Exit taxes when a wealthy family changes country

Figures are for tax year 2026. This Guide compares what happens to unrealised gains when an individual stops being tax resident in Germany, France, the Netherlands, Norway, Spain, Italy, Canada, Australia, the United States or the United Kingdom. It covers the trigger, what is taxed, the holding or value threshold, the deferral or instalment options, when the tax falls away on a return, and the return or form that reports it. Each country section uses the wording of that country's tax authority or statute page, linked in the section. Amounts in the worked example are hypothetical and labelled as such. Where an allowed official page does not print a rule, this Guide says "not printed on an allowed page" rather than guess.

Deeper corridor Guides by Michael Cutajar cover single departures: leaving-france-exit-tax, norway-to-switzerland-wealth-tax-exit, leaving-australia-tax-residency-cgt, us-citizen-moving-abroad-tax and germany-to-switzerland-cross-border-tax. The United States exit tax has its own Guide, us-expatriation-exit-tax. This Guide links to them and does not repeat them. Companion Guides on the same family-office theme: family-office-residency-regimes-compared and succession-and-forced-heirship-compared.

The method, step by step

1. Fix the departure date and the residence history for each family member who holds assets. Each exit tax tests years of past residence differently (Germany: section 6(2) AStG; France: Brochure IR 2026; Spain: article 95 bis Ley 35/2006).
2. List every asset each person holds on the day before departure, by type: company shares, fund units, pension and savings wrappers, real estate, receivables from an earn-out. The country sections below say which types each country catches (Norway exit tax page; Canada dispositions page).
3. Test each holding against the country's threshold in the tables below. A threshold is not an allowance unless the page says so: on a move, Norway's NOK amount is a deduction from the gain, but on a gift or other transfer Norway's NOK amount is a cliff (the whole gain is taxed once it is exceeded); Spain's and France's amounts decide whether the rule applies at all.
4. Value the holdings at the date the country names and compute the deemed gain. Then apply the country's rate on that gain. Only the rates printed in the tables below are stated here.
5. Choose payment: immediate, deferral, or instalments. Note what security is needed and what ends the deferral early (a sale, a gift, a dividend above a limit, a move to a non-EU or non-EEA state).
6. File the departure return with the country's exit form, then diarise the yearly follow-up filings and the date on which the tax falls away if the person comes back or keeps the shares.
7. Check whether the destination country gives a credit or a stepped-up cost for the exit charge. Treaty relief is outside this Guide; record it as an open question for the adopting accountant.

Ask the client first

• For each person who will move: in which years were they tax resident in the country they are leaving, and on what exact date does residence end?
• Which company shares, fund units and pension or savings accounts does each person (and, for France and the Netherlands, the household or fiscal partner) hold, and what share of each company do they own?
• Is the destination inside the EU or EEA? Several deferrals depend on it; for France, whether it is on the tax authority's list.
• Is a sale, a dividend, a gift or a restructuring of the company planned within the next twelve years?
• Is a return to the country of departure possible, and within how many years?
• Is anyone in the family a US citizen or a US green card holder?

Comparison at a glance

No amounts in this table. The threshold and rate for each country sit in that country's own table below.

