Before you leave

Exit tax in 2026: what it costs to leave your country

Several European countries tax the unrealised gains on your shares on the day you stop being resident, even if you sell nothing. For a business owner, that bill can be larger than years of tax savings in the new country. Here is how it works in Spain, Germany, France, Italy and the United Kingdom, and what you can do about it.

Updated: 7 min readReviewed by the Erase.tax team

Key facts

Spain
Shares worth over €4 million, or over 25% of a company worth over €1 million
Germany
At least 1% of a company in the last five years; investment funds too since 2025
France
Securities over €800,000, or at least 50% of a company's profits
Italy
No general exit tax for individuals; applies to businesses
United Kingdom
No exit tax; the October 2026 Budget did not introduce one

The five countries at a glance

Country Who pays Years of prior residence How it is taxed Deferral
Spain Shares worth over €4 million, or over 25% of a company worth over €1 million 10 of the last 15 years As a capital gain, at 19% to 30% EU/EEA move: only taxed if you sell or leave the EU/EEA within 10 years. Temporary moves for work or to treaty countries: on request
Germany At least 1% of a company at any time in the last five years; fund units of at least 1% or €500,000 since 2025 7 of the last 12 years 60% of the gain at your personal rate Seven interest-free annual instalments, usually with security
France Securities over €800,000, or at least 50% of a company's profits 6 of the last 10 years 12.8% income tax plus 18.6% social charges in 2026 Automatic within the EU/EEA, the UK and the US; on request with guarantees elsewhere, such as the UAE
Italy No general exit tax for individuals with non-business shareholdings – Applies to businesses that transfer their residence –
United Kingdom No exit tax for individuals – Gains on return if you come back within five years –

Spain

The Spanish exit tax applies when you stop being resident after having been resident for at least 10 of the last 15 tax years, and either your shares and holdings are worth more than €4 million in total, or you own more than 25% of a company and that holding is worth more than €1 million. In the second case, only that holding is taxed.

The gain, market value minus acquisition cost, is taxed in your last Spanish tax return as savings income, at 19% to 30% in 2026.

There are two ways to defer it:

  • Moving to another EU or EEA country with effective exchange of information. You can opt for a special regime: you only pay if, within 10 years, you sell the shares, stop being resident in the EU or EEA, or fail to notify the tax agency.
  • Temporary moves for work to a country that is not a tax haven, or for other reasons to a country with a treaty that includes exchange of information. The tax is deferred on request, and is cancelled if you become a Spanish taxpayer again within five years without having sold.

If you return to Spain without having sold, you can claim back what you paid, with interest. A further rule matters for Spanish nationals: if you move to a non-cooperative jurisdiction, you remain a Spanish taxpayer in the year of the move and the following four. The UAE, Cyprus and El Salvador are not on that list.

Germany

The German Wegzugsteuer applies if you held at least 1% of a company, directly or indirectly, at any time in the last five years, and you had unlimited tax liability in Germany for at least 7 of the last 12 years. The trigger is giving up your German residence or habitual abode, but also other events that restrict Germany's taxing rights, such as gifting shares to someone abroad.

The deemed gain is the difference between fair value and cost. Under the partial income method, 60% of it is taxed at your personal rate. Since 2025, the tax also covers investment fund units when you hold at least 1% of a fund or paid at least €500,000 for units of one fund.

Since 2022 there is no longer an indefinite interest-free deferral for moves within the EU: EU and non-EU destinations are treated alike. On request you can pay in seven interest-free annual instalments, usually against security. If you return to Germany within seven years, a period that can be extended by five, the tax can be reversed under certain conditions.

France

The French exit tax, article 167 bis of the tax code, applies if you were tax resident in France for at least 6 of the last 10 years and, on departure, you hold securities worth more than €800,000 or at least 50% of a company's profits.

The gain is taxed at the flat tax: 12.8% income tax plus social charges. In 2026 those social charges rose to 18.6% on most capital income, so the total flat tax is 31.4%.

