This guide gives an overview of “exit taxes” across Europe, specifically tailored for 2025/2026. Things are moving quickly (for example, at the time of writing it is unclear how things will turn out with a potential UK exit tax).
Exit taxation is a tax on the unrealized “on-paper” profit of your assets (like company shares) that you built up while living in a country, which is triggered at the moment you move your tax residency away. The “Moral” Behind It: The moral justification is that the country provided the infrastructure, legal system, education, and economic stability that allowed you to build that wealth; therefore, it reserves the right to tax the value created within its borders, even if you leave before “cashing in” (selling) those assets.
This article is particularly useful for startup founders and entrepreneurs holding significant equity, as well as investors and business angels with substantial shareholdings (like the 1% in Germany or 5% in the Netherlands) who plan to move their tax residency. It is also critical for high-net-worth individuals whose assets exceed national thresholds (like €800K in France) and long-term expatriates or “digital nomads” who may unknowingly trigger this tax after residing somewhere for 6-10 years. Finally, it serves as a quick reference for tax advisors and planners advising clients on cross-border relocation, especially given the critical 2025/2026 changes.
Before we compare, these are the most important terms you should know:
Exit Tax: A tax on the potential profit of your assets (primarily company shares). It is triggered simply by moving your tax residency out of the country, even if you have not sold any shares. It’s essentially a tax on “unrealized gains.” The moral jusitification is that the country you provided the infrastructure, legal system, education and general (economic) stability that allowed a person to build that wealth that is no being taxed. The country then reserves the right to tax the value created within its borders, even if you leave before selling those assets. There are loads of pros and cons, but we will leave that to others.
Unrealized Gains: The “on-paper” profit of your shares. It’s the difference between their current market value and the price you originally paid for them.
Threshold: The set of conditions that make you liable for the tax. This is usually a combination of how long you lived there (e.g., “6 of last 10 years”) and how much you own (e.g., “>€800K”).
Deferral: The option to postpone paying the tax bill. This is often automatically granted when moving to another EU/EEA country, but payment is usually required immediately if moving elsewhere (e.g., to the US or Dubai).
Forgiveness / Waiver: A rule that cancels your deferred exit tax bill after certain conditions are met. Common examples include not selling the shares for a set period (15 years in France) or moving back to the country (10 years in Spain).
Capital Gains Tax (CGT): This is the “normal” tax you pay on the actual profit when you finally sell your shares. Countries listed as “No Exit Tax” (like Portugal or Switzerland) will only tax you when you make this actual sale.
Special Cases (e.g., Sweden, UK): These countries don’t tax you for just leaving (no exit tax), but they “claw back” the right to tax you if you sell your shares within a few years of having left (e.g., Sweden’s 10-year rule).
Exit Tax Countries
France 🇫🇷
Threshold: Resident 6 of last 10 years AND (shares >€800K OR >50% ownership)
Deferral: Automatic for EU/EEA moves
Forgiveness: 15 years if shares not sold
Rate: 30% (12.8% + 17.2% social)
Sources: French Tax Authority | KPMG | Qualifisc
Germany 🇩🇪
Threshold: ≥1% shareholding in last 5 years
Deferral: 7-year installments for EU/EEA (with interest)
Rate: Up to 26.375%
NEW 2025: Also applies to investment funds ≥€500K
Sources: German Finance Ministry | Grant Thornton | Noerr
Netherlands 🇳🇱
Threshold: ≥5% substantial interest
Deferral: Automatic, interest-free for EU/EEA
Key benefit: Tax only due when shares sold
Rate: 26.9% (24.5% on first €67K)
Sources: NedTax | PwC | People & Media
Spain 🇪🇸
Threshold: Resident 10 of last 15 years AND (shares >€4M OR >25% of company >€1M)
Deferral: 10-year for EU/EEA
Forgiveness: Tax waived if return within 10 years
Rate: 19-30%
Sources: Gentile Law | IR Global | Kinship
Denmark 🇩🇰
Threshold: Resident 7 of last 10 years AND shares >DKK 100,000 (~€13,400)
Deferral: Available for EU/EEA
Note: Very low threshold
Rate: 27-42%
Sources: Danish Tax Agency | Skat.dk | PwC
Norway 🇳🇴
Threshold: Unrealized gains >NOK 3M (NEW 2025)
Deferral: 12-year with installments (interest-free)
Rate: 37.84%
NEW 2025: 70% of dividends trigger proportional payment of the deferred tax
Sources: Norwegian Tax Admin | Government | KPMG | Schjødt
Belgium 🇧🇪
2025: NO exit tax
Jan 1, 2026: 10% exit tax starts
2-year window: No tax if shares not sold within 24 months
ACTION: Move by December 31, 2025
Sources: KPMG | EY | PwC | BDO
Italy 🇮🇹
Threshold: >25% voting or >5% listed
Deferral: Available for EU/EEA
Rate: 26%
No Exit Tax Countries
Portugal 🇵🇹
No exit tax on unrealized gains for individuals
Capital gains: 28% on actual sale only
Very founder-friendly
Ireland 🇮🇪
No exit tax on individuals
CGT: 33% on actual disposal only
Note: Ireland has corporate exit tax and fund exit tax
Switzerland 🇨🇭
No exit tax on private assets
Wealth tax while resident
Clean exit
Austria, Estonia, Latvia, Lithuania, Poland, Czech Republic, Greece 🇦🇹🇪🇪🇱🇻🇱🇹🇵🇱🇨🇿🇬🇷
No exit tax on unrealized gains
CGT on realized gains only
Special Cases
Sweden 🇸🇪
NO EXIT TAX on unrealized gains
10-year rule: Swedish CGT applies to REALIZED gains (actual sales) for 10 years after leaving
Exit tax proposals: Cancelled 2023
UK 🇬🇧
Current: No exit tax on unrealized gains
Temporary non-resident rule: If you return within 5 years, CGT applies to REALIZED gains made while abroad
⚠️ Nov 2025: Chancellor considering exit tax (proposal only)
Quick Reference
| EXIT TAX | NO EXIT TAX | SPECIAL CASE |
|---|---|---|
| France | Portugal | Sweden (10-yr realized gain rule) |
| Germany | Ireland | UK (Temp. non-resident rule) |
| Netherlands | Switzerland | |
| Spain | Austria | |
| Denmark | Estonia | |
| Norway | Latvia | |
| Italy | Lithuania | |
| Belgium (from Jan 1, 2026) | Poland | |
| Czech Republic | ||
| Greece | ||
| Belgium (until Dec 31, 2025) |
Critical 2025 Changes
Belgium: Last year without exit tax – move by Dec 31, 2025.
Norway: New NOK 3M threshold, 12-year deferral, and dividend rule now in effect.
Germany: Fund rules expanded.
UK: Exit tax under consideration.
Planning Essentials
EU/EEA vs Non-EU:
- EU/EEA: Deferral, often interest-free.
- Non-EU: Immediate payment, collateral often required.
Valuation:
- Based on fair market value at departure.
- Last funding round ≠ tax valuation.
- Document methodology.
Timing:
- Plan 18-24 months ahead.
- Belgium: Move by Dec 31, 2025.
Return Clauses:
- France: 15-year forgiveness
- Spain: 10-year forgiveness (if you return)
- Norway: 12-year installment plan (waived if you return)
Current as of November 2025. This article is for informational purposes only. Consult qualified tax advisors in both countries before relocating.