Country	Trigger	What is taxed	Deferral or instalments	Falls away on return	Source
Germany	End of unlimited tax liability by giving up domicile or habitual abode, after at least seven years of unlimited liability within the last twelve	Shares within section 17(1) EStG, deemed sold at fair market value	Seven equal yearly instalments on application, normally against security	Return within seven years, extendable by up to five years, if conditions are met	https://www.gesetze-im-internet.de/astg/__6.html
France	Transfer of tax domicile out of France after domicile in France for at least six of the ten preceding years	Latent gains on securities above the holding tests, earn-out receivables, gains in deferral	Automatic suspension for the EU and listed states with both assistance agreements; on request with a representative and guarantees elsewhere	Yes, if the securities are still held on the return	https://www.impots.gouv.fr/www2/fichiers/documentation/brochure/ir_2026/pdf_integral/Brochure-IR-2026.pdf
Netherlands	Emigration	Deemed disposal of a substantial interest (box 2); pension and annuity entitlements are also caught	Automatic deferral for EU or EEA moves; otherwise on request; security for a substantial interest on a non-EU move, except to Norway, Iceland or Liechtenstein	Not printed on an allowed page	https://www.belastingdienst.nl/wps/wcm/connect/nl/buitenland/content/conserverende-aanslag-bij-emigratie
Norway	Becoming resident elsewhere under a treaty, emigrating for tax purposes, or moving to Svalbard	Latent gains on shares, fund units, share savings accounts and similar assets	Pay at once, in instalments over twelve years, or defer for twelve years	The tax must be paid within twelve years unless the person moves back before then	https://www.skatteetaten.no/en/person/taxes/get-the-taxes-right/abroad/exit-tax/
Spain	Loss of Spanish taxpayer status by change of residence, after at least ten of the fifteen preceding tax periods	Gains on shares and units of any entity above the value tests	Option for EU or EEA moves; on request with guarantees and interest for qualifying temporary moves	Yes, within the periods in the Spain section	https://www.boe.es/buscar/act.php?id=BOE-A-2006-20764
Italy	Transfer of tax residence by a person carrying on a commercial business (art. 166 TUIR, in force until 31 December 2026)	Not stated here	Not printed on an allowed page	Not printed on an allowed page	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art166
Canada	Ceasing to be resident in Canada	Deemed disposition of most property at fair market value, with listed exceptions	Election to defer payment, with security above a federal tax amount	An election to unwind applies on becoming resident again	https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/dispositions-property.html
Australia	See leaving-australia-tax-residency-cgt	Not restated here	Not restated here	Not restated here	Not printed on a readable allowed page
United States	Renouncing citizenship, or a long-term resident ending US resident status	See us-expatriation-exit-tax	See us-expatriation-exit-tax	See us-expatriation-exit-tax	https://www.irs.gov/individuals/international-taxpayers/expatriation-tax
United Kingdom	No exit charge on an individual printed on the pages read; a return within five years after temporary non-residence brings certain gains back into charge	Capital gains and listed income received while temporarily non-resident	Not applicable	Not applicable	https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-test-srt-rdr3

Germany: section 6 AStG

Who is caught. A natural person who, within the last twelve years before the event, was unlimited liable to German income tax for at least seven years in total (section 6(2) AStG). Years of a person who gave the shares free of charge also count for the recipient.

What triggers it. Three events are treated as a sale of the shares at fair market value (gemeiner Wert): the end of unlimited tax liability because the person gives up domicile or habitual abode; a free transfer to a person who is not unlimited liable to German tax; and any exclusion or restriction of Germany's right to tax the gain on the shares (section 6(1) AStG).

What is taxed. Only shares within section 17(1) sentence 1 EStG: shares in a corporation where the person held, directly or indirectly, at least the percentage in the table below of the capital at any time within the last five years (section 17 EStG). Fund units outside business assets have their own deemed sale under section 19(3) InvStG, but only if the holder held at least the percentage in the table of the issued units within the last five years, OR holds units whose acquisition cost is at least the amount in the table, per fund (units "an dem Investmentfonds"), and only if the sum of taxable gains is positive ("die Summe der ... steuerpflichtigen Gewinne insgesamt positiv") (section 19 InvStG). This Guide does not state the German income tax rate on the deemed gain; see germany-to-switzerland-cross-border-tax.

Item	Value	Note
Source	all figures below	https://www.gesetze-im-internet.de/estg/__17.html
Holding in a corporation that brings shares within section 17 (any time in the last five years)	1%	"innerhalb der letzten fünf Jahre am Kapital der Gesellschaft unmittelbar oder mittelbar zu mindestens 1 Prozent beteiligt war"

Item	Value	Note
Source	all figures below	https://www.gesetze-im-internet.de/invstg_2018/__19.html
Fund units: share of issued units held in the last five years	1%	"mindestens 1 Prozent der ausgegebenen Investmentanteile gehalten hat"
Fund units: acquisition cost of units held at the time of the deemed sale	EUR 500,000	"deren Anschaffungskosten mindestens 500 000 Euro betragen"

Instalments. On application, the tax on the deemed gain can be paid in seven equal yearly instalments. The application is normally granted only against security. The first instalment is due within one month of the tax notice; the rest fall due on 31 July of the following years; no interest is charged. The unpaid balance becomes due within one month if an instalment is missed, the reporting duties are not met, the person files for insolvency, the shares are sold or transferred, or distributions or capital repayments exceed one quarter of the value at departure (section 6(4) AStG). A transfer on death to a natural person is disregarded for the sale or transfer event. The law prints no special EU or EEA deferral for a departure under the current text.

