilation No. 56 (9 September 2026), Volume 1 (ss 1 to 25, Schedules 2 to 15) · Superannuation Industry (Supervision) Regulations 1994, Compilation No. 159 (1 July 2026), Volume 2, Schedule 1 · Superannuation Industry (Supervision) Regulations 1994, Compilation No. 159 (1 July 2026), Volume 1 · Income Tax Assessment Act 1997, Compilation No. 268 (1 October 2026), Volume 6, ss 301-170, 301-175
Private and occupational pensions
Superannuation of Australian citizens and permanent residents stays preserved after departure until a condition of release is met, for example retirement after preservation age (60 for anyone born after 30 June 1964) or reaching age 65; leaving Australia is not itself a condition of release for them. The departing Australia superannuation payment (DASP) applies only to former temporary visa holders who have left Australia and whose visa has ceased, and the release rules expressly exclude Australian citizens, New Zealand citizens and permanent residents. DASP is taxed at nil on the tax-free component, 35% on the taxed element and 45% on the untaxed element (65% on amounts from contributions made as a working holiday maker). For other investment income paid to non-residents, domestic withholding tax is 30% on unfranked dividends (franked dividends are exempt), 10% on interest and 30% on royalties, before any treaty reduction. The withholding or tax treatment of superannuation income streams and lump sums paid to non-resident citizens, and the reduced treaty rates, could not be verified at a primary source.
Public health cover
Medicare eligibility under the Health Insurance Act 1973 depends on being an 'Australian resident', defined as a person who resides in Australia and is a citizen, a permanent visa holder or in another listed category. Medicare benefits are paid for professional services rendered in Australia. A person who stops residing in Australia therefore falls outside the statutory definition and has no Medicare cover abroad; Services Australia's procedural guidance on leaving could not be retrieved.
Sources: Health Insurance Act 1973, Compilation No. 136 (19 September 2026), Volume 1, ss 3 and 10
New ZealandNo general exit tax; FIF interests deemed sold › When your tax residence ends
Under section YD 1 of the Income Tax Act 2007, a New Zealand tax resident becomes non-resident only if they have no permanent place of abode in New Zealand and are absent for more than 325 days in any 12-month period; non-residence is then backdated to the first of those days. The permanent place of abode test overrides the day counts, so keeping a home you habitually return to (owned or not, even if rented out) keeps you resident, and Inland Revenue also weighs family, economic ties and any intention to return. People working abroad for the New Zealand government stay resident. Where a treaty applies, its tie-breaker tests allocate residence for treaty purposes.
Sources: Inland Revenue: Tax residency status for individuals · Inland Revenue: Interpretation statement IS 25/16 Tax residence (16 May 2025) · Inland Revenue: Leaving New Zealand
Exit or departure tax
Inland Revenue lists specific tax consequences of becoming non-resident rather than a general exit charge on all assets. Interests taxed under the foreign investment fund (FIF) rules are treated as sold at market value immediately before the change, for the purpose of calculating FIF income. Parties to financial arrangements may need a final base price adjustment, and a trust whose resident settlor leaves may become a non-complying trust. New Zealand residential property remains subject to the bright-line test (2 years for sales on or after 1 July 2024).
Sources: Inland Revenue: Leaving New Zealand · Inland Revenue: Tax for non-resident taxpayers
Private and occupational pensions
KiwiSaver members moving permanently to Australia may transfer to an Australian superannuation scheme; members living in any other country can withdraw most of their savings (not government contributions) after 1 year overseas, or ask their provider to transfer to an approved foreign superannuation scheme. Interest, dividends and royalties paid to non-residents bear non-resident withholding tax: without a treaty 15% on interest and royalties and 30% on dividends, with a 2% approved issuer levy available instead of NRWT on certain debt; under the treaties Chile is listed at 10% interest and 15% dividends, Mexico at 10% interest and 0, 5 or 15% dividends. Non-resident investors in portfolio investment entities move to a 28% prescribed investor rate. The New Zealand tax treatment of occupational superannuation pensions and lump sums paid to non-residents was not verified at a primary source.
Public health cover
New Zealand citizens remain eligible for publicly funded health and disability services after moving abroad: Health New Zealand states that time spent overseas does not affect a citizen's eligibility. A citizen who is only in New Zealand temporarily may not be able to enrol with a primary health organisation (general practice). ACC cover for accidents overseas is available only to New Zealand residents and only in limited situations.