  • EU and EEA, and countries with tax-assistance and recovery agreements with France, such as the UK and the US: automatic deferral, without guarantees.
  • Other countries, such as the UAE, Switzerland or El Salvador: deferral on request, with a guarantee.
  • Non-cooperative states: no deferral.

The tax is cancelled if you do not sell the securities for 2 years after leaving, when they are worth €2.57 million or less, or for 5 years above that.

Italy

Italy has no general exit tax for individuals who hold shares outside a business: changing residence is not a taxable event, and the gain is only taxed if and when you sell, under the applicable treaty. The Italian exit tax, article 166 of the income tax code, applies to those carrying on a business activity, companies and entrepreneurs, that transfer their tax residence abroad, on the latent gains of the business assets.

United Kingdom

The UK has no exit tax for individuals. The Autumn Budget of 28 October 2026 did not introduce one, nor did it raise capital gains tax rates, despite months of speculation.

What does apply are the temporary non-residence rules. If you were solely UK resident for at least 4 of the 7 tax years before leaving and your period abroad lasts five years or less, gains you realise while abroad on assets you held before leaving are taxed in the year you return. Companies that move their tax residence out of the UK face a corporate exit charge.

How to plan for it

  1. Check the thresholds and dates now. The years of residence and the value are measured on the day your residency changes.
  2. Value your shares properly with a defensible method: it is the base of the tax and of any later dispute.
  3. Choose the destination with the exit tax in mind. For Spanish and French residents, an EU destination such as Cyprus allows deferral; a non-EU one such as Dubai usually means paying or guaranteeing.
  4. Time the move. In Spain and France, a move before reaching the years of residence or the threshold changes everything.
  5. Do not restructure at the last minute without advice. Transfers of shares just before leaving are reviewed closely by tax authorities.

We calculate the exit tax at the start of every assessment, so you decide with all the numbers on the table. Compare destinations in Cyprus vs Dubai vs El Salvador.

Frequently asked questions

What is an exit tax?

A tax on the increase in value of your assets, usually shares, calculated as if you had sold them on the day you stop being tax resident. You pay it even if you keep the shares, unless a deferral applies.

Does moving to another EU country avoid the exit tax?

It often softens it. Spain lets you opt for a regime under which you only pay if, within 10 years, you sell the shares or leave the EU. France grants an automatic deferral for moves within the EU/EEA and to countries, such as the UK and the US, that have tax-assistance and recovery agreements with it. Germany, since 2022, treats EU and non-EU moves the same and allows payment in seven annual instalments.

Is there an exit tax in the UK in 2026?

No. The Autumn Budget presented on 28 October 2026 did not introduce an exit tax or change capital gains tax on emigration. The temporary non-residence rules still apply: if you return within five years, gains made abroad on assets you held before leaving can be taxed on your return.

Can I avoid the exit tax legally?

You can plan for it: check whether you reach the thresholds, value the shares properly, choose a destination and a timing that allow deferral, and consider restructuring before leaving with proper advice. What you cannot do is ignore it: it is calculated on the date your residency changes.

Official sources and references

  1. BOFiP: list of states with administrative and recovery assistance clauses (BOI-ANNX-000508)
  2. Agencia Tributaria: special regime for capital gains on change of residence (Spain)
  3. Guía Fiscal: exit tax on change of residence (Spain, September 2026)
  4. Grant Thornton Germany: Wegzugsteuer overview
  5. Hayot Expertise: exit tax 2026, article 167 bis CGI (France)
  6. Club Patrimoine: CSG increase on capital income in 2026 (France)
  7. Fiscomania: exit tax for individuals in Italy and Europe (July 2026)
  8. Macfarlanes: the Autumn Budget 2026 (UK)
  9. HMRC HS278: temporary non-residents and capital gains tax (2026)

Figures reviewed on the date shown above. Rules change: always check the source.

This guide is general information, not tax or legal advice. Every case needs individual analysis.