Anyone who moves their residence abroad pays tax in many countries on a sale that never took place. This country comparison of the exit tax (in Germany: Wegzugsteuer) shows for 17 countries whom the rule affects, which assets it covers, which rate applies and when the tax is deferred or lapses. It adds a uniform calculation example and the countries that have no exit tax but continue to tax emigrants for a while.
The German rule under § 6 Foreign Tax Act (Außensteuergesetz, AStG), with instalments, return and special cases, is covered in separate articles to which this overview refers at the relevant points, for example the basic article on the exit tax on GmbH shares.
The Key Point: Tax on a Fictitious Sale
Germany taxes shares in corporations (Kapitalgesellschaften) from a holding of 1 % on emigration as if they had been sold at fair market value (gemeiner Wert) (§ 6 (1) AStG, § 17 (1) Income Tax Act (Einkommensteuergesetz, EStG)). For a GmbH worth EUR 1 million with acquisition costs of EUR 25,000, that comes to around EUR 278,000, although not a single euro of purchase price has been received.
The reason is simple: on emigration, the right to tax future capital gains usually passes to the new country of residence. The previous country therefore settles the account beforehand. Where emigration is treated as a sale, there is a liquidity trap: the tax arises on a paper value. Anyone who cannot or does not want to sell their shares pays from other assets.
Three Models of Exit Tax in International Comparison
In the firm’s assessment, three models can be distinguished:
- Immediate taxation as a fiction. Emigration counts as a sale. This is how Germany, Austria, Canada, South Africa and Poland, for example, work. Whether the tax is deferred is, depending on the country, a right, a discretionary decision or not provided for at all.
- Assessment, collection only on sale. The tax is assessed and left pending, in some cases with remission after a period has expired. Examples are the Netherlands, France and Belgium.
- No exit tax, but trailing tax liability. The United Kingdom, Sweden and Finland keep the emigrant in the net for a certain time. Only gains actually realised are then taxed.
Within the EU, too, the rules differ considerably, above all in thresholds and deferral. Many countries defer the tax on a move to another EU or EEA state, but not on a move to a third country, or only against security.
Exit Tax Country Comparison: Trigger, Assets and Rate
The following overview of exit taxes by country covers only countries for which the firm has evaluated evidence. If a country is missing, that does not mean it has no exit tax. “Open” means that no reliable evidence is available.
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| Country | Who is affected | What is covered | Rate |
|---|---|---|---|
| Germany | unlimited tax liability for 7 of 12 years | shares of 1 % or more in corporations; investment funds from 1 % or EUR 500,000 acquisition costs per fund | approx. 28.5 % (partial income method (Teileinkünfteverfahren), top rate incl. solidarity surcharge) |
| Austria | every emigrant, no value threshold in the wording | capital assets, derivatives, cryptocurrencies | 27.5 % |
| Netherlands | holding of 5 % or more (aanmerkelijk belang) | shares; also pension and annuity entitlements with tax relief | Box 2: 24.5 % up to EUR 68,843, above that 31 % |
| France | 6 of 10 years; shares from EUR 800,000 or 50 % profit share | latent gains | open |
| Spain | 10 of 15 years; shares over 4 million euros or over 25 % with a value over 1 million euros | shares and fund units | 19–30 % progressive |
| Denmark | 7 of 10 years; holdings from DKK 100,000 | shares and receivables | 27 %, above DKK 67,500 42 % |
| Norway | latent gain above an allowance (amount open) | shares, funds, options, derivatives | open (factor for 2026 not documented) |
| Poland | change of residence; exemption threshold PLN 4 million | unrealised gains | 19 % |