Sources: Health New Zealand: Publicly funded healthcare (eligibility)
Sweden10-year rule on gains from shares › When your tax residence ends
Under chapter 3, section 3 of the Income Tax Act (inkomstskattelagen), you stay fully taxable on worldwide income while you are resident, habitually stay in Sweden, or keep an essential connection (väsentlig anknytning) after moving. For five years after departure, Swedish citizens and anyone who lived in Sweden for at least ten years are presumed to keep that connection unless they prove otherwise (chapter 3, section 7); the factors include a year-round home, family, business activity and significant business holdings in Sweden. After five years the burden shifts to Skatteverket, but close ties can still keep you taxable. Deregistering from the population register does not by itself end tax liability, and residence under a tax treaty decides which country taxes which income.
Sources: Inkomstskattelag (1999:1229), as amended up to SFS 2026:1393 (Sveriges riksdag) · Skatteverket: Har du flyttat från Sverige? · Skatteverket (English): Moving from Sweden
State pension paid abroad
Pensionsmyndigheten pays the income pension, premium pension and supplementary pension wherever you live, including in Latin America, to a Swedish or foreign account, against an annual life certificate. The guarantee pension (garantipension) is residence-based and stops when you move from Sweden for more than a year (Canada is the only exception); the income pension supplement is paid only in the EU/EEA, Switzerland or a social security agreement country, which among the 12 destinations means Chile only. Non-residents with limited tax liability pay SINK, a final withholding tax of 22.5 percent in 2026 and 20 percent from 1 January 2027, with a monthly tax-free amount (SEK 3,799 in 2026) on public pensions; Pensionsmyndigheten withholds 22.5 or 0 percent depending on the treaty. Treaties differ: the Chile treaty lets Sweden tax pensions, the Argentina treaty lets both states tax pensions and social security payments, and the Brazil treaty taxes pensions up to USD 4,000 a year only in the country of residence.
Sources: Pensionsmyndigheten: Du som är bosatt utanför Sverige · Pensionsmyndigheten: Planera att flytta från Sverige · Pensionsmyndigheten (news): Garantipension upphör för utlandsbosatta · Socialförsäkringsbalk (2010:110), as amended up to SFS 2026:1658 (Riksdagen open data) · Pensionsmyndigheten: Utbetalning av din pension till annat land · Lag (1991:586) om särskild inkomstskatt för utomlands bosatta (Sveriges riksdag)
Private and occupational pensions
Occupational pensions (tjänstepension) for work mainly performed in Sweden and pensions from private pension insurance issued by a Swedish insurer are taxable under SINK at the same flat rate (sections 5 and 7 of the SINK Act, Lag 1991:586). Income exempted by a tax treaty is exempt from SINK, and a non-resident can instead ask to be taxed under the Income Tax Act for the year. Treaty pension articles (see statePension) also apply to these pensions.
NorwayExit tax on share gains above NOK 3 million › When your tax residence ends
Norway taxes residents on worldwide income and wealth (skatteloven § 2-1), and a person is resident after more than 183 days in any 12-month period or more than 270 days in any 36-month period. Moving abroad or deregistering in the Population Register does not end residence: someone resident for less than ten years stops being resident for the income year in which they show permanent residence abroad, no more than 61 days in Norway and no dwelling at their own or their close relatives' disposal in Norway. Someone resident for ten years or more stays resident until the end of the third income year after the year of departure, and only if those conditions are met in each of the three years. Tax emigration is claimed in the Norwegian tax return; where a treaty applies, a person can instead claim treaty residence in the other country with a certificate of residence.
Sources: Lovdata, skatteloven kapittel 2 · Skatteetaten, Skattemessig emigrasjon - opphør av skatteplikten · Skatteetaten, Globalskatteplikt · Skatteetaten, Bosted etter skatteavtale · Skatteetaten, Begrenset skatteplikt - når du flytter fra Norge
Exit or departure tax
Under skatteloven § 10-70, an individual who ends Norwegian tax residence under § 2-1(3) or becomes treaty-resident elsewhere is taxed as if shares and similar assets (Norwegian and foreign shares, fund units, share savings accounts, options and other derivatives on such assets, capital insurance) were sold the day before. Only the part of the total net gain above NOK 3 million is taxed on emigration, and only value built up while resident in Norway counts; for moves outside the EEA, losses are not netted. Payment can be deferred for 12 years (annual instalments or one payment at the end with interest), normally against security, and deferral ends on sale, death (unless heirs take over), transfer, and partly on dividends. The tax lapses if the person becomes resident in Norway again within 12 years; these rules apply to emigrations from 20 March 2024.
