Belgium spent decades as the European country you could leave without paying for the privilege. That ended on January 1, 2026.
Under Belgium’s new capital gains regime, a resident who moves their tax residence abroad is treated as having sold their financial assets on the day they go. The paper gain is taxed at 10%.
Belgium is the 17th country that charges you to leave. IMI’s March 2026 survey of exit taxes recorded Belgium as having none, and this piece corrects that.
An exit tax works on one mechanic. On the day you stop being a tax resident, the government treats you as having sold everything you own.
It calculates the profit you would have made and taxes it. You have sold nothing, and you have no cash to pay with.
This guide covers the 17 countries that levy a departure charge on unrealized gains. It leaves out countries that continue to tax you after you go.
Sweden, Finland, and Luxembourg do that through clawback rules that reach your gains for years after departure. Brazil does it through a departure declaration that leaves you taxable on worldwide income indefinitely if you fail to file it.
Both approaches are worth knowing about. Neither one taxes you on the day you leave.
Your bill depends on the country you are leaving, the day you leave it, and how you arranged the years before. Your destination affects one thing only, which is whether you can defer.
David Lesperance, managing partner at Lesperance & Associates, tells internationally mobile families to study the country they are leaving as closely as the one they are going to. He puts exit taxes near the top of the issues that catch them.
What Triggers the Charge
The trigger is the loss of your old tax residency. Buying a golden visa does not set off an exit tax, and collecting a second passport does not either.
Ceasing to be a tax resident of the country you are leaving is the event that does it.
Lesperance describes the charge as the point where “a jurisdiction triggers unrealized capital gains upon departure,” and he counts two kinds of departure. “That may be a physical departure, or that may be a departure upon death.”
That distinction decides the timing of your planning. Once residency ends, the valuation is locked and the liability is fixed.
Restructuring afterward changes nothing.
The government values your assets at fair market value on the departure date, subtracts your original cost basis, and taxes the difference.
Headline rates on the deemed gain range from 10% in Belgium to 42% at the top of Denmark’s share income scale. Australia reaches higher by taxing the gain at your marginal rate.
Payment terms vary more than the rates do. Some countries demand cash on the way out.
Others allow installments, defer until you sell, or cancel the charge if you return within a set window.
The liquidity problem turns an exit tax from an inconvenience into a crisis. A founder who owns illiquid private company shares can face a seven-figure assessment with nothing sold and no cash to settle it.
Tax residency is not settled by counting to 183, and the rule works differently in every country. Center of vital interests, permanent home available to you, habitual abode, and formal ties can all leave you resident long after you have physically left.
The assumption that day-counting settles the question is the most expensive mistake in the field.
The United States Taxes the Citizenship Itself
Every other country on this list waits for you to leave. The United States taxes you wherever you are, so an American in Dubai files with the IRS for as long as they are a citizen..
Relocation therefore changes nothing about the bill. The American exit charge fires on renunciation, or on a long-term resident abandoning a green card they have had for eight of the last 15 years.
Both routes lead to the same mark-to-market regime under Section 877A, and both reach only “covered expatriates.”
You become one by failing any single test out of three.
Two of those tests measure wealth. The first is a net worth of $2 million or more.
The second is an average annual net income tax liability above $211,000 across the prior five years, for 2026 expatriations.
The third test has nothing to do with wealth. Fail to certify five years of full tax compliance on Form 8854 and you are covered whatever your balance sheet says.
A single unfiled return or missed FBAR in the lookback period can therefore hand a middle-income American the same treatment as a billionaire.
For 2026, the first $910,000 of net unrealized gain is excluded. Everything above it is taxed at the applicable capital gains rates.
Retirement accounts fare worse than that exclusion suggests. The IRS deems an IRA fully distributed the day before expatriation, which produces ordinary income tax on the entire balance instead of capital gains treatment on the growth.
The charge also outlives the expatriate. US citizens and residents who later receive a gift or inheritance from a covered expatriate pay a 40% transfer tax on amounts above the annual exclusion.
A parent who renounces can therefore cost an American child close to half of what they leave behind.
IMI has published a full guide to expatriating from the United States and a dedicated breakdown of preparing for the exit tax itself.
Seven Countries Charge You Whatever You Own
Seven of the 17 apply no wealth test and no ownership test to the general charge. If you own an appreciated asset and you leave, you are in scope.