Return within seven years. If the departure was only a temporary absence and the person becomes unlimited liable again within seven years, the tax falls away, but only to the extent that: the shares were not sold, transferred or put into business assets in the meantime; distributions or capital repayments did not exceed one quarter of the value at departure; AND Germany's right to tax a sale of the shares is restored at least to the extent it existed at departure. On application the tax office can extend the seven years by at most five years in total if the intention to return still exists (section 6(3) AStG).

Where the departure is a temporary absence under section 6(3), the payment is deferred for the period the tax office grants and, on application, no instalments are collected; if the tax does not then fall away, interest is charged for the deferral (section 6(4) AStG).

Reporting. The taxpayer must report any of the events that end the instalments within one month, electronically, to the tax office that was competent at departure. Every year by 31 July the taxpayer must report the current address and confirm that the shares are still attributed to them (section 6(5) AStG).

Older departures. Where a trigger under the version in force until 30 June 2021 happened before 1 January 2022, that older version continues to apply to the case, with the modifications in section 21(3) AStG (section 21 AStG).

France: article 167 bis CGI

The text below follows the 2026 income tax brochure of the tax authority, which covers departures in 2025 declared in 2026. Legifrance refused automated retrieval when this Guide was written, so the article itself is not quoted.

Who is caught. A person who was tax domiciled in France for at least six of the ten years before the transfer of tax domicile out of France (Brochure IR 2026).

What is taxed. Latent gains on company rights and securities, receivables from an earn-out clause (complément de prix), and gains held in deferral (plus-values en report). Latent gains are taxed only if, at the date of transfer, the taxpayer together with the members of the tax household holds EITHER a direct or indirect stake of at least the percentage in the table below in the profits of one company, OR one or more direct holdings whose total value exceeds the amount in the table. The latent gain is the difference between the value at the transfer date and the acquisition value, reduced where applicable by the holding-period allowance. Latent losses at departure cannot be set against gains.

Item	Value	Note
Source	all figures below	https://www.impots.gouv.fr/www2/fichiers/documentation/brochure/ir_2026/pdf_integral/Brochure-IR-2026.pdf
Stake in the profits of one company (test 1)	50%	"d’au moins 50 % dans les"
Total value of direct holdings (test 2, more than)	EUR 800,000	"valeur globale excède 800 000 € à la date du transfert du domicile"
Total value that sets the two-year or five-year holding period (transfers from 1 January 2019)	EUR 2.57 million	"2,57 M € à la date du transfert"
Income tax on the gain, if the flat rate applies	12.8%	"au barème ou à 12,8 %"

Rate. The brochure has the exit gain reported either at the progressive scale or at the flat rate, and the gain is also subject to social levies. The tax authority's page on gains on securities realised from 1 January 2018 prints the rates below: the flat-rate tax (PFU) applies by default unless the taxpayer opts, for all such income, for the progressive scale by ticking box 2OP.

Item	Value	Note
Source	all figures below	https://www.impots.gouv.fr/particulier/questions/jai-realise-une-plus-value-mobiliere-comment-est-elle-imposee
Income tax part of the flat-rate tax on gains on securities	12.8%	"12,8 % au titre de l'impôt sur le revenu et 18,6 % au titre des prélèvements sociaux"
Social levies part	18.6%	"18,6 % au titre des prélèvements sociaux"
Overall flat rate	31.4%	"dont le taux global est de 31,4 %"

Suspension of payment (sursis). For transfers from 1 January 2019 the suspension is automatic on a move to an EU member state, or to another state or territory that has concluded with France both an administrative assistance agreement against tax fraud and evasion AND a mutual assistance agreement on recovery, and is not a non-cooperative state; the tax authority prints the list of such states for transfers from 1 January 2025 (it includes the United Kingdom, the United States, Australia, Norway and Monaco; Switzerland and the United Arab Emirates are not on it) (2074-ETS2 notice 2026). For any other state the taxpayer may ask for a suspension, provided they appoint a tax representative in France and give guarantees. The suspension ends in particular on the sale, redemption, repayment or cancellation of the securities, and in some cases on a gift of the securities or the taxpayer's death.

