Exit taxes by country: where leaving triggers a tax bill (2026)
See which countries tax unrealised gains or shareholdings when you leave in 2026, what triggers each charge, and who it actually hits.
Some countries send you a tax bill for gains you have not yet cashed in, simply because you are moving your tax residence abroad. This is the exit tax (also called departure tax or deemed-disposal tax): the country treats your assets as sold at market value on the day you leave and taxes the paper gain. Seven jurisdictions covered here run a version of it in 2026 — Germany, Norway, the Netherlands, France, Canada, Australia and the United States. Treat this guide as orientation, and confirm the detail for your situation with a qualified adviser before you move.
What an exit tax actually does
An exit tax charges the growth in value of your assets before you have sold anything. The mechanism is a “deemed disposal”: on your departure date the tax authority pretends you sold the asset at its current market value, calculates the gain against what you originally paid, and taxes that notional gain. Most countries aim the charge at company shares and investment portfolios. Real estate is usually left out, because a country can already tax local property whenever you actually sell it.
The practical effect is timing. A charge can land in the year you leave, on money you have not received. Many countries soften this with deferral: you agree the liability now and pay later, often only when you genuinely sell, and frequently interest-free if you move within the EU or EEA. The size of the bill, the deferral terms and the exemptions differ sharply from one country to the next.
Exit taxes by country (2026)
| Country | What triggers the charge | Who it is aimed at |
|---|---|---|
| Germany | Giving up German tax residence while holding at least 1% of a corporation (now, or at any point in the past 5 years) | Founders and GmbH/AG shareholders |
| Norway | Leaving with unrealised share gains above the NOK 3 million allowance | Investors and owners with sizeable share portfolios |
| Netherlands | Emigrating while holding a “substantial interest” of at least 5% in a company | Owner-managers and 5%-plus shareholders |
| France | Moving residence abroad with shares worth over €800,000 or above 50% of a company | Larger shareholders and founders |
| Canada | Becoming a non-resident, which deems most assets sold | Almost every emigrant with investments outside registered accounts |
| Australia | Ceasing Australian residency (CGT event I1) on assets that are not taxable Australian property | Residents holding foreign shares and other non-property investments |
| United States | Renouncing citizenship or ending long-term residence as a “covered expatriate” | High-net-worth citizens and long-term green-card holders |
Germany
Germany taxes departing shareholders under Section 6 of the Foreign Tax Act (§6 AStG). The charge applies when you have been subject to unlimited German tax liability and you hold at least 1% of a corporation as a private asset, counting holdings you owned at any point in the previous five years [1]. Your shares are treated as sold at market value, and the notional capital gain is taxed under normal German income tax rules [1]. From January 2025 comparable rules also reach units in investment funds [1].
Norway
Norway tightened its exit tax through 2024 and 2025, and the current rules bite from a NOK 3 million allowance in net latent gains, above which departing residents are treated as realising their share gains the day before they leave [2]. Share gains for individuals carry an effective rate of 37.84% in 2026 (the gain is multiplied by 1.72 and taxed at 22%) [3]. You can pay immediately, in instalments, or defer the whole liability for up to 12 years, after which it falls due even if the shares remain unsold [2].
Netherlands
The Netherlands issues a “protective assessment” (conserverende aanslag) when someone holding a substantial interest — at least 5% of a company’s shares — emigrates [4]. Your shares are treated as disposed of at market value on the emigration date, and the assessment records the tax on the gain [4]. In many cases you do not pay straight away: the liability is deferred and only collected when you actually sell or when the company distributes profits [4]. Box 2 rates in 2026 are around 24.5% on the first tranche of substantial-interest income and 31% above it — confirm the current bands with your adviser.
France
France applies its exit tax (Article 167 bis CGI) when you transfer your residence abroad holding shares worth more than €800,000, or shares representing over 50% of a company [5]. The gain is taxed at a flat 12.8% income tax plus 18.6% social surtaxes, with an option for progressive rates instead [5]. Moving to another EU or EEA state, or to a treaty country with mutual assistance on recovery, brings automatic deferral [5]. The charge is then cancelled after two years if the gain was below €2.57 million on departure, or five years above that, and on your return to France [5][6].
