Exit tax countries
35 jurisdictions that tax unrealized gains upon emigration — critical for tax planning before relocation
These countries impose exit taxes or deemed disposition rules when you cease tax residency. This can trigger tax on unrealized capital gains, even if no actual sale occurs.
All exit tax jurisdictions (35)
| Country | System | PIT | CIT | VAT | CGT | CFC | Exit tax details | Regime |
|---|---|---|---|---|---|---|---|---|
 CA
Canada
|
Worldwide | 33.0% | 15.0% | 5.0% | 27.4% | Yes | Deemed disposition of assets at fair market value upon ceasing residency. Capita... | — |
 US
United States
|
Citizenship based | 37.0% | 21.0% | — | 20.0% | Yes | Covered expatriates (net worth over USD 2 million, average annual net income tax... | — |
 BR
Brazil
|
Worldwide | 27.5% | 34.0% | — | 22.5% | Yes | Deemed disposition of certain assets at market value on departure; final annual... | — |
 AU
Australia
|
Worldwide | 45.0% | 30.0% | 10.0% | 22.5% | Yes | Deemed disposal of assets at market value upon ceasing to be an Australian resid... | — |
 ZA
South Africa
|
Worldwide | 45.0% | 27.0% | 15.0% | 18.0% | Yes | Deemed disposal of worldwide assets at market value upon ceasing tax residency.... | — |
 FR
France
|
Worldwide | 45.0% | 25.0% | 20.0% | 31.4% | Yes | Exit tax on unrealised gains on shares when leaving France if holdings exceed 50... | — |
 ES
Spain
|
Worldwide | 47.0% | 25.0% | 21.0% | 30.0% | Yes | Exit tax on unrealised gains for residents of 10+ years moving to non-EU/EEA cou... | Non-dom |
 SE
Sweden
|
Worldwide | 52.0% | 20.6% | 25.0% | 30.0% | Yes | Extended liability on certain capital gains (including Swedish shares) for up to... | — |
 JP
Japan
|
Worldwide | 45.0% | 23.2% | 10.0% | 20.3% | Yes | Residents departing Japan with covered financial assets of JPY 100 million or mo... | Non-dom |
 DE
Germany
|
Worldwide | 45.0% | 15.8% | 19.0% | 26.4% | Yes | Exit tax on unrealised gains in substantial shareholdings (>1%) when leaving Ger... | — |
 NO
Norway
|
Worldwide | 47.4% | 22.0% | 25.0% | 37.8% | Yes | Latent gains on shares, fund units and similar assets when ceasing Norwegian tax... | — |
 PL
Poland
|
Worldwide | 32.0% | 19.0% | 23.0% | 19.0% | Yes | Exit tax 19% on unrealised gains when qualifying assets worth more than PLN 4 mi... | — |
 IT
Italy
|
Worldwide | 43.0% | 24.0% | 22.0% | 26.0% | Yes | Exit tax on unrealised capital gains when transferring residence to non-EU/EEA c... | Non-dom |
 EC
Ecuador
|
Worldwide | 37.0% | 25.0% | 15.0% | 10.0% | Yes | Impuesto a la Salida de Divisas (ISD): 5% on outbound transfers of money abroad... | — |
 RO
Romania
|
Worldwide | 10.0% | 16.0% | 21.0% | 16.0% | Yes | Corporate exit tax (ATAD) applies at 16% on unrealised gains when a taxpayer tra... | Nomad |
 KR
South Korea
|
Worldwide | 45.0% | 25.0% | 10.0% | 20.0% | Yes | Applies when a long-term resident emigrates, including deemed disposal of domest... | — |
 HU
Hungary
|
Worldwide | 15.0% | 9.0% | 27.0% | 15.0% | Yes | Corporate exit tax (ATAD) taxes unrealised gains when a company moves tax reside... | — |
 PT
Portugal
|
Worldwide | 48.0% | 19.0% | 23.0% | 28.0% | Yes | Loss of Portuguese tax residence is treated as a disposal of cryptoassets. Corpo... | Non-dom |
 AT
Austria
|
Worldwide | 55.0% | 23.0% | 20.0% | 27.5% | Yes | Exit tax on unrealised gains when transferring to non-EU/EEA countries. EU/EEA:... | — |
 IE
Ireland
|
Worldwide | 40.0% | 12.5% | 23.0% | 33.0% | Yes | Exit tax at 33% on unrealised gains on shares/assets when ceasing Irish tax resi... | Non-dom |
 LV
Latvia
|
Worldwide | 33.0% | 20.0% | 21.0% | 25.5% | Yes | Corporate exit tax under ATAD (CIT Act): charge when a Latvian company moves ass... | — |