Sources: Lovdata, skatteloven kapittel 10 (§ 10-70) · Skatteetaten, Utflyttingsskatt – exitskatt
State pension paid abroad
Nav pays Norwegian old-age pension abroad, including to a bank in the country of residence, but never as a lump sum. Outside the EEA and without a social security agreement (all destinations except Chile), the earned income pension is paid abroad, while the guarantee pension (and, for people born before 1963, the full pension) is kept only with at least 20 years of residence in Norway between ages 16 and 67 (folketrygdloven §§ 19-3 and 20-10); with Chile, which has a social security agreement, Nav says the pension can as a rule be taken along without reduction. Pensions in payment are uprated each year with the average of wage and price growth under § 20-18, which sets no residence condition. After tax emigration, Norway withholds 15 percent of gross pension (kildeskatt, skatteloven § 2-3(4)) with no allowance; treaties change this: under the Mexico treaty pensions, including state pensions, are taxable only in the state of residence, the Chile treaty caps Norwegian tax at 15 percent, and Skatteetaten states that for residents of Argentina and Brazil all pensions from Norway remain taxable in Norway.
Sources: Lovdata, skatteloven kapittel 2 · Skatteetaten, Kildeskatt på pensjoner og uføreytelser · Skatteetaten, Kildeskatt på pensjon - begrensninger etter skatteavtaler · Lovdata, Norges traktater, Norway-Mexico convention · Lovdata, Norges traktater, Norway-Chile convention · Lovdata, Norges traktater, Norway-Brazil convention 2022
Private and occupational pensions
The 15 percent withholding tax also covers public and private occupational pensions and other private pensions paid by a Norwegian payer when the recipient has pension capital or points in the National Insurance Scheme; private pensions are not subject to it if the recipient has no such pension capital. Treaty relief depends on the destination: Mexico gives the residence state sole taxing rights over pensions and annuities, Chile caps source tax at 15 percent, and the Argentina and Brazil treaties let both states tax, with the residence state relieving double taxation. Nav advises asking each private or occupational pension provider about its own export rules; the treatment of lump sums was not verified.
Public health cover
Compulsory membership of the National Insurance Scheme (folketrygden) ends when a stay abroad is intended to last, or lasts, more than 12 months (folketrygdloven § 2-14), and with it public health cover. A pensioner settling outside the EU/EEA must apply to Nav for voluntary membership to keep any cover; this requires at least 30 years' membership after age 16, including 10 years immediately before applying (§ 2-8). Even with voluntary membership the right to a GP is lost, care abroad is only partly reimbursed by Helfo (claims within 6 months), and care in Norway remains covered. Non-members generally pay no National Insurance contribution.
Sources: Lovdata, folketrygdloven kapittel 2 (§§ 2-1, 2-8, 2-9, 2-14) · helsenorge.no (Helfo), Pensjonister utenfor EU/EØS · Nav, Alderspensjon (updated 20.10.2026) · Nav, Medlemskap i folketrygden · Skatteetaten, Medlemskap i folketrygden og trygdeavgift når du flytter til utlandet
DenmarkExit tax on shares from DKK 100,000 › When your tax residence ends
Under kildeskatteloven (Withholding Tax Act) section 1, a person is fully liable to Danish tax while they have a dwelling (bopæl) in Denmark, or if they stay in Denmark for 6 months or more without one. Full liability ends on departure only when the person no longer has a year-round home at their disposal: in practice the home must be sold, the lease ended, or the home let on a lease that cannot be terminated for at least 3 years; a holiday home used only for holidays does not count. Deregistering from the population register does not by itself end liability. There is no extended or trailing liability for nationals, but a later stay of 6 months or more makes the person fully liable again, and dual residence with a treaty country is settled by the treaty.