Austria taxes unrealized gains on financial assets at 27.5%, with no minimum threshold. One appreciated share is enough to create a liability.
The Austrian trade-off is in the payment terms. Move within the EU or EEA and you can ask for the tax to be assessed but not collected until you sell, an arrangement Austrian law calls Nichtfestsetzung.
Move anywhere else and the tax falls due immediately, with no deferral and no installment option.
That deferral is no longer as passive as it looks. The Budgetmaßnahmengesetz 2026 attached a proof obligation to every Nichtfestsetzung, and a failure to file the proof counts as a disposal, which triggers the tax.
Deferrals granted from July 1, 2026 need an annual filing, due by the end of the following year.
Deferrals granted before that date, reaching back as far as December 31, 2005, need a one-off filing due December 31, 2026, wherever the deferred income exceeded €100,000.
Anyone who left Austria in the last twenty years and deferred now has four months to file, or a dormant liability becomes a live one.
Belgium is the newest entrant and the cheapest, at 10%. Only gains accrued from January 1, 2026 count, and listed securities are rebased to their last closing price of 2025, so the taxable base starts near zero and grows from there.
Belgium pairs that low rate with generous escape hatches. Moves to the EEA, or to treaty countries with information exchange and recovery assistance, get automatic payment deferral.
For any other destination, Belgian law requires that the departing taxpayer formally request deferral and post security.
The charge is cancelled outright if you sell nothing within 24 months of departure, and cancelled again if you return to Belgium inside that window.
Departing residents must file two certificates confirming they qualify, due by the last day of the 14th and the 26th month after the month they left. The Royal Decrees governing that process took effect on June 1, 2026.
Founders should not read the 10% headline too literally. A stake of 20% or more falls on a separate track, with a €1 million exemption and rates from 1.25% to 10%, while so-called internal capital gains face 33%.
Canada deems you to have disposed of most worldwide assets at fair market value immediately before departure.
Stocks, funds, cryptocurrency, foreign property, partnership interests, and private company shares are all caught. Canadian immovable property, registered accounts such as RRSPs, RRIFs, and TFSAs, and your principal residence are not.
Half of any gain is added to taxable income at the 50% inclusion rate and taxed at your marginal rate.
The 2024 proposal to raise that inclusion rate to 66.67% was deferred and then cancelled outright in March 2025, so the flat 50% governs.
You can postpone payment by filing Form T1244. If the deferred federal tax exceeds $16,500, the Canada Revenue Agency requires that you post adequate security, typically a letter of credit or a charge against Canadian assets.
Return to Canada and re-establish residency, and you can elect to unwind the whole deemed disposition on assets you own.
Australia administers its version through CGT Event I1. When you cease Australian tax residency, you are treated as having disposed of all assets other than taxable Australian property, which remains inside the net regardless.
The deferral election catches people. It is all or nothing across every eligible asset, and any asset you defer is reclassified as taxable Australian property, so Australia retains the right to tax it whenever you sell.
The 50% CGT discount is prorated for the portion of ownership that falls after May 8, 2012.
South Africa applies a deemed disposal on worldwide assets when residency ends, at market value.
South African immovable property is excluded, because the country taxes it whether you live there or not.
The maximum effective rate for individuals is 18%, which comes from applying a 40% inclusion rate to a top marginal rate of 45%.
Israel has taxed departures under Section 100A of the Income Tax Ordinance for years, and almost nobody outside Israel knows it exists.
Assets are deemed sold one day before residency ends, with no threshold, at the applicable capital gains rate.
Israeli law lets the taxpayer postpone payment until the assets are sold. Israel then claims the portion of the gain that matches the ratio between the Israeli ownership period and the total ownership period.
Practitioners describe the resulting charge as difficult to enforce, because the Israel Tax Authority has limited reach over a former resident who has already gone.
Anyone leaving should treat that leniency as temporary. Reform proposals have targeted the gap repeatedly, and Israel has been closing the ones nearby.
New immigrants and veteran returning residents who arrived from January 1, 2026 lost the ten-year reporting exemption their predecessors enjoyed.
New Zealand is the narrowest regime on this list, and it belongs here with a heavy caveat. The country has no general capital gains tax and applies no general deemed disposal on departure.
An exit charge exists only for people who elected the revenue account method under the Foreign Investment Fund rules.
That option opened in the 2026 tax year, for certain new migrants and returning New Zealanders who own unlisted foreign shares.