 SK
Slovakia
|
Worldwide | 35.0% | 24.0% | 23.0% | 19.0% | Yes | ATAD exit tax on hidden reserves when Slovak residents (or non-residents with a... | — |
 EE
Estonia
|
Worldwide | 22.0% | 22.0% | 24.0% | 22.0% | Yes | Corporate exit tax (Income Tax Act § 54⁵, ATAD): when a resident company moves a... | Nomad |
 DK
Denmark
|
Worldwide | 60.5% | 22.0% | 25.0% | 42.0% | Yes | Exit tax on unrealised gains when leaving Denmark; share portfolios with market... | Non-dom |
 NL
Netherlands
|
Worldwide | 49.5% | 25.8% | 21.0% | 36.0% | Yes | Exit tax on substantial interest holdings and deferred pension rights when emigr... | Non-dom |
 AL
Albania
|
Worldwide | 23.0% | 15.0% | 20.0% | 15.0% | Yes | 15% on deemed disposal when a resident company ceases Albanian tax residence or... | — |
 IL
Israel
|
Worldwide | 50.0% | 23.0% | 18.0% | 25.0% | Yes | Deemed disposal of assets at market value upon ceasing Israeli residency, with o... | Non-dom |
 SI
Slovenia
|
Worldwide | 50.0% | 22.0% | 22.0% | 25.0% | Yes | Corporate exit tax (ATAD) taxes unrealised gains (“hidden reserves”) when assets... | — |
 LU
Luxembourg
|
Worldwide | 42.0% | 16.0% | 17.0% | 22.9% | Yes | Companies and individuals transferring assets, a business or tax residence abroa... | — |
 RE
Reunion
|
Worldwide | 45.0% | 25.0% | 8.5% | 31.4% | Yes | Exit tax on unrealised gains on shares when leaving France if holdings exceed 50... | — |
 MQ
Martinique
|
Worldwide | 45.0% | 25.0% | 8.5% | 31.4% | Yes | Exit tax on unrealised gains on shares when leaving France if holdings exceed 50... | — |
 GP
Guadeloupe
|
Worldwide | 45.0% | 25.0% | 8.5% | 31.4% | Yes | Exit tax on unrealised gains on shares when leaving France if holdings exceed 50... | — |
 GF
French Guiana
|
Worldwide | 45.0% | 25.0% | — | 31.4% | Yes | Exit tax on unrealised gains on shares when leaving France if holdings exceed 50... | — |
 YT
Mayotte
|
Worldwide | 45.0% | 25.0% | — | 31.4% | Yes | Exit tax on unrealised gains on shares when leaving France if holdings exceed 50... | — |
 NF
Norfolk Island
|
Worldwide | 45.0% | 30.0% | — | 22.5% | Yes | Deemed disposal of assets at market value when ceasing Australian tax residency... | — |
-
CA
CanadaWorldwide
- PIT
- 33.0%
- CIT
- 15.0%
- VAT
- 5.0%
- CGT
- 27.4%
- CFC
- Yes
Exit tax details: Deemed disposition of assets at fair market value upon ceasing residency. Capital gains triggered on all property worldwide.
-
US
United StatesCitizenship based
- PIT
- 37.0%
- CIT
- 21.0%
- VAT
- —
- CGT
- 20.0%
- CFC
- Yes
Exit tax details: Covered expatriates (net worth over USD 2 million, average annual net income tax over USD 211,000 for the five years before expatriation, or failure to certify...
-
BR
BrazilWorldwide
- PIT
- 27.5%
- CIT
- 34.0%
- VAT
- —
- CGT
- 22.5%
- CFC
- Yes
Exit tax details: Deemed disposition of certain assets at market value on departure; final annual return and exit procedures apply.
-
AU
AustraliaWorldwide
- PIT
- 45.0%
- CIT
- 30.0%
- VAT
- 10.0%
- CGT
- 22.5%
- CFC
- Yes
Exit tax details: Deemed disposal of assets at market value upon ceasing to be an Australian resident. CGT event I1 applies.
-
ZA
South AfricaWorldwide
- PIT
- 45.0%
- CIT
- 27.0%
- VAT
- 15.0%
- CGT
- 18.0%
- CFC
- Yes
Exit tax details: Deemed disposal of worldwide assets at market value upon ceasing tax residency. CGT applies on deemed gain.
-
FR
FranceWorldwide
- PIT
- 45.0%
- CIT
- 25.0%
- VAT
- 20.0%
- CGT
- 31.4%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains on shares when leaving France if holdings exceed 50% of the company or EUR 800,000 total value, for individuals who were French tax...