When it falls away. For transfers from 1 January 2019, income tax and social levies are relieved or refunded if the securities are still held two years after the transfer where their total value at the transfer date is below the amount in the table, or five years after the transfer where it exceeds that amount. Transfers between 1 January 2014 and 31 December 2018 use fifteen years; transfers before 1 January 2014 use eight years. On a new transfer of domicile back to France, the tax on all the gains and receivables is relieved or refunded if the securities and receivables are still held.

Forms. In the year of departure, the gains and receivables are computed on form 2074-ETD, attached to the income tax return, and carried to form 2042 C. While a suspension runs, form 2074-ETS is the follow-up return, and the tax in suspension is reported on line 8TN of form 2042 C. For depth, use leaving-france-exit-tax.

Netherlands: the conserverende aanslag

What triggers it. Emigration. A person with a substantial interest (aanmerkelijk belang) in a company in the Netherlands (the page's heading: "U hebt een aanmerkelijk belang in een vennootschap in Nederland") is treated on emigration as if the shares were sold (fictieve vervreemding). Whether shares in a foreign company are treated the same way on emigration is not printed on the pages read. The gain is box 2 income, and the tax on it is raised by a protective assessment, the conserverende aanslag (Belastingdienst, conserverende aanslag bij emigratie). The same page also issues protective assessments on pension built up in the Netherlands with tax relief, on annuities (lijfrente) whose premiums were deducted, and on some own-home savings products.

Substantial interest. A person holds a substantial interest if, alone or together with a fiscal partner, they hold directly or indirectly at least the percentage in the table of the shares (also per class) of a Dutch or foreign company, or of its profit certificates or rights of enjoyment (Belastingdienst, aanmerkelijk belang 2026). Family members' holdings can also bring a smaller holding in.

Item	Value	Note
Source	all figures below	https://www.belastingdienst.nl/wps/wcm/connect/fisin/fisin2026/aanmerkelijk_belang
Substantial interest: share of the shares, alone or with a fiscal partner (at least)	5%	"direct of indirect minimaal 5% hebt van: de aandelen"

Item	Value	Note
Source	all figures below	https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/prive/inkomstenbelasting/heffingskortingen_boxen_tarieven/boxen_en_tarieven/box_2/box_2
Box 2 band 1 for 2026: taxable income up to	EUR 68,843	"2026 1 tot € 68.843 24,5%"
Box 2 band 1 rate, 2026	24.5%	"2026 1 tot € 68.843 24,5%"
Box 2 band 2 rate, 2026, from the band 1 limit	31%	"2 vanaf € 68.843 31%"

Deferral. On a move to an EU or EEA country, deferral of payment is automatic and no collection interest runs over the deferral period. Otherwise the person can ask for deferral; how to ask is printed on the assessment. On a move to a non-EU country, security must be given for the tax on a substantial interest; no security is needed on a move to Norway, Iceland or Liechtenstein. Security can be, for example, a bank guarantee, a mortgage or a pledge. Deferral is withdrawn if a person who first moved to an EU country with automatic deferral then moves on to a non-EU country; they may ask again and the tax office can ask for security.

How long it lasts. A protective assessment normally has a validity of ten years; only one for a substantial interest is unlimited. If the person deregistered from the municipality after 15 September 2015 at 15.15 hours, the deferral is lifelong and the assessment is no longer remitted on request after ten years; the tax on the Dutch substantial-interest gain must be settled at some point. For an emigration before that moment, deferral is ten years, after which remission can be requested if the person shows the company still exists and they still own the shares. A sale of the shares, a dividend paid on them, or the company ceasing must be reported, and the assessment then becomes (partly) payable.

On return. What happens to the protective assessment on a return to the Netherlands is not printed on the Belastingdienst pages linked in this section.

