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the individual later returns to the country or holds the assets without selling for a certain number of years 2 non financial assets real estate jewelry etc are often excluded from the scope of exit tax 2 many countries prescribe a minimum number of residency years before an exit tax becomes applicable a minimum threshold on assets or net worth can be prescribed to minimize the required bureaucracy 2 some countries implement other anti avoidance rules besides deemed disposal extended trailing residency e g uk ireland reversal of burden of proof e g italy 3 portugal 4 etc a related but distinct concept is corporate exit tax triggered by relocating a company to another country both taxes may get triggered by the same relocation an emigrating business owner may move the company s tax residence with them due to place of effective management or controlled foreign company rules in the destination country in the eu this is mandated by anti tax avoidance directive atad in all member states 5 by country edit australia edit australia imposes an exit tax when an individual stops being a tax resident assets are deemed to have been sold at the market value on departure deemed disposal except for taxable australian property like real estate 6 conversely assets are deemed to have been acquired at the market value on the day of becoming a tax resident deemed acquisition or step up in cost basis 6 there is an exemption for temporary residents mainly people on temporary visas 6 the gain is taxed at ordinary income tax rates up to 45 plus medicare levy 7 50 cgt discount may apply in certain cases 8 tax can be deferred until the actual sale however the assets would get reclassified as taxable australian property until then 9 austria edit exit tax applies when austria loses the right to tax gains on capital assets whether due to the taxpayer moving abroad or any other circumstance 10 the event is treated as a deemed disposal of assets at fair market value standard cgt rate is 27 5 11 tax can be deferred indefinitely until the actual sale but only if moving within eu eea 12 there is no minimum threshold on assets or period of residence once tax residency is established losing it triggers the tax a person is generally regarded as a tax resident after a 6 months stay 13 belgium edit belgium introduced a comprehensive capital gains tax regime for individuals in 2026 along with a related exit tax 14 the changes apply retroactively from 1 january 2026 with a step up in cost basis only the gains accrued from that date are taxable standard cgt rate is 10 emigration is treated as a deemed disposal of assets however the tax can be deferred for 2 years until the actual sale and waived completely if the assets are not sold within 2 years or the taxpayer returns to belgium deferral is granted automatically if moving within eu eea else requires collateral 15 16 17 canada edit canada imposes a departure tax when an individual ceases to be a canadian tax resident most property is deemed to have been sold at fair market value on departure deemed disposition with gains subject to ordinary capital gains tax 18 19 main exceptions include taxable canadian property like real estate registered plans and property owned before becoming a canadian resident by short term residents less than 5 in the past 10 years 19 conversely most property is deemed to have been acquired at fair market value on the day of becoming a canadian resident so the taxable gain is generally based on the difference between the market value on the date of arrival in canada or later acquisition and the market value on the date of departure 19 as of 2026 top capital gains tax rate is 27 4 20 payment of departure tax can be deferred until the actual sale with collateral required above a certain threshold 19 tax residency is based on residential ties not just days of presence leaving canada without severing them wouldn t terminate tax residency leaving one liable to canadian taxes on worldwide income and gains treaty tie breakers can override this and make someone a deemed non resident triggering departure tax 18 denmark edit for shares exit tax fraflytterskat normally applies to portfolios from 100 000 kr approx us 10 000 and if the individual was fully liable to danish tax for at least 7 of the past 10 years full tax liability status matters for counting the years not just treaty tax residency status 21 shares are deemed to be disposed at the day of departure tax rate is 27 42 22 tax can be deferred henstandssaldo subject to annual compliance obligations and possibly collateral if moving outside the eu nordics 23 eritrea edit eritrea levies a yearly 2 recovery and rehabilitation tax on the worldwide income of its citizens living abroad 24 also commonly called diaspora tax it is thus one of the few countries along with the us that practices a citizenship based taxation the tax has been criticized by a number of governments for intimidation practices in its collection