For those who did elect it, ceasing New Zealand residency deems a disposal of every revenue account method investment at market value immediately before departure.
The deemed disposal only produces tax if you sell within three years of leaving. Sell later than that and New Zealand disregards it.
The design echoes Belgium’s, which is a useful hint about where New Zealand is heading.
Six Countries Set a Number
These six gate the charge behind a value threshold. The numbers range from DKK 100,000 in Denmark to €4 million in Spain, which is the whole distance between a regime that catches an ordinary saver and one that reaches only the wealthy.
Denmark sets the lowest entry point in the world. Its exit tax, fraflytterbeskatning, catches anyone taxable in Denmark for at least seven of the preceding ten years who owns shares worth DKK 100,000 or more.
That threshold is low enough to reach a Dane with a modest brokerage account, which puts Denmark in a different category from every wealth-gated regime on this list.
Gains face Denmark’s share income rates, 27% up to DKK 79,400 for 2026 and 42% above that. The lower bracket doubles to DKK 158,800 for married couples.
Deferral is available, and taxpayers can elect to report gains and losses annually as though they had never left. No collateral is required within the EU and the Nordic area.
Norway administers the toughest collection regime in Europe, and has tightened it repeatedly since 2022.
A basic allowance of NOK 3 million shields the first slice of any gain. Only the excess is taxed, at an effective rate near 37.84%, which comes from applying the 22% income tax rate to a gain multiplied by a 1.72 adjustment factor.
The 2025 National Budget removed the feature that had made the Norwegian tax optional in practice.
Departing taxpayers now choose between paying in full on the day they leave, 12 interest-free annual installments, or a single lump sum with interest at the end of a 12-year deferral.
Two further changes deserve attention from anyone who owns a Norwegian company.
Seventy percent of any dividend you receive while abroad must go toward paying down the outstanding exit tax bill. That kills the old strategy of stripping value out through distributions and selling the emptied shell later.
Norway has also removed the ability to credit foreign taxes paid on an eventual sale against the Norwegian charge, which pushes any double-taxation relief onto your new country of residence.
Return within 12 years and the tax is cancelled on assets you own.
Die during the deferral and Norwegian-resident heirs escape it, while heirs living abroad inherit the bill.
The EFTA Surveillance Authority opened an examination in June 2025 into whether any of this complies with EEA free movement rules.
Japan catches expatriates who never imagined they were exposed. The tax applies to residents who own financial assets worth ¥100 million or more and who have lived in Japan for more than five of the preceding ten years.
The rate is 15.315%, which combines national income tax with a reconstruction surtax.
The 5% local inhabitants’ tax that applies to ordinary Japanese capital gains does not reach the exit charge. Liability for it turns on resident registration as of January 1 of the following year, and a departing taxpayer is not registered then.
Securities, ETFs, funds, bonds, options, and derivatives are all caught. Cash, bank deposits, property, and cryptocurrency fall outside both the threshold test and the taxable base.
Visa category decides whether the residency clock advances at all.
Foreign nationals on Table 1 work visas are generally excluded from the count. Table 2 residents, including permanent residents and spouses of Japanese nationals, are not.
Long-term expatriates who upgraded to permanent residency without thinking about the tax consequences are the group this regime hits hardest.
Deferral extends up to ten years, an initial five-year period plus a five-year extension. Japanese law requires that applicants appoint a Japanese tax agent and post collateral matching the liability.
Poland has taxed unrealized gains since 2019, when it implemented the EU Anti-Tax Avoidance Directive.
The rate is 19%, or 3% where the acquisition cost cannot be determined, and the threshold is PLN 4 million in aggregate market value.
Shares, company rights, derivatives, and fund participation units all fall within scope.
Individuals file a PIT-NZ declaration, and transfers to EU or EEA states that meet the mutual assistance condition qualify for installments over as long as five years.
A Polish court has referred the regime to the Court of Justice of the European Union, which is now considering whether the tax is compatible with EU free movement law in case C-430/25.
A ruling against Warsaw would reverberate well beyond Poland.
France applies its exit tax to individuals who have been tax resident for at least six of the preceding ten years and who own securities worth more than €800,000, or more than 50% of a company.
The rate is 31.4%, which combines 12.8% flat income tax with 18.6% in social charges.
Deferral is automatic for relocations within the EU or EEA and for moves to countries with qualifying tax treaties.