| Belgium | transfer of residence | financial assets | open |
| Italy (bill only) | 6 of 10 years; assets from EUR 800,000; emigration from 2027 | holdings, securities, funds, precious metals etc.; not real estate | 26 %; government bonds 12.5 % |
| Canada | emigrants; reporting from CAD 25,000 | almost all assets, excluding Canadian real property and retirement savings | Ontario, top rate approx. 26.76 % |
| USA | only on renouncing citizenship or a long-held green card; from 2 million USD net worth or average tax above USD 211,000 (2026) | worldwide assets; exclusion amount USD 910,000 | open |
| Australia | end of residence | assets other than Australian real property and similar | open |
| Japan | 5 of 10 years; securities from JPY 100 million | securities, derivatives | 15.315 % (inhabitant tax open) |
| South Korea | 5 of 10 years; major shareholders; from 2027 also foreign shares | shares | open |
| South Africa | end of residence | worldwide assets except South African real property | max. approx. 18 % |
| Israel | end of residence | deemed disposal of assets | open |
Payment, Deferral and Lapse Compared
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| Country | When due, when not |
|---|---|
| Germany | 7 annual instalments on application, interest-free, usually against security, for every destination country; immediately due e.g. on sale, insolvency, distributions exceeding 1/4 of the value |
| Austria | EU/EEA: on application no assessment until sale (cryptocurrencies not mentioned in the wording); onward move to a third country triggers the tax; since 2026 annual proof from EUR 100,000 |
| Netherlands | EU/EEA: deferral automatic and interest-free, outside the EU/EEA in some cases against security; assessment for holdings unlimited in time |
| France | deferral automatic or on application with security; remission after 2 years (value below EUR 2.57 million) or after 5 years without sale |
| Spain | EU/EEA by election: tax only on sale, onward move or breach of reporting duties within 10 years |
| Denmark | interest-free deferral; outside the Nordic countries and the EU only against security |
| Norway | payment within 12 years; security possible even in the EEA; 70 % of every distribution repays the tax |
| Poland | return and payment by the 7th of the following month; deferral not established |
| Belgium | EU/EEA and treaty states with recovery assistance: deferral until sale; lapse after 24 months without sale |
| Italy (bill only) | payment within 180 days; deferral EU 5, cooperating states 10 years against 50 % down payment and security; lapse without sale or on inheritance |
| Canada | deferral on application without interest; security only from CAD 16,500 federal tax |
| USA | payment deferral can be elected |
| Australia | election: no immediate tax, the assets then remain subject to Australian tax |
| Japan | deferral 5, up to 10 years, against security |
| South Korea | foreign shares up to KRW 500 million exempt |
| South Africa | no deferral mentioned |
| Israel | deferral until sale can be elected (as of 2019) |
For Germany and the basics of most countries, statutory texts or official guidance notes form the basis; many tax rates, by contrast, come from professional articles and summaries. Italy’s exit tax so far exists only in the bill for the 2027 Budget Law, and the sources disagree on whether the EUR 800,000 threshold applies to all assets or only to financial assets. How the seven annual instalments are applied for in Germany and when they fall away is explained in the article on paying the German exit tax in instalments.
Calculation Example: EUR 1 Million Value, EUR 25,000 Acquisition Costs
The uniform example is based on assumptions: a holding worth EUR 1,000,000, acquisition costs of EUR 25,000 and thus EUR 975,000 hidden reserves, top tax rate, all thresholds other than those stated met, no church tax. Double taxation and credit in the country of arrival are not taken into account. It is a rough calculation, not a tax assessment.