and alleged use in funding eritrea s war efforts 25 26 finland edit no general exit tax on unrealized gains for individuals there is an exception for deferred gains from certain tax neutral share exchanges 27 additionally finnish citizens are deemed to remain tax residents for 3 years after departure unless they prove that substantial ties with finland have ended 28 france edit according to the law l impôt sur les plus values latentes en cas de transfert du domicile fiscal hors de france article 167 bis code général des impôts 29 there is a rule forcing french tax subjects to pay a tax if they move abroad to certain countries and not return promptly france s exit tax applies to individuals who have been tax residents in france for at least 6 of the last 10 years before their departure and have ownership of more than 800 000 worth of shares or other financial instruments or are holding more than 50 of the shares in a company a deferral of payment is possible if the person relocates to an eu eea country or a country with a tax treaty with france that includes administrative assistance if the individual retains the assets for a certain period usually 15 years or returns to france to become a tax subject the tax may be canceled germany edit germany has a long history of taxing emigration the most famous example being the reich flight tax implemented in 1931 to stem capital flight during the unstable interwar period after seizing power in 1933 the nazi government largely used the tax to confiscate assets from persecuted people mostly jews who sought to flee nazi germany 30 contemporary legislation traces back to the scandal with helmut horten a department store magnate who moved to switzerland in 1968 sold his business stake and paid virtually no tax the event prompted enactment of the foreign tax act außensteuergesetz in 1972 whose exit tax provision 6 astg is nicknamed lex horten 31 32 as of 2026 exit taxation wegzugsbesteuerung is triggered for certain assets when an individual loses unlimited german tax liability after being subject to it for at least 7 of the past 12 years 33 gifting or inheritance to a non resident or another event by which germany loses the right to tax the gains may trigger the tax as well 33 the law has historically targeted substantial ownership in corporations at least 1 share since 2002 34 from 2025 the scope was extended to investment funds such as mutual funds and etfs with acquisition costs of at least 500 000 in a single fund or at least 1 share within the past 5 years 35 36 37 and special investment funds with no minimum threshold 38 affected assets are deemed disposed at fair market value gain is taxed as partial income teileinkünfteverfahren with an effective tax rate of up to roughly 28 5 plus church tax if applicable 37 payment can be split into 7 equal interest free yearly installments if collateral is provided 33 german exit tax applies to ownership in any corporation from large publicly traded companies to smallest one person business entities unlisted shares are usually valued using standardized methods such as vereinfachtes ertragswertverfahren 13 75 average annual profit with a floor at the company s book value 39 40 this can assign a substantial value even to young or loss making firms producing a tax bill disconnected from any realistic sale price and payable in cash regardless if any shares are or can be sold it is criticized as one of the biggest mobility blockers in german tax law locking in entrepreneurs and discouraging start ups 41 42 43 additionally german law has a concept of extended limited tax liability it applies for up to 10 years to german citizens who were tax residents for at least 5 of the previous 10 years move to a low tax jurisdiction and retain substantial economic interests in germany 44 ireland edit no general exit tax on unrealized gains for individuals however ireland has a provision for taxing former residents an individual becomes ordinarily resident after 3 continuous years of tax residence and remains so for 3 years after leaving during these years depending on their domicile status ireland may continue to tax their worldwide income and gains or at least the portion that is remitted to ireland 45 46 investments in irish etfs and mutual funds as well as similar in all material respects to them offshore funds are subject to deemed disposal every 8 years gains are classified as case iv income automatically within the scope of irish tax and thus may get taxed during this 3 year ordinarily residence tail 47 iceland edit no general exit tax on unrealized gains for individuals however former residents remain fully tax liable for 3 years after departure unless they prove that they have become subject to taxation in another country 48 israel edit individuals are deemed to have sold their assets the day before ceasing their tax residence in israel standard cgt rate is 25 tax may be deferred until the actual sale 49 50 assets owned before becoming israeli resident may be exempt for 