Governments around the world are becoming increasingly aggressive in how they tax their citizens, particularly when those citizens attempt to leave. What was once a clear boundary between tax residency and non-residency is now giving way to a growing web of rules that continue to apply long after an individual has relocated. While this approach was once associated primarily with the United States, it is now gaining momentum across Europe.
From France to Spain, Germany, and Norway, several European governments are introducing or strengthening exit taxes and extended tax obligations after residency ends. These measures are designed to prevent high-net-worth individuals from relocating to low-tax jurisdictions without first settling their domestic tax liabilities. Some countries are even exploring the taxation of worldwide income for multiple years after an individual departs, effectively extending their fiscal reach beyond borders.
Meanwhile, countries such as Canada and Australia have long applied departure tax regimes that treat an individual’s assets as sold at the time of exit, triggering taxation on unrealised gains. In the United Kingdom, a different route has been taken: instead of adopting a formal exit tax, the government has abolished its long-standing non-domicile regime and shifted toward full global income taxation for new and returning residents.
For high-net-worth individuals, fiduciary planners, and corporate structuring professionals, this marks a significant shift. Exiting a country is no longer a clean break. It now requires forward planning to manage not just the timing of departure but the continuing tax exposure that may follow.
What is Exit Tax?
Exit tax refers to a levy on individuals who give up their tax residency, requiring them to pay tax on unrealised capital gains as if they had sold their assets immediately before departure. Countries like the United States, Canada, and Australia have long enforced these rules to prevent individuals from leaving without paying tax on accumulated gains. Now, several European countries are adopting similar measures. France, Spain, Germany, and Norway have introduced or expanded exit tax regimes, reflecting a broader move toward long-term global tax enforcement, even after relocation.
A Fragmented but Growing Trend Across Jurisdictions
While there is no unified approach to taxing departing residents, the direction is unmistakable: more countries are finding ways to maintain tax authority over individuals even after they leave. Some governments focus on taxing unrealised capital gains at the point of exit. Others go further, extending global income tax liability for years after residency ends or imposing reporting obligations to track wealth abroad. This is creating a patchwork of exit-related rules that corporate and fiduciary advisors must navigate with increasing precision.
Although the legal tools differ, the underlying goal is the same, safeguard the national tax base and slow the outflow of mobile capital. Below is a breakdown of how specific countries are currently approaching the issue.
France – Enhanced Exit Tax Enforcement
In late 2024, French lawmakers proposed an amendment to restore stricter exit tax provisions, reintroducing elements of the original 2011 framework. The tax applies to individuals who have been French tax residents for at least six of the previous ten years and who hold significant shareholdings. Tax is levied on unrealised capital gains as if assets were sold immediately before departure. Deferral may be available for individuals relocating within the EU or to countries that have qualifying tax treaties with France.
Spain – Exit Tax and Extended Global Income Enforcement
Spain introduced its exit tax in 2015. It applies to individuals who have been tax residents in Spain for at least ten of the previous fifteen years and who hold company shares or ownership stakes above certain thresholds. Additionally, those who move to jurisdictions classified as tax havens remain liable for Spanish global income tax for up to five years following departure.
Germany – Reinforced Capital Gains Exit Tax
Germany imposes an exit tax on individuals who hold at least one percent of a company’s shares. The tax is calculated on unrealised gains as if the shares were sold the day before departure. In 2025, tax authorities have intensified scrutiny of outbound fund investors and high-ownership individuals, particularly where assets are opaque or held offshore. Although no new legislation has been passed this year, enforcement has become more rigorous. Deferral options are available but depend on the destination country and specific treaty protections.
Norway – From Deferred to Predictive Enforcement
Norway introduced its exit tax regime in 2022. Originally applied only upon realisation, new rules implemented in 2024 require the tax to be settled within twelve years of departure, regardless of whether assets are sold. A three million NOK exemption applies, and taxpayers may choose instalment-based payments. Special provisions are available for cases involving inheritance or death. Norway’s model is considered among the most structured in Europe.
United Kingdom – Global Income Tax Without Exit Tax
The UK does not impose a formal exit tax. However, in April 2025, it abolished its long-standing non-domicile regime and replaced it with the Foreign Income and Gains (FIG) system. Under the new rules, all new and returning residents are taxed on their worldwide income and gains from day one, although a four-year exemption is available through annual elections. Former non-doms may also access temporary repatriation facilities. These changes reflect the UK’s broader move toward full-scope global taxation.
Canada – Departure Tax with Longstanding Framework
Canada continues to apply its long-standing departure tax, which treats most capital assets as disposed of at fair market value the day before an individual gives up tax residency. Exemptions apply to Canadian real estate, registered pensions, and certain insurance plans. Tax deferral is available if the departing individual provides acceptable security to the Canada Revenue Agency. No major reforms have been introduced in 2025, but the regime remains firmly enforced.
Australia – Deemed Disposal and Deferred Tax Triggers
Australia’s departure tax operates under a deemed disposal rule, whereby capital assets are treated as sold at market value when tax residency ends. Individuals may defer the tax, but payment becomes due once the asset is sold or if the person resumes Australian residency. Exemptions apply to Australian real property and select business assets. While no major reforms have occurred in 2025, tax authorities have increased oversight of outbound structures involving trusts and offshore holding companies.
Adapting to Tax Changes: What Fiduciary Advisors and HNWIs Should Do
For fiduciary advisors and high-net-worth individuals (HNWIs), the expanding scope of exit taxes and post-residency tax rules calls for a more proactive, jurisdiction-sensitive approach to planning. Advisors should conduct thorough pre-exit assessments that include asset valuation, liquidity analysis, and a review of applicable treaties or exemptions in both the home and destination countries. Structures should be tailored to minimise exposure to unrealised gain taxation, while also allowing for flexibility if rules change after relocation.
For HNWIs, adapting means understanding that relocation is no longer just a lifestyle decision, it is a financial strategy that requires timing, transparency, and professional oversight. The most effective protection today lies not in secrecy, but in anticipating enforcement trends and working with trusted advisors to build compliant, future-proof frameworks that preserve long-term wealth.
Leaving Means Planning
Relocating to another country is no longer just a personal decision, it’s a financial event that can come with serious tax consequences. As more countries enforce exit taxes or extend global tax obligations, wealthy individuals face increasing complexity when moving abroad.
This growing trend makes early planning essential. Whether it’s valuing assets, restructuring holdings, or understanding treaty protections, both individuals and their advisors must think ahead. Leaving a country now means more than packing bags, it means preparing for the tax impact too.