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| Country | Rate in the example | Tax | % of value | Remark |
|---|---|---|---|---|
| Denmark | up to 42 % | up to approx. EUR 409,500 | approx. 40.9 % | upper limit, brackets not converted |
| Netherlands | 24.5 / 31 % | EUR 297,775 | 29.8 % | deferred within EU/EEA |
| Germany | 28.485 % | EUR 277,729 | 27.8 % | approximation; 7 instalments of EUR 39,676 |
| Austria | 27.5 % | EUR 268,125 | 26.8 % | EU/EEA no assessment |
| Canada (Ontario) | approx. 26.76 % | approx. EUR 260,910 | 26.1 % | not recalculated |
| Italy (bill only) | 26 % | EUR 253,500 | 25.4 % | status of the bill |
| Poland | 19 % | EUR 185,250 | 18.5 % | PLN threshold not converted |
| South Africa | approx. 18 % | approx. EUR 175,500 | 17.6 % | top rate |
| Japan | 15.315 % | EUR 149,321 | 14.9 % | only from JPY 100 million; inhabitant tax open |
| Spain | – | EUR 0 | 0 % | EUR 1 million is not above the threshold |
| France | open | open | open | rate not clarified; remission after 2 or 5 years possible |
| Norway | open | open | open | rate and allowance not clarified; payment over 12 years |
Two lessons follow. First, it is not the rate alone that counts but also the threshold: Spain does not tax this example at all. Second, the burden depends on the ratio of gain to value. If EUR 800,000 of the value consists of acquisition costs, the same emigration costs only EUR 56,970 in Germany, or 5.7 % of the value. The founder is therefore hit hardest: low share capital, high value and no sale in sight.
Countries Without an Exit Tax: No Free Pass
The United Kingdom taxes temporary non-residents in the year of their return if they were resident for 4 of 7 years and have been away for no more than 5 years. Sweden keeps citizens and long-term residents in the net for up to ten years on share gains, although tax treaties can limit this. Finland covers Finnish nationals as a rule in the year of departure and the three following years. The firm has not found an exit tax in these three countries. That is an assessment based on research, not proof that none exists.
In Switzerland, Singapore, the United Arab Emirates and Hong Kong, private capital gains are not taxable, so in the firm’s assessment an exit tax there would come to nothing. However, this only protects against the tax of the country of arrival. The German exit tax still applies on a move there. What these countries otherwise mean for new residents is shown in the country profiles (in German) Switzerland, Singapore and United Arab Emirates and in the country overview (in German). How special regimes for new residents in other countries interact with the German exit tax is covered in the article on non-dom status, and a specific destination country in the article on the exit tax on a move to Serbia.
When the Exit Tax Applies and When It Does Not
Length of residence. Anyone who has not had unlimited tax liability in Germany for at least seven of the last twelve years is not covered by § 6 AStG. France, Spain, Denmark, Japan and South Korea have similar periods.
It is not only the move that triggers the tax. § 6 (1) AStG also covers a gratuitous transfer to a person who is not subject to unlimited tax liability, for example a gift to a child abroad, as well as any other exclusion or restriction of Germany’s right to tax. More on this in the article on gifts before moving abroad.
Dropping below 1 % shortly before does not help. § 17 EStG looks back five years: it is sufficient if the holding amounted to at least 1 % during that period. More on this in the article on the exit tax on GmbH shares.
Return and Onward Move: EU States and Third Countries Compared
Several countries let the tax lapse if the emigrant comes back, but on different conditions:
- Germany: lapse on return within 7 years (+ no more than 5), only if the absence was temporary from the outset. Details are in the article on paying the German exit tax in instalments.
- Spain: in the case of a temporary move, the tax lapses on return within 5 years.
- Belgium: lapse on return within 24 months.
- Japan: cancellation on return during the deferral period.
- Italy (bill only): lapse on return is planned.
The onward move is just as important. Anyone who, after a first move within the EU, later leaves the EU loses the deferral in Austria and, within 10 years, in Spain. The first move is therefore not the last tax date.
Four European Countries in Detail
Austria covers every emigrant without a value threshold in the wording, namely capital assets, derivatives and cryptocurrencies (§ 27 (6) no. 1 Austrian Income Tax Act (EStG 1988)). The rule does not mention real estate. The sale of an Austrian property, however, remains taxable in Austria at 30 % after emigration, and in the firm’s assessment the main residence exemption can be partly lost if the order is unfavourable. The details are in the article on property sales in Austria and Germany.