10 years 51 italy edit no general exit tax on unrealized capital gains for individuals there is an anti avoidance rule italian citizens moving to certain low tax jurisdictions are presumed to remain tax residents unless they prove otherwise tax residence may also continue through residential or close family ties in italy 3 52 japan edit exit tax applies to high net worth individuals holding over 100m approx us 900 000 in financial assets who resided in japan for more than 5 of the past 10 years 53 for foreign nationals time on table 1 visa status doesn t count towards these 5 years 54 the tax was introduced in 2015 tax reform and began applying to foreigners with a table 2 status permanent residents spouse child of a japanese from 2020 55 assets are deemed disposed at departure cgt rate is 20 315 15 315 national 5 local tax 56 tax can be deferred for 5 10 years if the taxpayer appoints a tax agent and provides collateral and cancelled if the taxpayer returns to japan within the deferral period 53 netherlands edit the netherlands has treaties with belgium and portugal permitting them to charge emigration tax against dutch people who move to those countries the aim is to impose a tax on persons who move abroad and cash out on the tax free appreciation of their dutch pensions however in 2009 the supreme court of the netherlands ruled that the tax and customs administration could not impose an emigration tax on a dutch man who moved to france in 2001 57 luxembourg edit no general exit tax on unrealized gains for individuals capital gains from shares are tax free in general except for short term holdings and substantial over 10 shareholdings 58 former residents who lived in luxembourg for more than 15 years remain taxable for 5 years after departure on gains from selling substantial shareholdings in luxembourg companies 59 60 new zealand edit individuals subject to foreign investment fund fif rules generally shares in overseas companies funds above nz 50 000 are deemed to have sold their fif assets when losing tax residency 61 norway edit norway imposes an exit tax on unrealised capital gains when departing the country and ceasing to be tax resident which is also relevant when inheriting or receiving gifts from someone who was subject to exit tax the rules have changed often and significantly throughout 2022 2023 2024 and 2025 an english language summary of all the changes and the current rules can be found at the norwegian tax administration website 62 poland edit exit tax is triggered when an individual changes tax residence after being a polish tax resident for at least 5 of the past 10 years or by transferring assets especially business interests abroad in such a way that poland loses the right to tax their disposal there is an exemption for assets under 4 000 000 zł approx us 1 000 000 in total market value tax rate is generally 19 63 64 there is no step up in cost basis and no indefinite tax deferral whether moving to eu or not only a possibility to pay in installments over 5 years 65 portugal edit no general exit tax on unrealized capital gains however there are specific provisions for cryptocurrency assets 66 deferred capital gains from certain share reorganisations 67 and employee equity plans 68 there is also an anti avoidance rule portuguese nationals who relocate to low tax jurisdictions are deemed portuguese tax residents for 4 years after departure unless they prove they moved for a valid non tax reason 4 singapore edit singapore has no capital gains tax and thus no exit tax on unrealized capital gains 69 there is a deemed exercise rule concerning employee equity for the purposes of income tax foreign citizens with unexercised share options esop and unvested or restricted share awards esow granted while employed in singapore are deemed to realize the gains from them one month before they cease singapore employment 70 71 south africa edit the current south african exit tax regime works in concert with south africa s foreign exchange controls a person who is a resident of south africa as defined under the exchange control laws someone who is resident or domiciled in south africa may change status to become an emigrant if the person is leaving the common monetary area south africa namibia swaziland and lesotho to take up permanent residence in another country a single emigrant may expatriate up to r 4 million of assets without exit charge while a family is entitled to twice that amount the emigrant must declare all worldwide assets to an authorised dealer of the south african reserve bank and obtain a tax clearance certificate from the south african revenue service 72 south korea edit individuals who had a domicile or residence in south korea for at least 5 of the last 10 years before departure may be subject to exit tax on unrealized capital gains the rules were first introduced in 2018 for large shareholders of domestic companies from 2027 exit tax is expanded to cover foreign st...
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