The Exit Tax Map (2026): What It Costs to Leave a Country With Your Assets

Published on: June 15, 2026

Quick answer: An exit tax fires when you change tax residency or give up citizenship, not when you sell. Many countries treat your assets as if sold at market value the day you leave and tax the unrealised gain, even though no cash changed hands. Most European exit taxes target shares and securities rather than your home directly, but property feeds the US net-worth test and Canada's deemed-disposition rule, and a home you sell after leaving is usually still taxed where it sits.

Every cross-border buyer plans for capital gains tax on the day they sell. Almost nobody plans for the tax that fires on the day they leave.

Exit tax, also called departure or expatriation tax, is a separate, often larger event. It is not triggered by a sale. It is triggered by the act of changing your tax residency or giving up citizenship. The moment you cease to be taxable somewhere, a growing list of governments treats your assets as if you sold them at market value the day before, and taxes the unrealised gain. No buyer, no sale, no cash, and still a bill, sometimes a very large one.

For an internationally mobile investor moving between markets, this is the tax that turns a clean relocation into a liquidity trap. Here is the 2026 map.

Exit tax vs capital gains tax on sale

The distinction is the whole point. Capital gains tax on sale is charged when you actually dispose of an asset and receive proceeds you can pay it from. Exit tax is charged on a deemed disposal, a legal fiction that you sold, so you can owe tax on appreciation you have never converted to cash. That mismatch between the tax due and the money in hand is what catches people. The rest of this guide is about who imposes it, on what, and how to soften it.

United States, the expatriation tax (Section 877A)

The US is the only country that taxes on the basis of citizenship, so its exit tax reaches US citizens who renounce and long-term green-card holders who surrender residency, wherever in the world they live.

It applies only to a covered expatriate, which you become if you meet any one of three tests at expatriation: a net worth of US$2 million or more; an average annual net income tax liability over the prior five years above roughly US$211,000 (the figure is indexed annually); or failure to certify five years of full tax compliance on Form 8854.

If you are covered, all your worldwide assets are treated as sold at fair market value the day before you expatriate. For 2026, the first US$910,000 of net unrealised gain is excluded; gains above that are taxed under normal capital-gains rules (and the 3.8% net investment income tax may apply). Note that cash cannot be "sold," but it still counts toward the US$2 million net-worth test, as does your home and every other asset.

Canada, departure tax (deemed disposition)

Canada's departure tax is one of the broadest in the world. When you cease Canadian tax residency, you are deemed to have disposed of virtually all your property at fair market value, and you pay tax on the resulting gains.

The reach is wide, shares, partnership interests, trust interests, stock options, but there are key carve-outs: Canadian real property stays in the Canadian net and is taxed on actual disposition rather than on departure, along with pension rights and personal-use property under CAD 10,000. Helpfully, Canada generally measures the gain from the value when you arrived (or later acquired the asset) to the value on departure, not from your original cost decades earlier.

Australia, deemed disposal on ceasing residency

When you stop being an Australian tax resident, a capital gains event is deemed to occur on your assets that are not "taxable Australian property" (broadly, assets other than Australian real estate), and you pay CGT on the deemed gain.

Australia offers a choice: you can elect to defer by treating those assets as taxable Australian property, keeping them in the Australian net until you actually sell, instead of paying on departure. Many leavers decline the election and accept the departure charge in exchange for a clean break from the Australian system, the right answer depends on the size of the unrealised gains and whether the assets will keep appreciating. Australian real estate itself remains subject to Australian CGT regardless.

Germany, the Wegzugsteuer (§6 AStG)

Germany's exit tax targets entrepreneurs and company shareholders specifically. The Wegzugsteuer under Section 6 of the Foreign Tax Act (AStG) applies when you permanently leave Germany and hold 1% or more of the shares in a corporation (a GmbH, AG, UG, or foreign equivalent), having been a German tax resident for at least 7 of the last 12 years.

On departure, those shares are treated as sold at fair market value, and the unrealised gain is taxed under the partial-income method, broadly, 60% of the gain taxed at progressive rates, an effective burden of roughly 28.5%. Since the 2022 reform the exit tax is generally payable in seven equal, interest-free annual instalments; an EU/EEA move qualifies for the instalment plan without posting security, while a move to a non-EU/EEA destination (such as the US, UK, Switzerland, or the UAE) generally means the tax is due upfront as of 2026, though the exact treatment depends on the destination and any applicable treaty. One 2025 expansion to watch: the rules now also reach significant holdings in investment funds and ETFs, closing a route that previously let portfolio investors leave untaxed.