Netherlands: Anyone holding at least 5 % is affected (aanmerkelijk belang). The tax is assessed by a protective assessment (conserverende aanslag), which is unlimited in time for holdings. Within the EU and EEA, deferral is automatic and interest-free. Pension and annuity entitlements with tax relief are also covered. On ongoing assets in the Netherlands, see the article on the Box 3 model (in German).
Spain’s exit tax only applies after 10 of 15 years of residence and to large holdings. On a move within the EU and EEA, the taxpayer can elect that the tax only arises on sale, onward move or breach of reporting duties within 10 years.
France covers, after 6 of 10 years of residence, shares from EUR 800,000 or a 50 % profit share. The tax is deferred automatically or on application against security and remitted after 2 years (for a value below EUR 2.57 million) or after 5 years without sale. Which rate exactly applies is currently open.
What the Exit Tax Does Not Cover and What Restructuring Achieves
The exit tax does not reach all assets. Most countries work with a catalogue, and what is not listed there triggers nothing on the move. In Germany, § 6 AStG refers only to shares within the meaning of § 17 EStG. Real estate, gold, cryptocurrencies and bank balances are not mentioned in the provision (assessment based on the wording). Not covered does not mean tax-free, however: a German property remains subject to tax after emigration as long as the ten-year period runs, see selling German property before emigrating. Real estate held in a GmbH does not help, because it is the GmbH share that is taxed, whatever the GmbH owns (assessment based on the wording of § 6 AStG, see transferring property to a GmbH before emigration). On gold and cryptocurrencies, see the articles on the speculation period on emigration and on cryptocurrency when moving abroad.
Investment Funds: The EUR 500,000 Threshold Applies per Fund
For investment funds held as private assets, a separate provision applies (§ 19 (3) Investment Tax Act (Investmentsteuergesetz, InvStG)). There, emigration only counts as a sale at fair market value if the investor held at least 1 % of the issued units in the last five years or, on emigration, holds units in the investment fund with acquisition costs of at least EUR 500,000. The wording refers to the individual fund: anyone who puts EUR 1.2 million into one ETF is covered; in the firm’s assessment, anyone who spreads the same amount over three funds with EUR 400,000 acquisition costs each is not. Indirectly held units count as well, and it is the acquisition costs that matter, not the market value, so a long-running savings plan can exceed the threshold unnoticed. Details are in the article on the securities account after emigration.
Limits of Restructuring
- Restructuring is itself a sale. Anyone who sells GmbH shares or fund units to move into real estate or gold pays the tax before emigration, only for real rather than notionally and without the seven instalments. Room for manoeuvre is offered above all by new money, which can be invested outside the catalogue from the outset (the firm’s assessment).
- Not covered does not mean tax-free. Real estate remains subject to tax in the country where it is located, and the increase in value of other investments moves to the country of arrival.
- The catalogue is not narrow everywhere. Canada, the USA and South Africa cover almost everything, the Italian bill also precious metals. Anyone who visibly restructures only because of emigration must also reckon with § 42 Fiscal Code (Abgabenordnung, AO) (the firm’s assessment).
Does a GmbH & Co. KG Help Against the Exit Tax?
It is often recommended to convert the GmbH into a GmbH & Co. KG before emigrating. The KG interest is not a share in a corporation and therefore does not fall under § 6 AStG. But the KG has business assets: if Germany’s right to tax them is excluded or restricted by the emigration, this counts as a deemed withdrawal (Entnahme), and for the entire business as a deemed business cessation (Betriebsaufgabe) (§ 4 (1) sentence 3 EStG, § 16 (3a) EStG).
In the firm’s assessment, the change of legal form (Formwechsel) therefore usually only replaces the exit tax with the tax on loss of taxing rights (Entstrickung) and is rarely cheaper. The change of legal form itself already costs tax, and afterwards a higher rate and worse instalment rules apply. An advantage is conceivable at most in a narrow group of cases, for example an operating KG whose business stays in Germany. How the tax on loss of taxing rights works is explained in the articles on exit taxation of business assets and on the emigration of partners.