Move to a non-cooperative state, or to a country without a tax fraud prevention agreement with France, and deferral becomes discretionary. French law can then require that applicants post guarantees.
The forgiveness rules reward patience. For departures since January 1, 2019, owning your securities without selling for two years cancels the tax outright, provided the total taxable value was below €2.57 million.
Above that figure, the period is five years. Anyone who left France between 2014 and 2018 remains on the old 15-year clock.
French lawmakers have tried repeatedly to go further. The National Assembly’s Finance Committee adopted a citizenship-based taxation measure in October 2025, and the full Assembly voted it down the following month by a single vote.
Spain taxes individuals who have been resident for at least ten of the preceding 15 years and who own company shares or collective investments worth more than €4 million, or a stake of 25% or more worth over €1 million.
Rates range from 19% to 30%, following the addition of a top bracket above €300,000 in gains.
Two separate deferral provisions apply, and they are easy to confuse.
For moves inside the EU or EEA, the gain becomes taxable only if you sell, leave the bloc, or breach your reporting obligations within ten years. You never have to set foot in Spain again.
For a transfer to a treaty country undertaken for work reasons, deferral extends five years and can be extended by five more. Regaining Spanish residency inside that window without selling extinguishes the debt altogether.
A separate trap catches Spanish nationals and nobody else.
Under Spain’s tax quarantine rule, a Spanish national who moves to a jurisdiction Spain classifies as a tax haven remains a Spanish tax resident for the year of departure and the four tax years that follow.
Foreign nationals leaving Spain fall outside it.
Three Countries Only Come for Owners
The last three regimes look past your portfolio and go after your cap table, which lets a diversified shareholder walk out untouched while a founder pays.
Germany applies its Wegzugsteuer to anyone who owns at least 1% of a company’s shares and who has been subject to unlimited German tax liability for at least seven of the last twelve years.
The tax authority values the unrealized gain at market price on the day before departure, and the effective rate reaches roughly 28.5% including the solidarity surcharge.
Germany dropped the EU versus third-country distinction in 2022, which makes it the outlier on payment terms.
Departing shareholders can spread payment over seven annual installments wherever they are going, so a founder moving to Dubai gets the same schedule as one moving to Lisbon.
That evenhandedness arrived by levelling down. EU movers previously enjoyed indefinite interest-free deferral, and the 2022 reform took it away from them.
The installments usually require that the taxpayer post collateral, and they impose annual cooperation duties. Any breach makes the entire tax immediately due.
Return to Germany within seven years, extendable to twelve, and the charge is cancelled retroactively.
Since January 2025, the rules also reach investment fund units. The charge triggers where the investor owned at least 1% of a fund’s issued units at any point in the previous five years, or where the units’ acquisition cost reaches €500,000.
That test applies fund by fund instead of across a portfolio, so €2 million spread across five investments of €400,000 each falls outside it.
The Netherlands taxes gains on “substantial interests,” meaning stakes of 5% or more of a company’s shares.
A two-bracket system has applied since 2024. For 2026 the rates are 24.5% on the first €68,843 of gain and 31% above that.
EU and EEA movers receive automatic interest-free deferral through a protective assessment, and pay only when they sell.
The Dutch Parliament has instructed the government to develop broader exit tax measures amid concern over departing high-net-worth individuals. Separate proposals to tax unrealized gains more generally have met Senate resistance.
South Korea taxes departing residents classified as large shareholders. The test turns on the size of a stake in a listed company, or on the market value of the shares.
The taxpayer must also have been a Korean tax resident for five years or more within the ten years before departure. The deemed sale covers domestic stocks only, at rates of 20% to 25%.
That narrow scope is about to widen. Korea has passed an extension that brings foreign stocks into the exit tax base for departures from January 1, 2027, and the large shareholder condition does not apply to them.
A Korean resident of five years who owns an ordinary portfolio of US equities, and who owes nothing today, will land inside the regime.
Where Your Destination Changes the Bill
Deferral is the only place your destination changes anything, and it changes a great deal.
Move within the EU or EEA and most European regimes give you automatic or near-automatic deferral.
Austria, Belgium, France, the Netherlands, Spain, Poland, and Denmark all treat an intra-European move more gently than an exit to a third country, a legacy of the free movement case law that constrains what member states can charge at the border.
Move to Dubai, Singapore, or the Caribbean and the terms change. Austria demands immediate payment with no installment option, and Belgium requires that you request deferral formally and post security.