-
ES
SpainWorldwide
- PIT
- 47.0%
- CIT
- 25.0%
- VAT
- 21.0%
- CGT
- 30.0%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains for residents of 10+ years moving to non-EU/EEA countries
Non-dom regime -
SE
SwedenWorldwide
- PIT
- 52.0%
- CIT
- 20.6%
- VAT
- 25.0%
- CGT
- 30.0%
- CFC
- Yes
Exit tax details: Extended liability on certain capital gains (including Swedish shares) for up to ten years after leaving; many treaties shorten the period.
-
JP
JapanWorldwide
- PIT
- 45.0%
- CIT
- 23.2%
- VAT
- 10.0%
- CGT
- 20.3%
- CFC
- Yes
Exit tax details: Residents departing Japan with covered financial assets of JPY 100 million or more at market value may be taxed on deemed disposal gains at 15.315% (no inhabita...
Non-dom regime -
DE
GermanyWorldwide
- PIT
- 45.0%
- CIT
- 15.8%
- VAT
- 19.0%
- CGT
- 26.4%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains in substantial shareholdings (>1%) when leaving Germany
-
NO
NorwayWorldwide
- PIT
- 47.4%
- CIT
- 22.0%
- VAT
- 25.0%
- CGT
- 37.8%
- CFC
- Yes
Exit tax details: Latent gains on shares, fund units and similar assets when ceasing Norwegian tax residence. From 20 March 2024 emigration uses a NOK 3 million allowance on aggr...
-
PL
PolandWorldwide
- PIT
- 32.0%
- CIT
- 19.0%
- VAT
- 23.0%
- CGT
- 19.0%
- CFC
- Yes
Exit tax details: Exit tax 19% on unrealised gains when qualifying assets worth more than PLN 4 million leave Polish tax jurisdiction
-
IT
ItalyWorldwide
- PIT
- 43.0%
- CIT
- 24.0%
- VAT
- 22.0%
- CGT
- 26.0%
- CFC
- Yes
Exit tax details: Exit tax on unrealised capital gains when transferring residence to non-EU/EEA countries
Non-dom regime -
EC
EcuadorWorldwide
- PIT
- 37.0%
- CIT
- 25.0%
- VAT
- 15.0%
- CGT
- 10.0%
- CFC
- Yes
Exit tax details: Impuesto a la Salida de Divisas (ISD): 5% on outbound transfers of money abroad (reinstated from April 2024; reduced rates apply to certain pharmaceutical and p...
-
RO
RomaniaWorldwide
- PIT
- 10.0%
- CIT
- 16.0%
- VAT
- 21.0%
- CGT
- 16.0%
- CFC
- Yes
Exit tax details: Corporate exit tax (ATAD) applies at 16% on unrealised gains when a taxpayer transfers assets, transfers a permanent establishment abroad, or moves tax residenc...
Nomad regime -
KR
South KoreaWorldwide
- PIT
- 45.0%
- CIT
- 25.0%
- VAT
- 10.0%
- CGT
- 20.0%
- CFC
- Yes
Exit tax details: Applies when a long-term resident emigrates, including deemed disposal of domestic listed shares for qualifying large shareholders (five-year residency test). F...
-
HU
HungaryWorldwide
- PIT
- 15.0%
- CIT
- 9.0%
- VAT
- 27.0%
- CGT
- 15.0%
- CFC
- Yes
Exit tax details: Corporate exit tax (ATAD) taxes unrealised gains when a company moves tax residence or transfers assets or activities out of Hungary; payment may be spread in i...
-
PT
PortugalWorldwide
- PIT
- 48.0%
- CIT
- 19.0%
- VAT
- 23.0%
- CGT
- 28.0%
- CFC
- Yes
Exit tax details: Loss of Portuguese tax residence is treated as a disposal of cryptoassets. Corporate exit-tax rules also apply to transfers of residence or assets abroad.
Non-dom regime -
AT
AustriaWorldwide
- PIT
- 55.0%
- CIT
- 23.0%
- VAT
- 20.0%
- CGT
- 27.5%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains when transferring to non-EU/EEA countries. EU/EEA: installment payments.
-
IE
IrelandWorldwide
- PIT
- 40.0%
- CIT
- 12.5%
- VAT
- 23.0%
- CGT
- 33.0%
- CFC
- Yes
Exit tax details: Exit tax at 33% on unrealised gains on shares/assets when ceasing Irish tax residence
Non-dom regime -
LV
LatviaWorldwide
- PIT
- 33.0%
- CIT
- 20.0%
- VAT
- 21.0%
- CGT
- 25.5%
- CFC
- Yes
Exit tax details: Corporate exit tax under ATAD (CIT Act): charge when a Latvian company moves assets or tax residence abroad, including transfers between head office and foreign...