France, the exit tax (Article 167 bis CGI)

France's exit tax applies to individuals who were tax resident for at least 6 of the last 10 years and who, on departure, hold securities worth more than €800,000 or more than 50% of a company's shares.

The transfer of residence is the taxable event, and the rate for 2026 is a flat 31.4%, 12.8% income tax plus 18.6% social contributions (the social-contribution component was raised from 17.2% by the 2026 Social Security Financing Act). The system is comparatively forgiving: deferral is available for moves to the EU/EEA or to treaty countries, and if you return to France still holding the assets, or hold them long enough through the monitoring period, the tax can be cancelled and any prepayment refunded. The trade-off is heavy reporting, miss the departure and annual monitoring filings and you can be assessed as though the tax fell due immediately.

Spain, the exit tax (Article 95 bis IRPF)

Spain's exit tax under Article 95 bis of the personal income tax law applies when a long-term tax resident (broadly, resident in 10 of the last 15 years) moves abroad while holding significant shareholdings or financial assets above set thresholds. As with the others, Spain taxes the difference between acquisition value and market value on the day residency changes, as if the shares had been sold. Deferral is available under EU freedom-of-movement principles when the move is to another EU/EEA state, but the taxpayer must still declare and meet administrative requirements on leaving.

United Kingdom, no formal exit tax, but a trap

The UK does not impose a classic deemed-disposal exit tax. Instead it relies on temporary non-residence rules: if you leave, realise gains while non-resident, and then return within roughly five years, certain gains can be clawed back and taxed as if they arose in the year you came back. The lesson is that "no exit tax" does not mean "leave and sell freely", the timing of your return matters.

Where does property actually sit?

This is the question that matters most to a real-estate-focused reader, and the answer is nuanced.

Most of the European exit taxes above, Germany, France, Spain, are aimed at shares and securities, not your home directly. But property is not off the hook:

• It feeds the US net-worth test (the value of your home counts toward the US$2 million covered-expatriate threshold) and is part of the US deemed sale.
• Real property generally falls inside Canada's broad deemed disposition, though Canadian real property is typically taxed on actual sale rather than on departure. How a specific asset is treated depends on your circumstances.
• And under most tax treaties, as of 2026, real estate is generally taxed where it sits, so a home you sell after relocating is usually still subject to capital gains tax in the country it is located in, regardless of where you now live.

In short: exit tax rarely hits the foreign holiday home directly, but it shapes when and whether you should restructure, sell, or hold across a move.

Exit tax at a glance (2026)

Frequently asked questions

What is an exit tax?
A tax triggered by changing tax residency or citizenship, not by selling. Many countries treat your assets as sold at market value on departure and tax the unrealised gain.

Does the US exit tax apply to me?
Only if you are a covered expatriate: roughly US$2 million net worth, ~US$211,000 average annual income tax, or a failed five-year compliance certification on Form 8854.

Do exit taxes apply to my house?
Mostly indirectly, most European exit taxes target shares. But property feeds the US net-worth test and Canada's deemed disposition, and is usually still taxable where it sits when you sell.

Can I defer an exit tax?
Frequently within the EU/EEA. Germany, France, and Spain all offer deferral or instalments for EU/EEA moves; non-EU/EEA moves typically mean paying upfront, but this varies by country and treaty.

Model the move before you make it

Planning a move between markets? The exit tax in your departure country and the entry rules in your destination need to be modelled together, before you buy or sell. JanusHermes maps cross-border property, tax, and residency across 50+ countries, start with listings and country intelligence on JanusHermes.

This is general information, not tax or legal advice, and exit-tax thresholds are indexed and change yearly. Model your specific position with a cross-border tax adviser before relocating. This topic involves significant financial consequences, professional, jurisdiction-specific advice is essential.

A note on the numbers: where no source is named, the market figures in this article (prices, yields, costs) are indicative estimates compiled from publicly available market data and industry reporting at the time of writing. Markets move and rules change, so treat them as a starting point and verify current figures with official sources before acting on them.