Sources: Retsinformation, Bekendtgørelse af kildeskatteloven, LBK nr. 460 af 3. maj 2024 (Withholding Tax Act, consolidated; status Valid at retrieval) · Skattestyrelsen, Den juridiske vejledning 2026-2, C.F.1.2.3 Hvornår ophører skattepligten ved fraflytning? · Skattestyrelsen (skat.dk), Du flytter fra Danmark · Skattestyrelsen, Den juridiske vejledning 2026-2, C.F.1.2.1 Hvornår er der bopæl i Danmark? · Skattestyrelsen, Den juridiske vejledning 2026-2, C.F.1.3 6-måneders ophold i Danmark
Exit or departure tax
Denmark has an exit tax: when liability ends for a reason other than death, assets leaving Danish taxation are treated as sold at market value (kildeskatteloven section 10). Shares are taxed under aktieavancebeskatningsloven section 38 if their total market value is DKK 100,000 or more per person and, as a rule, the person was liable to Danish tax for at least 7 of the last 10 years; claims and financial contracts follow the same DKK 100,000 threshold, and crypto-assets are deemed sold on the day of departure. Payment of the share tax can be deferred (henstand) for shares taxed on realisation, 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 (pensionsbeskatningsloven sections 19 A to 19 E).
Sources: Skattestyrelsen, Den juridiske vejledning 2026-2, C.F.1.6.4 Fraflytningsbeskatning ved skattepligtens ophør · Skattestyrelsen, Den juridiske vejledning 2026-2, C.B.2.14.2.6 Hvad skal personer beskattes af ved fraflytning? · Skattestyrelsen, Den juridiske vejledning 2026-2, C.B.2.14.2.3 Hvem er omfattet af reglerne om fraflytterskat i aktieavancebeskatningsloven? · Skattestyrelsen, Den juridiske vejledning 2026-2, C.B.2.14.2.5 Hvornår skal personer beskattes ved fraflytning? · Skattestyrelsen, Den juridiske vejledning 2026-2, C.B.2.14.2.8.1 Henstand med betaling af skatten · Skattestyrelsen, Den juridiske vejledning 2026-2, C.B.2.14.2.1 Kort om fraflytterskat på aktier
State pension paid abroad
Folkepension and other Danish social pensions paid to a non-resident are subject to Danish limited tax liability (kildeskatteloven section 2(1) no. 11) at an average rate; Argentina, Brazil, Chile and Mexico have treaties that may shift the taxing right (exemption is applied for on form 01.016), and for the other 8 destinations Denmark taxes. Under the Social Pension Act section 3, a Danish citizen can receive folkepension abroad after at least 30 years of residence in Denmark between age 15 and pension age, or keep an already awarded pension abroad after at least 10 years (or a quarter of the time from 15) of Danish residence; Udbetaling Danmark can grant a dispensation, which must be sought before leaving. Only the basic amount (grundbeløb) is paid outside the EU/EEA, Switzerland and the UK: the pension supplement (pensionstillæg) is not exported, personal and heating supplements must be applied for separately after the move, and the pension is reduced pro rata if Danish residence was below 9/10 of the period from 15 to pension age. Chile is the only destination with a social security convention: a Chilean national moving to Chile can take the pension after 3 years of residence and 1 year of work in Denmark.
Sources: Retsinformation, Bekendtgørelse af kildeskatteloven, LBK nr. 460 af 3. maj 2024 (Withholding Tax Act, consolidated; status Valid at retrieval) · Skattestyrelsen, Den juridiske vejledning 2026-2, C.F.3.1.11 Sociale ydelser mv. · Skattestyrelsen, Den juridiske vejledning 2026-2, C.F.3.1.10 Pensioner · Skattestyrelsen (skat.dk), Dansk pension, når du flytter til udlandet · Retsinformation, Bekendtgørelse af lov om social pension (pensionsloven), LBK nr. 1123 af 2024 (Social Pension Act, consolidated; status Valid at retrieval) · borger.dk (written by Udbetaling Danmark), Vil du have din folke-, førtids- eller seniorpension med til udlandet?
Private and occupational pensions
Occupational and private pensions paid to a non-resident are taxable in Denmark under kildeskatteloven section 2(1) nos. 9 and 10; where a treaty applies (Argentina, Brazil, Chile, Mexico) the treaty decides, and Skattestyrelsen notes that Denmark may keep the taxing right where it gave the deduction for contributions. With the other 8 destinations there is no treaty, so Denmark taxes the payments, and cashing in a kapitalpension, aldersforsikring, aldersopsparing or supplerende engangssum triggers the Danish duty on the full amount for which deduction was given. The tax on pension-fund returns (PAL tax) stops once the person is no longer fully liable or is resident abroad, on application with form 07.058.