Norway: exit tax on shares, after the 2024 changes

What triggers it. Moving out of Norway and becoming resident in another country under a tax treaty, being registered as emigrated for tax purposes, or becoming tax resident in Svalbard, after having been tax resident in Norway under both the Taxation Act and any relevant treaty. Gifts and gift sales to persons resident abroad, and inheritance passing to heirs abroad (inheritance from a Norwegian estate from 1 January 2025), are also caught (Skatteetaten, exit tax). Registration of a residential address in Norway is not relevant.

Which rules apply depends on the date of the move. The page splits moves on or before 19 March 2024 from moves on or after 20 March 2024, with further changes from 7 October 2024 and 1 January 2025. This section states the rules for moves on or after 20 March 2024. For a move on or before 28 November 2022, the conditional liability lasted five years and then lapsed.

What is taxed. Latent gains on shares in Norwegian or foreign companies, units in securities funds, share savings accounts, investment fund accounts, employment options, interests in companies assessed as partnerships, financial instruments with such underlying assets, and assets in foreign pension savings schemes when considered a regular investment account (the page names IRAs and 401(k)s). Exit tax is calculated only on values accumulated while the person was tax resident in Norway. On a move there is a basic deduction, shown below; only the total gain or loss above it is subject to exit tax. On a move within the EEA or to Svalbard, gains and losses are netted before the deduction. On a move outside the EEA, only gains are added up; losses are not included. For gifts and other transfers (not moves), there is no basic deduction: if the net latent gain exceeds NOK 100,000, exit tax is due on the entire gain.

Item	Value	Note
Source	all figures below	https://www.skatteetaten.no/en/person/taxes/get-the-taxes-right/abroad/exit-tax/
Basic deduction from the total latent gain or loss on a move	NOK 3,000,000	"You get a basic deduction of NOK 3,000,000 in the calculated latent gain or loss"
Share of a distribution that must go to repay a deferred claim (from 7 October 2024)	70%	"70 percent of the distribution must go towards repayment of the tax claim"
Transfer threshold: net latent gain on a gift or other transfer (not a move)	NOK 100,000	"net latent gain exceeding NOK 100,000, you must pay exit tax on the entire gain"

Rate. The exit tax page prints no rate. The tax authority's rate page prints the rate on gains and dividends on shares for the 2026 income year, below.

Item	Value	Note
Source	all figures below	https://www.skatteetaten.no/en/rates/factor-for-upward-adjustment-of-gainloss-or-dividend-on-shares/
Tax rate on gains and dividends on shares, 2026 income year	37.84%	"The tax rate on gains and dividends for the 2026 income year is 37.84 percent"

Payment. In the tax return the person chooses to pay at once, to pay in instalments over twelve years after the move, or to defer the whole liability for twelve years. The tax must be paid within twelve years unless the person moves back to Norway before the twelve years have passed. The tax authority can require security even on a move to another EEA country. If the person dies, the exit tax must be paid, unless the asset passes with full continuity to heirs resident in Norway; an heir resident abroad can take over the liability and the deferral. A person who moves back after twelve years has the opening value of the assets still held adjusted to market value at the time of the move.

Reporting. The exit tax information goes in the tax return for the day before the move (a move on 1 January 2025 is reported in the 2024 return). While a deferral runs, a questionnaire must be answered every year by 30 April, and changes, such as a sale or a move from an EEA country to a country outside the EEA, must be reported within two months. If no exit tax information is given, the tax authority can assess it up to fifteen years after the move. For the Switzerland corridor, see norway-to-switzerland-wealth-tax-exit.

Spain: article 95 bis LIRPF

Who is caught. A taxpayer who loses Spanish taxpayer status by change of residence, and who was a taxpayer in at least ten of the fifteen tax periods before the last period that must be declared (article 95 bis Ley 35/2006). For a person who used the special regime for workers posted to Spain, the ten periods are counted from the first period in which that regime no longer applied.

Article 95 bis is the law of common-regime Spain. The Basque historical territories and Navarre apply their own income tax law ("sin perjuicio de los regímenes tributarios forales de concierto y convenio económico en vigor, respectivamente, en los Territorios Históricos del País Vasco y en la Comunidad Foral de Navarra", article 4 Ley 35/2006); this Guide does not cover them.