-
SK
SlovakiaWorldwide
- PIT
- 35.0%
- CIT
- 24.0%
- VAT
- 23.0%
- CGT
- 19.0%
- CFC
- Yes
Exit tax details: ATAD exit tax on hidden reserves when Slovak residents (or non-residents with a Slovak PE) transfer assets, business activities or tax residence abroad. Tax is...
-
EE
EstoniaWorldwide
- PIT
- 22.0%
- CIT
- 22.0%
- VAT
- 24.0%
- CGT
- 22.0%
- CFC
- Yes
Exit tax details: Corporate exit tax (Income Tax Act § 54⁵, ATAD): when a resident company moves assets to a foreign permanent establishment, tax applies to market value minus ca...
Nomad regime -
DK
DenmarkWorldwide
- PIT
- 60.5%
- CIT
- 22.0%
- VAT
- 25.0%
- CGT
- 42.0%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains when leaving Denmark; share portfolios with market value from DKK 100,000 are treated as realised (deferral available). Broader exi...
Non-dom regime -
NL
NetherlandsWorldwide
- PIT
- 49.5%
- CIT
- 25.8%
- VAT
- 21.0%
- CGT
- 36.0%
- CFC
- Yes
Exit tax details: Exit tax on substantial interest holdings and deferred pension rights when emigrating.
Non-dom regime -
AL
AlbaniaWorldwide
- PIT
- 23.0%
- CIT
- 15.0%
- VAT
- 20.0%
- CGT
- 15.0%
- CFC
- Yes
Exit tax details: 15% on deemed disposal when a resident company ceases Albanian tax residence or transfers assets from head office to a foreign PE in exit cases described in law...
-
IL
IsraelWorldwide
- PIT
- 50.0%
- CIT
- 23.0%
- VAT
- 18.0%
- CGT
- 25.0%
- CFC
- Yes
Exit tax details: Deemed disposal of assets at market value upon ceasing Israeli residency, with optional deferral until actual sale.
Non-dom regime -
SI
SloveniaWorldwide
- PIT
- 50.0%
- CIT
- 22.0%
- VAT
- 22.0%
- CGT
- 25.0%
- CFC
- Yes
Exit tax details: Corporate exit tax (ATAD) taxes unrealised gains (“hidden reserves”) when assets, a permanent establishment or tax residence are transferred cross-border, gener...
-
LU
LuxembourgWorldwide
- PIT
- 42.0%
- CIT
- 16.0%
- VAT
- 17.0%
- CGT
- 22.9%
- CFC
- Yes
Exit tax details: Companies and individuals transferring assets, a business or tax residence abroad may trigger exit tax on latent gains (Article 38 LIR, ATAD-aligned). Payment m...
-
RE
ReunionWorldwide
- PIT
- 45.0%
- CIT
- 25.0%
- VAT
- 8.5%
- CGT
- 31.4%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains on shares when leaving France if holdings exceed 50% of the company or EUR 800,000 total value, for individuals who were French tax...
-
MQ
MartiniqueWorldwide
- PIT
- 45.0%
- CIT
- 25.0%
- VAT
- 8.5%
- CGT
- 31.4%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains on shares when leaving France if holdings exceed 50% of the company or EUR 800,000 total value, for individuals who were French tax...
-
GP
GuadeloupeWorldwide
- PIT
- 45.0%
- CIT
- 25.0%
- VAT
- 8.5%
- CGT
- 31.4%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains on shares when leaving France if holdings exceed 50% of the company or EUR 800,000 total value, for individuals who were French tax...
-
GF
French GuianaWorldwide
- PIT
- 45.0%
- CIT
- 25.0%
- VAT
- —
- CGT
- 31.4%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains on shares when leaving France if holdings exceed 50% of the company or EUR 800,000 total value, for individuals who were French tax...
-
YT
MayotteWorldwide
- PIT
- 45.0%
- CIT
- 25.0%
- VAT
- —
- CGT
- 31.4%
- CFC
- Yes
Exit tax details: Exit tax on unrealised gains on shares when leaving France if holdings exceed 50% of the company or EUR 800,000 total value, for individuals who were French tax...
-
NF
Norfolk IslandWorldwide
- PIT
- 45.0%
- CIT
- 30.0%
- VAT
- —
- CGT
- 22.5%
- CFC
- Yes
Exit tax details: Deemed disposal of assets at market value when ceasing Australian tax residency (CGT event I1), subject to the same rules and transitional provisions as mainlan...