What Helps Instead
In the firm’s assessment, what helps is less a change of legal form than careful calculation and the right sequence:
- examine the destination country before the move and consciously decide between EU/EEA and a third country,
- count the periods, in Germany the seven out of twelve years, abroad the respective residence periods,
- prepare deferral and security in good time,
- keep the return option open and think about a later onward move,
- clarify double taxation with the country of arrival separately.
Further typical mistakes are described in the article Moving away from Germany: tax traps and planning options (in German), planning for larger assets in the article Emigrating as a wealthy person (in German).
Status of Sources and Limits of This Comparison
For Germany, Austria and the basics of many countries, the comparison is based on statutory texts and official guidance notes, and for numerous tax rates on professional articles and summaries. The rates for Belgium, Australia, Israel, South Korea and the USA remain open, as do the French rate and the rate and allowance in Norway. Italy’s rule so far exists only as a bill, and the position may change by the end of the year. The source on Israel dates from 2019. Inheritance tax and extended limited tax liability (erweiterte beschränkte Steuerpflicht) are not covered here. The legal status of the sources evaluated is 02.11.2026, for the fund rule 03.11.2026. The overview is not exhaustive.
Conclusion
The exit tax is not a German peculiarity. Many countries tax emigration, but with very different thresholds, rates and deferral rules. In the calculation example, the range runs from zero in Spain to around 40.9 % of the value in Denmark. Anyone planning to emigrate should therefore calculate early, plan the sequence of move, sale and onward move, and also examine the country of arrival. In the firm’s assessment, converting into a GmbH & Co. KG usually only shifts the burden.
Frequently Asked Questions
Which countries have an exit tax?
Among the 17 countries evaluated, Germany, Austria, the Netherlands, France, Spain, Denmark, Norway, Poland, Belgium, Canada, Japan, South Korea, South Africa, Australia and Israel, among others, tax emigration. In the USA, the rule only applies to renouncing citizenship or a long-held green card. Italy plans an exit tax for emigration from 2027, so far only in a bill.
Are there countries without an exit tax?
The firm has not found an exit tax for the United Kingdom, Sweden and Finland. These countries, however, continue to tax emigrants for a while: the United Kingdom in the year of return, Sweden for up to ten years on share gains, Finland as a rule in the year of departure and the three following years.
Does the German exit tax also apply on a move to Switzerland or Dubai?
Yes, if the conditions of § 6 AStG are met. The fact that Switzerland and the United Arab Emirates do not tax private capital gains only protects against the tax of the country of arrival. In Germany, the seven annual instalments are available on application for every destination country, usually against security.
Does the EUR 500,000 threshold for funds apply to the whole securities account?
According to the wording of § 19 (3) InvStG, it does not; what matters is the acquisition costs per fund (the firm’s assessment). A restructuring shortly before emigration is, however, a genuine sale.
Which country has the highest exit tax?
In the calculation example with a value of EUR 1 million and acquisition costs of EUR 25,000, Denmark leads with up to around EUR 409,500. Thresholds and deferral are just as decisive, however: Spain does not tax the same example at all, and the Netherlands defer the tax automatically within the EU and EEA.
Can the exit tax be avoided with a GmbH & Co. KG?
Usually not. The KG interest does not fall under § 6 AStG, but the hidden reserves in the business assets are taxed via the exit taxation of business assets instead. In the firm’s assessment, an advantage is conceivable only in a narrow group of cases.
As of: November 2026. This overview is not exhaustive and does not replace advice in the individual case.
Attorney Dr. Johannes Fiala and the law firm, specialising in international inheritance law, tax law and asset protection in Munich, advise entrepreneurs, shareholders and investors on planning their emigration, from comparing destination countries and calculating the exit tax to preparing deferral and the return option. Dr. Fiala has published extensively on emigration and asset protection. Contact the firm without obligation to discuss your individual situation in an initial consultation.