Public health cover
Entitlement to Danish public health care follows a registered address in Denmark. A person who registers a move to a country outside the EU, Switzerland and the EEA (all 12 destinations) is no longer socially insured from Denmark and is not covered by the yellow health card (gule sundhedskort), even when visiting Denmark; borger.dk points to the public scheme or private insurance in the new country. A pensioner who stays outside the EU for under 6 months can as a rule keep a Danish address and the yellow card, depending on the housing situation.
Sources: borger.dk, Guide: Når du flytter til udlandet (Digitaliseringsstyrelsen with KL, ATP/Udbetaling Danmark and Skattestyrelsen; all answers view)
FinlandNarrow: deferred share-swap gains outside the EEA › When your tax residence ends
Under section 11 of the Income Tax Act (tuloverolaki 1535/1992), a person is resident in Finland if their main abode and home is there or they stay continuously for more than six months, and a resident is taxed on income from Finland and abroad. A Finnish citizen who moves abroad stays resident for the year of departure and the three following tax years unless they request non-residence and show that no substantial ties remain (for example a home, a spouse in Finland, real property other than a summer cottage, Finnish social security cover, or business or work in Finland). Ties broken at departure give non-residence from the moving day; ties broken later give non-residence from the next 1 January. After the three years, residence continues only where ties are clearly stronger than in the years after the move, and a non-resident becomes resident again only by moving home back or staying more than six months. Under a treaty, dual residence is settled first by permanent home, then by centre of vital interests.
Sources: Finlex, Tuloverolaki 1535/1992 (Income Tax Act, consolidated), 11 § · Finnish Tax Administration (vero.fi), Finnish citizens and the 3-year rule (page last updated 1/30/2026) · Finnish Tax Administration, detailed guidance: Tax residency, nonresidency and residency in accordance with a tax treaty, natural persons (issued 1/29/2025) · Finnish Tax Administration, detailed guidance: Taxation of income received by nonresidents, natural persons (issued 8/7/2026)
Exit or departure tax
The exit tax provision in the Income Tax Act is headed as applying to entities (yhteisön maastapoistumisverotus). For individuals, the Tax Administration describes one emigration charge under section 52 f of the Act on the taxation of business income: a gain deferred in a tax-neutral share swap becomes taxable in Finland if the person moves to a country outside the EEA (which includes all 12 destinations) within 5 years from the end of the tax year of the swap, even if the shares are kept, and a loss at departure is not deductible. Separately, some treaties, including the one with Brazil, let the former residence state tax later share gains of an emigrant who had been resident there long enough (generally 5 years).
Sources: Finnish Tax Administration, detailed guidance: Capital gains and losses from the sale of assets in cross-border situations, natural persons (issued 4/22/2025) · Finlex, Tuloverolaki 1535/1992 (Income Tax Act, consolidated), 11 §
State pension paid abroad
The Finnish earnings-related pension (statutory TyEL, YEL and similar schemes) is paid to any country regardless of nationality; residents of countries without a social security agreement claim it directly from Finland, confirm their details to the payer every year, and the pension is adjusted with the earnings-related pension index, which applies to all pensions in payment. Kela's national pension and guarantee pension are paid abroad only during a temporary stay: on a permanent move to a non-EU/EEA country without an agreement Kela stops payment from the start of the next month, while the Chile agreement keeps Kela old-age and survivors' pensions payable on conditions such as citizenship and length of residence. Pensions are not subject to Finnish tax at source: a non-resident's Finnish pensions are taxed under the Assessment Procedure Act much as if the person lived in Finland, using the national average municipal tax rate for a full non-resident year, and a treaty-based tax card is requested on Form 6207a. Finland keeps the right to tax these pensions under its treaties with Argentina, Brazil and Uruguay, Finnish tax is capped at 20 % under the Mexico treaty, and with the other eight destinations there is no treaty, so Finland taxes under its own law.