What is taxed. The positive difference between market value and acquisition value of shares and units of any type of entity, if EITHER the market value of all such holdings together exceeds the first amount in the table, OR, where that test is not met, the person holds more than the percentage in the table in one entity on the accrual date of the last period and the market value of that holding exceeds the second amount. Under the second test only the gain on that holding is taxed. The gain is savings income, imputed to the last period that must be declared, by a complementary self-assessment without penalty, late-payment interest or surcharge. Listed shares are valued at market price; unlisted shares at the higher of net equity in the last closed balance sheet and the average result of the last three closed years capitalised at the rate the article prints, unless another market value is proved.

Item	Value	Note
Source	all figures below	https://www.boe.es/buscar/act.php?id=BOE-A-2006-20764
Market value of all holdings together (test a, more than)	EUR 4,000,000	"exceda, conjuntamente, de 4.000.000 de euros"
Holding in one entity (test b, more than)	25%	"el porcentaje de participación en la entidad sea superior al 25 por ciento"
Market value of that one holding (test b, more than)	EUR 1,000,000	"exceda de 1.000.000 de euros"
Savings scale: tax on the first EUR 300,000 of the savings base (state and regional halves together, as printed in article 66.2)	EUR 71,880	"100.000 27 300.000,00 71.880 En adelante 30"
Savings scale: rate on the savings base above EUR 300,000	30%	"100.000 27 300.000,00 71.880 En adelante 30"

Move to another EU or EEA state. Where the new residence is in another EU member state, or an EEA state with effective exchange of tax information, the taxpayer can opt for special rules: the gain is self-assessed only if, within the ten periods after the last one declared, the shares are transferred inter vivos, the person stops being resident in an EU or EEA state, or the person fails to make the required communication. The option, the gain, the new state and address, later changes, and continued ownership must be communicated to the tax authority. If the person becomes a Spanish taxpayer again before any of those events, the rule has no effect.

Temporary move elsewhere. On the taxpayer's request, payment is deferred where the change of residence is a temporary move for work to a country or territory that is not a tax haven, or a temporary move for any other reason to a country with a double tax treaty with Spain containing an exchange of information clause. Interest accrues and guarantees are required; the guarantees can be given over the shares. If the person becomes a Spanish taxpayer again within the five periods after the last one declared without having transferred the shares, the deferred debt and the interest are extinguished. For a work move the five periods can be extended, by no more than five more periods.

Return after paying. A person who becomes a Spanish taxpayer again without having transferred the shares can ask for rectification of the self-assessment and a refund, with interest from the date of payment.

Tax havens. The article also applies where a person moves to a tax haven but keeps Spanish taxpayer status under article 8.2, with the gain imputed to the last period of habitual residence in Spain.

Italy

Normattiva prints article 166 of the income tax code (TUIR) as repealed by D.Lgs. 19 June 2026 n. 117 with effect from 1 January 2027 ("Testo in vigore dal: 1-1-2027"). The version in force until 31 December 2026 applies to "soggetti che esercitano imprese commerciali" who move their tax residence abroad (Normattiva, art. 166 TUIR as in force on 4 October 2026). A 2026 departure of a person carrying on a business is therefore caught for the business assets; this Guide does not state its terms or rate. The text that replaces the article from 2027 is not traced in this Guide. An exit charge on shares held privately, outside a business, is not printed on the pages linked here.

Canada: departure tax

What triggers it. A person who ceased to be resident in Canada in the year is deemed to have disposed of certain property at fair market value when leaving and to have immediately reacquired it for the same amount (CRA, dispositions of property for emigrants). This applies to most property.

What is not caught. The exceptions the page lists include: Canadian real or immovable property, Canadian resource property and timber resource property; Canadian business property (including inventory) where the business is carried on through a permanent establishment in Canada; pension plans, annuities, registered retirement savings plans, registered retirement income funds, registered education and disability savings plans, tax-free savings accounts and the other plans and rights the page lists as excluded rights or interests; and property owned on last becoming resident (or inherited afterwards) by an individual who was resident in Canada for 60 months or less in the ten years before emigrating. A person can elect to report a deemed disposition of the first two kinds of property.

