Exit tax 2026: who pays it on leaving, country by country

An exit tax treats you as if you had sold certain assets on the day you leave, and it charges the gain built up while you were resident. The logic is the same everywhere, because a country that loses a resident also loses the right to tax a later sale. The details are not the same at all. Some countries only target shareholdings, and some cast the net wider. Canada's deemed sale has no wealth threshold in the page we read, while Spain starts at several million euros. Most of them allow you to wait: a deferral is often automatic within the EU or the EEA, conditional elsewhere, and in a few cases the tax falls away if you hold on or come back. So check three things before a move, not after: whether you meet the length-of-residence test, whether your assets reach the threshold, and which deferral your destination gives you. One deadline in France runs before you leave.

Exit tax by country at a glance

These are the conditions we read on each official source. A country that is absent is one whose text we did not read, which says nothing about its rule.

France: article 167 bis, and a difference of wording

Article 167 bis of the French tax code, in the version in force since 1 January 2024, targets taxpayers domiciled in France for at least six of the ten years before the move. Holdings must represent at least 50% of a company's profits, or have a total value that, in the words of the article, exceeds €800,000. impots.gouv.fr writes "at least" that amount: a small gap, but the statute is the reference. BOFiP places the gains under the 12.8% flat rate for transfers since 1 January 2018, with social levies on top.

The deferral is automatic for a move to an EU state or one with the required assistance agreements. For other destinations, you must ask, declare, appoint a representative in France and give guarantees, and impots.gouv.fr says the request goes in at least 90 days before the move, for transfers since 22 November 2019. If you still hold the securities, the tax is relieved after two years, or five when their value exceeds €2,570,000. Forms 2074-ETD and 2074-ETS follow. Our page on leaving France places this inside the rest of your departure, from the two returns of that year to your PEA.

United States: a tax on giving up status

The US rule does not look at moving at all, since the US taxes its citizens wherever they live. It bites when a citizen relinquishes citizenship, or when a long-term resident, meaning a green card holder in at least 8 of the last 15 tax years, gives up that status. You are then a covered expatriate if you meet any one of three tests. Your net worth is US$2,000,000 or more. Your average annual net income tax over the five prior years is above US$211,000 for 2026. Or you fail to certify on Form 8854 that you met all federal tax obligations for those five years.

A covered expatriate is treated as having sold worldwide assets at market value on the day before the expatriation date. The gain is reduced by an exclusion of US$910,000 for 2026. Deferred compensation such as a 401(k) is outside the deemed sale and has its own rules. The IRS gives two exceptions to the income and net worth tests, for some dual citizens from birth and some minors, but none to the certification test. Failing to file Form 8854 can therefore make you covered on its own, and there may be a US$10,000 penalty. Payment can be deferred with an irrevocable election, a bond or other security, a US agent and interest, and that means waiving any treaty right which would block collection.

Germany and Spain: stakes rather than wealth

Germany works from the share rule in section 17 of its income tax act, which applies from a stake of 1% held at any time in the last five years. Section 6 of the Foreign Tax Act treats those shares as sold when your unlimited tax liability ends, if you were subject to it for at least seven of the last twelve years. On request, you pay in seven equal yearly instalments, generally against security and with no interest. If you return within seven years of leaving, the claim lapses under listed conditions, and the tax office can extend that period by up to five years. Selling the shares brings the balance forward, and so do distributions above a quarter of the value.

Spain's threshold is far higher, and the Agencia Tributaria's manual sets out two alternatives: shares over €4,000,000 in total, or a holding of more than 25% with a value over €1,000,000, in which case only that company's shares count. For a move to an EU or EEA state with an effective exchange of information, there is a special regime with its own form, modelo 113. The older help text we read, for the 2018 tax year, says the gain is then only declared if within ten years you sell, leave the EU and EEA, or fail to report. Check the current version. For a temporary work move, or another move to a treaty country, payment can wait five periods, plus up to five more, and the debt and interest disappear if you become resident again without having sold.

Netherlands, Canada, Norway: wider nets

The Dutch protective assessment, the conserverende aanslag, is not just about shares. It also covers pension and annuity rights on which you had tax relief. You receive it after filing for the year of emigration, and the income falls into the top rate. Deferral is automatic for an EU or EEA country. An assessment usually lasts ten years, after which you can ask for remission if you have followed the rules, but the one on a substantial shareholding is unlimited. Buying out your pension makes the tax payable.

Canada calls it departure tax. You are considered to have sold certain property, with shares, jewellery, paintings and collections as its examples. Canadian real estate, resource property, and pension plans and RRSPs are out of scope. If the fair market value of all you own when you leave is over CA$25,000, you also file Form T1161. You report gains on Form T1243 and can defer the tax without interest using Form T1244, by 30 April of the following year; security is required when the federal tax owing is over CA$16,500.

Norway changed its rules on 20 March 2024. Since then, a basic deduction of NOK 3,000,000 applies, and for moves out of the EEA latent gains are added up with no loss offset. The page dates the rule that the tax must be paid within 12 years, unless you come back first, from 20 November 2024. It does not state a rate.

What your dates have to do with it

Each of these taxes hangs on one date, the day your residence ends, and that date is not always the one on your plane ticket. In France, if your household stays, you may still be domiciled there after you fly out. The counter above shows a departure from France on 30 June to Portugal: France gives no day verdict, whereas the other country may already count you. Being resident in two countries that year is common, and the tax treaty between them decides which one counts for treaty purposes. Keep a record of your days in both, with the Taxlag app or otherwise. Before a move with large holdings, this is one area where a licensed adviser earns their fee: valuation, forms and deadlines all turn on your exact facts.