Sources: Työeläke.fi (Finnish Centre for Pensions), How will my pension be paid and taxed? · Työeläke.fi (Finnish Centre for Pensions), Earnings-related pension paid abroad from Finland · Kela, Pension from Finland to another country · Finnish Tax Administration, detailed guidance: Taxation of pension income in cross-border circumstances (issued 9/25/2026) · Finnish Tax Administration, detailed guidance: Taxation of income received by nonresidents, natural persons (issued 8/7/2026) · Finlex, Laki rajoitetusti verovelvollisen tulon verottamisesta 627/1978 (Act on the taxation of nonresidents' income, consolidated)
Private and occupational pensions
Pensions from voluntary individual pension insurance, long-term savings (PS) agreements and a Finnish insurer's voluntary contracts are Finnish-source income, as are private-sector pensions for work done mainly in Finland for a Finnish employer. Under section 13 of the Act on the taxation of nonresidents' income (627/1978) these are assessed under the Assessment Procedure Act rather than withheld at a flat source rate; without a pension tax card the payer withholds 40 %. Small earnings-related pensions are paid as a one-off lump sum. Annex 2 of the Tax Administration's pension guidance shows that Finland may tax voluntary pensions paid to residents of Argentina, Brazil and Uruguay, caps Finnish tax at 20 % for Mexico, and may tax all pension categories where there is no treaty.
NetherlandsConservatory assessment on pensions and 5%+ stakes › When your tax residence ends
Dutch tax residence has no day count: under article 4 of the General State Taxes Act (AWR) where you live is judged on all the circumstances, and the Belastingdienst treats you as emigrated when you settle permanently in another country, looking at where you spend most time, where your family lives, where you work and where you are insured for medical costs. If you return within one year without having lived in another state in the meantime, you are deemed to have stayed resident throughout (article 2.2 of the Income Tax Act 2001). A tax treaty tie-breaker can also end residence for treaty purposes. For inheritance and gift tax, a Dutch national is deemed resident for ten years after leaving, and anyone is deemed resident for gifts made within one year (article 3 of the Inheritance Tax Act 1956).
Sources: Algemene wet inzake rijksbelastingen, art. 4 · Wet inkomstenbelasting 2001, art. 2.1 · Belastingdienst: Emigreer ik als ik naar het buitenland verhuis? · Successiewet 1956, art. 3
Exit or departure tax
There is no general deemed disposal of all assets, but on emigration the Netherlands issues a conservatory assessment (conserverende aanslag) on pension rights, deducted annuity (lijfrente) premiums and a substantial interest (aanmerkelijk belang, generally 5% or more of a company), taxed at the highest rate (articles 2.8, 3.83, 3.136 and 4.16(1)(h) of the Income Tax Act 2001). 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 (articles 25(5) and 26(2) of the Collection of State Taxes Act 1990). For a substantial interest held by someone who deregistered after 15 September 2015 the deferral is lifelong with no remission, and selling the shares, paying dividends or the company ceasing makes it (partly) payable. Deferral is automatic only for moves within the EU/EEA; moving to a non-EU country means requesting deferral and in some cases (substantial interest, pensions not held by an EU/EEA/Swiss insurer) providing security.
Sources: Wet inkomstenbelasting 2001, art. 2.8 · Belastingdienst: Conserverende aanslag bij emigratie · Invorderingswet 1990, arts. 25 and 26
State pension paid abroad
The AOW state pension is paid abroad, but AOW insurance is residence-based, so each calendar year lived abroad before pension age cuts the pension by 2% unless you take voluntary insurance (possible if you left less than a year ago) (articles 6 and 13 of the Old Age Pensions Act). Under the AOW as amended by the Benefits Export Restriction Act, a pensioner living abroad receives only the married-person rate and no partner supplement, unless they live in a country where a treaty or international decision provides for the right (articles 8a and 9a). Of the 12 destinations, social security or benefit export treaties are in force with Argentina, Uruguay, Chile, Paraguay, Panama and Ecuador; agreements with Brazil and Costa Rica will not enter into force, and none exists with Mexico, Colombia, Peru or El Salvador. The amounts are derived from the Dutch net minimum wage, the AOW cannot be taken as a lump sum, and the SVB may ask for life certificates. Whether the Netherlands withholds tax on the AOW depends on the tax treaty; without a treaty the Netherlands may tax it (for Mexico the Belastingdienst summary notes a 17.5% cap on Dutch tax on AOW and similar benefits).
Sources: Algemene Ouderdomswet, arts. 6 and 13 · NederlandWereldwijd: Krijg ik AOW buiten Nederland? · Wet beperking export uitkeringen · SVB: Buiten Nederland wonen (AOW) · SVB: Uw AOW buiten Nederland · SVB: Betaling van de AOW buiten Nederland
Private and occupational pensions
Dutch occupational pensions and annuities paid to non-residents are Dutch-source income (article 7.2(2) of the Income Tax Act 2001), and the applicable tax treaty decides which country taxes them; without a treaty the Netherlands may tax. On emigration the accrued pension and deducted annuity premiums are covered by a conservatory assessment, and commuting the pension or annuity (a lump-sum buy-out) within the ten-year deferral makes that assessment payable. For a move outside the EU, security may be required where the pension scheme is not placed with a recognised insurer in the EU, Norway, Liechtenstein, Iceland or Switzerland.