France makes deferral discretionary and can ask for guarantees.
Spanish nationals face the further prospect of Spain taxing their worldwide income for up to five years if it classifies the destination as a tax haven.
Germany cuts against the pattern, offering the same seven annual installments regardless of destination, so a German founder relocating to the UAE faces the same schedule as one relocating to Lisbon.
The practical consequence lands squarely on the classic investment migration route. A European exit into a territorial or low-tax jurisdiction is the move most likely to trigger immediate payment instead of deferral.
The destinations that deliver the tax benefit are consistently the destinations that cost the most on the way out.
The Programs That Put You Inside an Exit Tax
Several of the 17 countries sell residency. Buy in, remain long enough to become a tax resident, and you have purchased a future exit tax liability alongside the permit.
The United States EB-5 program is the clearest case. It requires that investors commit $800,000 in a targeted employment area, which delivers a green card.
Retain that green card for eight of the following 15 years and you become a long-term resident. Abandoning it then triggers the same covered expatriate exit tax that applies to renouncing citizens.
The Gold Card at $1 million and the E-2 visa, where a substantial investment is generally taken to start around $150,000, create adjacent exposures.
The New Zealand Active Investor Plus program requires that investors commit from NZ$5 million, and New Zealand’s exit charge, narrow as it is, waits for those who elect the revenue account method.
South Korea’s investor visa leads to Korean residency, and five years inside a ten-year window is the qualifying period the Korean exit tax uses.
Quebec’s investor program puts you inside Canada’s departure tax. Japan’s Active Investor Visa puts you inside a regime that starts biting at ¥100 million once you have been resident more than five of ten years.
Japan’s Active Investor Visa puts you inside a regime that starts biting at ¥100 million once you have been resident more than five of ten years.
Germany’s self-employment visa puts a founder inside the Wegzugsteuer.
These programs can be the right choice, provided the applicant prices the exit alongside the entry.
Where the Next One Comes From
New Zealand is the likeliest country to widen next. The 2026 Budget proposed extending the revenue account method to every New Zealand tax resident instead of the narrow migrant cohort it reaches today.
Draft legislation is expected around September 2026, and the Foreign Investment Fund de minimis would rise from NZ$50,000 to NZ$100,000. If it passes, the New Zealand exit charge stops being a footnote and becomes a general rule.
The United Kingdom is the case that will not go away. Then Chancellor Rachel Reeves weighed a 20% “settling up charge” on gains embedded in assets at the point of exit, a measure The Times reported could raise around £2 billion a year.
She abandoned it in mid-November 2025, ahead of that month’s Budget, after roughly 150 business leaders objected.
The idea has surfaced repeatedly since, and the constraint that shaped every European regime on this list no longer applies to Britain. Brexit removed the EU free movement rules that had limited what the UK could charge departing residents.
Lesperance points to the Autumn Budget on October 28, 2026, where one open question is whether the UK joins what he calls “a number of G20 countries in having an exit tax.”
Several existing regimes are in motion too. Korea’s extension to foreign stocks takes effect in January 2027, a Polish court has put its regime before the Court of Justice of the European Union, and the EFTA Surveillance Authority is examining Norway’s.
Austria’s deadline arrives first. Every Austrian deferral granted since 2005 needs its proof filing by December 31, 2026, and silence counts as a sale.
The countries that tax wealth annually are the same countries that tighten their exit rules, for the plain reason that a wealth tax without an exit tax funds the moving van.
Norway proves the point, and Australia’s debate over taxing unrealized gains suggests the logic travels.
Sequence the Move Before You Make It
The exit tax is calculated on unrealized gains, so it grows every year you wait. The bill you would pay today is the smallest bill you will ever pay.
The charge crystallizes at the moment your old residency ends, so everything useful has to happen before that date.
Asset restructuring, gifting, disposals timed to manage a multi-year tax average, and the choice of which residency to give up first all lose their power the day the trigger fires. That is why advisers want a long runway.
The sequencing question that decides the most is which residency you surrender, and when. Acquiring a passport does not answer it.
An investor can own a golden visa, a second citizenship, and a tax residency certificate from a territorial jurisdiction, and owe a full deemed disposal to the country they have not formally left.
Anyone renouncing a citizenship instead of a residency faces a separate calculation again, and for Americans the two are the same calculation.
Seventeen countries now price your departure, the thresholds are trending down instead of up, and the one variable you control is when you go.