Canada
Canada runs a broad departure tax under Section 128.1 of the Income Tax Act: on the day you become a non-resident, most of your property is deemed sold at fair market value [7]. Canadian real property, RRSPs and RRIFs, and registered pension rights are excluded, while foreign shares, ETFs and other investments are generally caught [7]. Emigrants owning property worth more than CAD 25,000 file Form T1161 [7]. You can elect to defer payment, interest-free, until you actually sell, though security is required where the federal tax on the deemed disposition exceeds CAD 16,500 [7].
Australia
Australia charges CGT event I1 when you cease to be a resident: your assets that are not “taxable Australian property” are treated as disposed of at market value on that date [8]. Taxable Australian property, chiefly Australian real estate, stays in the net and is taxed when you eventually sell it [8]. For everything else, you can elect to defer — treating those assets as taxable Australian property until you actually sell them — but the choice covers all affected assets together [8].
United States
The United States is the outlier: it charges on the act of giving up the status itself, through the covered-expatriate rules of Section 877A [9]. You are a covered expatriate if your net worth is at least $2 million, your average annual net income tax for the five prior years exceeds $211,000 (2026), or you cannot certify five years of tax compliance [9][10]. A covered expatriate’s worldwide assets are treated as sold the day before expatriation; the first $910,000 of net gain is excluded in 2026, and the rest is taxed at capital gains rates [10]. Retirement accounts and deferred compensation follow their own rules [9].
How to use this before you move
Exit taxes reward planning done before the departure date, since that date usually fixes the market value, the gain and the elections available to you. The country you leave, the country you enter, the assets you hold and any tax treaty between them all change the result, and deferrals or reliefs can move the real cost by a wide margin.
A TaxoTax brief turns this into a clear, advisor-ready picture for your exact move. Run the instant check to see whether an exit tax is likely to apply to you, and view a sample report to see how we set out the trigger, the timing and the deferral options side by side.
Sources
Verified 16 July 2026.
- PwC Worldwide Tax Summaries — Germany, Other taxes
- Skatteetaten (Norwegian Tax Administration) — Exit tax
- PwC Worldwide Tax Summaries — Norway, Income determination
- Belastingdienst — Protective assessment in the case of emigration
- PwC Worldwide Tax Summaries — France, Other taxes
- impots.gouv.fr — I am leaving France, do I have to pay exit tax?
- Canada Revenue Agency — Dispositions of property for emigrants of Canada
- Australian Taxation Office — How changing residency affects CGT
- IRS — Expatriation tax
- IRS — Instructions for Form 8854 (Rev. Proc. 2025-32 for 2026 amounts)
FAQ
Does every country charge an exit tax when you leave?
No. Most countries do not have a general exit tax, and among those that do, the charge often applies only above a shareholding percentage or asset value. The seven jurisdictions in this guide each run a version, with very different thresholds and deferral terms.
Is an exit tax the same as actually selling my shares?
It is a deemed, or notional, sale. The tax authority treats your assets as sold at market value on your departure date and taxes the paper gain, even though you still own the assets and have received no cash. That is why the timing can be difficult and why deferral matters.
Can I defer or reduce the charge?
Often yes. France, Canada, Australia, Norway and the Netherlands all offer some form of deferral, and moving within the EU or EEA frequently makes that deferral automatic and interest-free until you genuinely sell. Germany and the United States have narrower relief, so early planning carries the most weight there. Confirm the mechanics with an adviser.
Does a tax treaty stop an exit tax?
Usually not on its own. A deemed disposal triggered by departure typically sits outside the protection a treaty gives to actual sales, though treaties still matter for how the destination country taxes the same asset later and for avoiding double taxation. Have an adviser check the specific treaty before you rely on it.