Item	Value	Note
Source	all figures below	https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/dispositions-property.html
Form T1161 required if the fair market value of all property owned on leaving was more than	CAD 25,000	"owned when you left Canada was more than $25,000"
Security required for the deferral election if federal tax on the deemed disposition is more than	CAD 16,500	"on income from the deemed disposition of property is more than $16,500"
Same security limit for former residents of Quebec	CAD 13,777.50	"more than $13,777.50 for former residents of Quebec"

Forms and deferral. The gains are computed on Form T1243 and carried to Schedule 3 of the return for the year of departure. Form T1161 lists all property inside and outside Canada above the limit in the table, with listed exclusions such as cash. Form T1244 is the election to defer payment of the tax on the deemed disposition until the property is sold, without interest; it must be made by April 30 of the year after emigration, and it does not apply to the deemed disposition of an employee benefit plan. Above the limit in the table, adequate security is required; provincial or territorial tax may also need security. The page is written for the 2025 return; the 2026 equivalents are not printed on it.

On return. A person who emigrated after October 1, 1996 and later becomes resident again can elect to "unwind" the earlier deemed disposition for property still owned. This Guide does not state a Canadian rate. For residence questions, see ca-tax-residency.

Australia

The Australian rule is covered in leaving-australia-tax-residency-cgt. The tax authority's site refused automated retrieval on the day this Guide was written, so this Guide restates no Australian rule.

United States

The expatriation tax provisions of sections 877 and 877A of the Internal Revenue Code apply to US citizens who have renounced their citizenship and to long-term residents who have ended their US resident status for federal tax purposes. For expatriation on or after June 17, 2008, a person is a covered expatriate if any one of three tests is met: an average annual net income tax test, a net worth test, or a failure to certify five years of tax compliance on Form 8854 (IRS, expatriation tax). The amounts, the deemed sale and the deferral are in us-expatriation-exit-tax. Citizens who move abroad but keep citizenship are not expatriating; see us-citizen-moving-abroad-tax.

United Kingdom: no exit charge, but temporary non-residence

No UK charge on the unrealised gains of an individual who leaves is printed on the HMRC page linked in this section. The rule HMRC sets out for departures is temporary non-residence: a person who returns may pay tax in the year of return on certain income and gains received during the absence (HMRC RDR3, section 7). A person is temporarily non-resident if, after a residence period with sole UK residence, they have one or more residence periods without sole UK residence; AND in 4 or more of the 7 tax years before the year of departure they had sole UK residence for the tax year, or the year was a split year with a residence period of sole UK residence; AND the period of non-residence lasts 5 years or less. A period of more than five years, meaning five years plus one day, takes the person outside the rule: HMRC's example is a departure on 4 May 2015 and a return on 4 May 2020, to which the rules do not apply. Capital gains are among the items in scope. Trust and company charges are outside this Guide.

Worked hypothetical: a founder with a EUR 10,000,000 unrealised gain

Hypothetical facts, for illustration only: one founder, single, no fiscal partner, holds all the shares of one unlisted trading company. The unrealised gain on the shares is the hypothetical amount in the table below. The founder meets each country's past-residence test, has no other income, and pays at departure without deferral. No holding-period allowance, personal minimum, high-income surcharge or treaty credit is applied. These simplifications make the tax shown lower or higher than a real computation; use the result only to compare orders of magnitude.

Only countries whose allowed pages print a rate that applies to the gain are computed. Germany (progressive scale under the partial-income method, rate not stated here), Norway and Canada (gain in NOK or CAD, no exchange rate on an allowed page), Italy, Australia, the United States and the United Kingdom are not computed.

Item	Hypothetical value	Working	Source
Unrealised gain (hypothetical)	EUR 10,000,000	Assumption	https://www.boe.es/buscar/act.php?id=BOE-A-2006-20764
France: income tax part at the flat rate	EUR 1,280,000	Gain times 12.8%	https://www.impots.gouv.fr/www2/fichiers/documentation/brochure/ir_2026/pdf_integral/Brochure-IR-2026.pdf
France: social levies part	EUR 1,860,000	Gain times 18.6%	https://www.impots.gouv.fr/particulier/questions/jai-realise-une-plus-value-mobiliere-comment-est-elle-imposee
France: total at the overall flat rate	EUR 3,140,000	Gain times 31.4%	https://www.impots.gouv.fr/particulier/questions/jai-realise-une-plus-value-mobiliere-comment-est-elle-imposee
Netherlands: box 2 tax on the deemed disposal	EUR 3,095,525	EUR 68,843 times 24.5%, plus the rest of the gain times 31%, rounded to the euro	https://www.belastingdienst.nl/wps/wcm/connect/bldcontentnl/belastingdienst/prive/inkomstenbelasting/heffingskortingen_boxen_tarieven/boxen_en_tarieven/box_2/box_2
Spain: savings scale on the gain	EUR 2,981,880	Common-regime Spain only. EUR 71,880 plus the gain above EUR 300,000 times 30%	https://www.boe.es/buscar/act.php?id=BOE-A-2006-20764