Checked at official sources on 25 October 2026. Rules change and your own facts decide: we confirm your home-country position, together with our local partners, licensed attorneys in each country, before anything is filed.
The pension articles: where treaties bite For retirees, the pension article is the part of a treaty that matters most, and the answers differ sharply between pairs of countries. Some examples, as the authorities themselves describe them:
Norway and Mexico: pensions, including state pensions, are taxable only in the state of residence . Under the Chile treaty, Norwegian tax on pensions is capped at 15%.Ireland: the Mexico and Panama treaties give the residence country sole taxing rights over private pensions; the Chile treaty lets Ireland tax at up to 10% of the gross amount.Sweden: the Brazil treaty taxes pensions up to USD 4,000 a year only in the country of residence, the Argentina treaty lets both states tax, and the Chile treaty lets Sweden tax.Finland: Finnish tax on pensions is capped at 20% under the Mexico treaty, while the Argentina, Brazil and Uruguay treaties keep Finland's right to tax.Canada: Service Canada lists a 15% rate on CPP and OAS for Argentina, Colombia, Ecuador, Mexico and Peru, against 25% for Chile, Uruguay, Paraguay, Costa Rica, Panama and El Salvador. A treaty, in other words, does not always lower the rate.The full detail, including private pensions and the frozen or reduced state pensions, is in my guide to pension tax in Latin America .
Social security agreements: a separate track People often mix up tax treaties and social security agreements. A social security agreement does not decide who taxes your income. It decides which system you pay contributions into and whether periods in both countries can be combined for a pension. It can also keep benefits flowing abroad that would otherwise stop.
Chile stands out: it has an agreement with nine of the eleven home countries. With the UK, though, it is a contributions-only convention that gives no State Pension uprating. Canada has agreements with Uruguay, Mexico, Brazil, Chile and Peru, and has signed agreements with Argentina and Ecuador that are not yet in force. The Netherlands has full agreements with Argentina, Uruguay and Chile, and benefit export treaties with Paraguay, Panama and Ecuador; its agreements with Brazil and Costa Rica will not enter into force. Australia's only agreement in force with the twelve is with Chile, with Uruguay signed but not yet in force. Ireland and New Zealand have none with any of the twelve.
Territorial countries and the missing treaty This resolves the apparent paradox. Paraguay , Costa Rica , El Salvador and Panama tax individuals on a territorial basis, only on local-source income. If your new country does not tax your foreign income at all, there is little for a treaty to split. That is why the absence of a treaty with a territorial country is not automatically a warning sign .
But be careful with the conclusion. A missing treaty also means your home country's own rule applies in full to any income it still taxes. A UK private pension paid to someone in Paraguay, Costa Rica or El Salvador stays taxed in the UK. A Canadian pension paid to Panama or Uruguay bears the full 25%. With a worldwide-tax destination such as Mexico, Colombia, Brazil, Argentina or Peru, the treaty becomes much more important, because then both countries can have a claim. The comparison of systems is in my guide to territorial tax countries .
The question that really comes first Here is the shift in perspective. Most people first ask: does my destination have a tax treaty with my home country? The better first question is: am I still tax resident at home, yes or no? As long as you are, your home country taxes your worldwide income, and the treaty becomes a repair tool for a situation you actually wanted to end. Ending residence is its own topic, with day counts, ties and trailing rules that can last for years; I cover it in why moving abroad does not end tax residence . If you hold assets with large built-up gains, the second question is whether leaving triggers an exit tax .
Your part: first the exit, then the treaty A tax treaty is a set of rules about who taxes what, not a tax gift, and whether one exists is routinely overrated. No treaty does not automatically mean double tax , especially with a territorial destination, and a treaty does not end your residence at home . The real order is: a properly planned exit, a genuine new residence with substance, and only then the treaty as the fine-tuning for the income your home country still reaches. If you want to see how residence and substance hold together, read why substance beats a mailbox .
This is exactly the order I work through with my clients, so that the treaty question is answered by the structure, not by hope.
If you want to know whether your destination has a treaty with your home country, and whether it matters for your income, let us set it up together. Book a call with me; the link is right below.
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