Exit Tax 2026: The US Expatriation Tax and Exit Taxes Country by Country

An exit tax is a tax on gains you haven't realised, charged when you stop being a tax resident (or a citizen). The logic: the country let your shares or business grow in value while you lived there, so it taxes that growth before you leave, as if you'd sold everything on your last day.

Most people moving abroad never pay one. Exit taxes generally hit two groups: founders and investors with large share holdings, and wealthy Americans giving up citizenship or a long-held green card. If you're in either group, the exit tax can easily be the biggest single cost of moving, and it's mostly avoidable with planning done before you leave.

What is the US exit tax?

The US version, under IRC §877A, applies when a citizen renounces or a long-term resident (green card holder in at least 8 of the last 15 years) gives up their status, and they're a covered expatriate. You're covered if any one of these applies:

If you're covered, you're treated as selling all your worldwide assets at fair market value the day before you expatriate. Net gains above an exclusion of $910,000 for 2026 ($890,000 in 2025) are taxed at normal capital gains rates. Retirement accounts get their own rules:

• IRAs, HSAs, and 529s are treated as fully distributed and taxed as ordinary income, without the early withdrawal penalty.
• 401(k)s and other eligible deferred compensation are subject to 30% withholding on future payments instead, as long as you waive treaty reductions.
• Gifts and bequests you later make to US persons are taxed to the recipient at 40% under §2801.

You report all of this on Form 8854. You can elect to defer the tax until you actually sell an asset, but only if you post security and pay interest. The full process is in our renouncing US citizenship guide.

Simply moving abroad doesn't trigger the US exit tax. US citizens stay taxable wherever they live. The tax is about leaving the US tax system, not leaving the country.

Which countries have an exit tax on individuals?

Here are the main regimes that apply when an individual moves their tax residence away. Each one targets mainly shares and securities, not your home or your car.

Our countries with an exit tax list is updated as these rules change. They do change often: Norway tightened its rules in 2022 and again in 2024, and Germany widened its rules in 2022 and 2025.

Which countries don't have an exit tax?

Most countries don't tax individuals on unrealised gains when they leave. Among common origin countries, the UK, Ireland, Switzerland, Italy (for private shareholdings), Cyprus, Malta, Singapore, Hong Kong, and the UAE have no general exit tax for individuals. Two important caveats:

• UK temporary non-residence rule: if you leave the UK and come back within 5 years, gains you realised while away on assets you owned before leaving are taxed in the year you return.
• Sweden and Finland have no exit charge but keep taxing gains on certain shares for a period after you leave, which can have a similar effect.

How do you plan around an exit tax?

Most exit tax planning comes down to timing and structure before you move, not tricks after you leave.

1. Count your years. Germany's 7-of-12, France's 6-of-10, Spain's 10-of-15, and Denmark's 7-of-10 tests mean that someone who moves before hitting the residence threshold isn't caught at all.
2. Check your holding sizes. The thresholds are specific: 1% in Germany, 5% in the Netherlands, €800,000 in France, €4M in Spain, NOK 3M in Norway, DKK 100,000 in Denmark. Valuations as of the departure date matter.
3. Move within the EU/EEA first, if possible. France, Spain, and others give automatic or easier deferral for EU moves, while a direct move to Dubai or Singapore often means paying up front (Germany no longer distinguishes).
4. Realise gains at the right time. In some countries it's cheaper to sell or reorganise before departure, at a known rate, than to face a deemed sale later.
5. Americans: get under the covered thresholds. Gifting to a non-US spouse, using the $910,000 exclusion, and getting all five years of filings in order can make the exit tax zero. See the worked example in renouncing US citizenship.
6. Check the destination. Moving to a country with no capital gains tax means the gain is only ever taxed by the country you leave. That makes it all the more important to get the exit computation right.

Worked example: German founder moving to Dubai

A founder who has lived in Germany for 10 years owns 30% of a GmbH. She founded it with €25,000 of capital, and it's now worth €5 million, so her stake is worth €1.5 million. She moves to the UAE.

• She was resident 7 or more of the last 12 years and held ≥1%, so §6 AStG applies.
• Deemed gain: €1,500,000 − €25,000 cost ≈ €1.475 million.
• Under the partial-income method (60% taxable) at roughly 45% plus solidarity surcharge, the tax is roughly €420,000.
• She can pay it in 7 annual instalments of roughly €60,000, usually against security. If she returns to Germany within 7 years without having sold, the tax is cancelled.

If she had moved before reaching 7 years of German residence, the charge would have been zero. That's why the timing of a move matters so much for founders. Compare Germany with low-tax destinations like the UAE.

Does an exit tax apply to my house or crypto?

• Your home: usually not. Canada, Australia, and South Africa exclude local real estate because it stays taxable there anyway. Most other regimes cover only shares.
• Crypto: it depends on the country. Canada's and South Africa's deemed sale rules cover it, as does the US regime for covered expatriates. Germany's §6 doesn't (it's shares only). Check the rules for the country you're leaving before moving to a crypto tax-free country.
• Pensions: the Netherlands can charge on pension rights. The US taxes IRAs on expatriation. Canada excludes RRSPs from the deemed sale.

Not tax or legal advice. Thresholds are current as of November 2026 and change frequently. Get advice in the country you're leaving before you move.