Reading the result. France: the French high-income contributions are not included. With automatic suspension on a move to a qualifying EU or listed state and the shares still held after five years (the shares' value at the transfer date is above the French amount in the France table), both parts would be relieved. Netherlands: on an EU or EEA move the assessment is deferred automatically, but after 15 September 2015 it is not remitted after ten years. Spain: the founder meets test a; on an EU or EEA move with the option, nothing is self-assessed unless one of the listed events happens within ten periods.

Planning checklist

1. Timing. Fix the departure date against each test: Germany's seven of twelve years, France's six of ten, Spain's ten of fifteen, and the United Kingdom's 4 of 7 years and five-year absence. Leave before a sale is signed, not during it; a sale during a deferral ends it in France, Germany, the Netherlands, Norway and Spain.
2. Which assets. Map each holding against the tests: Germany's section 17 percentage and the fund rules; France's household tests; the Dutch substantial-interest percentage including the fiscal partner; Norway's wide asset list (including share savings accounts and some foreign pension accounts); Spain's two value tests; Canada's exceptions.
3. Getting the deferral. Germany: apply for the seven instalments and agree the security before the first notice. France: check that the destination is on the list for automatic suspension, or prepare a representative and guarantees. Netherlands: deferral is automatic only inside the EU or EEA. Norway: choose instalments or deferral in the return and expect a security request. Spain: exercise and communicate the EU or EEA option, or request the work-move deferral with guarantees. Canada: file Form T1244 by April 30 of the following year.
4. Dividends and distributions. Germany ends the instalments when distributions exceed one quarter of the departure value; Norway takes the share of a distribution in the Norway table towards the deferred claim; the Netherlands makes the assessment (partly) payable on a dividend. Plan the dividend policy before leaving.
5. Coming back. Germany: seven years, extendable. France: the tax is relieved on return with the securities still held. Norway: before twelve years. Spain: five periods on the deferral route, or a refund claim after paying. Canada: the unwind election. Write the deadline into the family calendar.
6. Yearly filings. Germany by 31 July; Norway by 30 April; France form 2074-ETS; Spain the communication of changes. Missing them can end the deferral.

When to refuse or refer

• Refer any family member who is a US citizen or green card holder to us-expatriation-exit-tax and a US-licensed adviser before any step.
• Refer departures from Australia to leaving-australia-tax-residency-cgt; this Guide states no Australian rule.
• Refer Italian departures, and any Italian business owner, to an Italian professional.
• Refer any move where the destination's treaty or tax credit for the exit charge decides the outcome; treaty relief is outside this Guide.
• Refer shares held through trusts, foundations or holding companies, where the exit charge may sit with the entity rather than the person.
• Refuse to state a German, Canadian or Norwegian tax amount on the deemed gain from this Guide: the rate or currency conversion is not printed here.

Sources

• Germany: section 6 AStG; section 21 AStG; section 17 EStG; section 19 InvStG
• France: Brochure pratique IR 2026; impots.gouv.fr, gains on securities; 2074-ETS2 notice 2026
• Netherlands: conserverende aanslag bij emigratie; aanmerkelijk belang 2026; box 2 tarieven
• Norway: exit tax; tax rate on shares
• Spain: Ley 35/2006, consolidated text
• Italy: Normattiva, art. 166 TUIR; Normattiva, art. 166 TUIR as in force on 4 October 2026
• Canada: dispositions of property for emigrants; leaving Canada (emigrants)
• United States: IRS, expatriation tax
• United Kingdom: HMRC RDR3