An exit tax is a charge on gains you have not yet realised, triggered by the transfer of your tax residence out of a country. The country treats your departure as a deemed disposal of certain assets, usually shares, and taxes the growth accrued while you were resident. Most regimes then allow deferral, sometimes with security, until the asset is actually sold. Five European countries apply one to individuals in 2026, and the details differ enough that the same departure can cost nothing in one and a seven-figure sum in another.
Netherlands: the protective assessment
A Dutch resident who holds a substantial interest, meaning at least 5 percent of the shares, voting rights or profit rights in a company, receives a conserverende aanslag on emigration. It is a protective assessment on the deemed gain in box 2 at the time of departure. Payment is deferred, without security for moves within the EU or EEA and with security otherwise, until the shares are sold, a dividend distribution reaches a set level, or the company is liquidated.
The Belastingdienst is explicit that most protective assessments lapse after ten years, but the one for a substantial interest is unlimited in time. The Netherlands also issues protective assessments for pension and annuity tax relief claimed while resident, which lapse after ten years if you comply with Dutch rules.
Germany: section 6 of the Außensteuergesetz
Germany's exit tax under section 6 AStG applies to anyone who has been subject to unlimited German tax liability for at least seven of the previous twelve years and who holds at least 1 percent of a corporation as a private asset. Ending German residence is treated as a sale at fair market value. The gain is taxed under the partial income method, so 60 percent of it enters the progressive scale, which reaches 45 percent plus the solidarity surcharge.
Since the 2022 reform the tax can be paid in seven interest-free annual instalments on request, usually against security, whether the move is inside or outside the EU. The charge is cancelled if the person becomes fully taxable in Germany again within seven years, extendable to twelve, provided the shares were not sold in the meantime.
France: the 2074-ETD return
France's exit tax applies to someone who has been French tax resident for at least six of the ten years before the transfer and who holds shares worth at least 800,000 euros in total or representing at least 50 percent of a company's profits. Unrealised gains, earn-out receivables and deferred gains are declared on form 2074-ETD in respect of the year of departure.
Payment is automatically deferred for moves to an EU member state or to a country that has signed an administrative assistance and recovery agreement with France. Other moves require a request and security. The charge lapses if the shares are still held after two years, or five years for portfolios above 2.57 million euros, or if you return to France.
Belgium: new from 1 January 2026
The law of 6 April 2026, published on 21 April 2026 and applicable from 1 January 2026, introduced a 10 percent tax on capital gains on financial assets for individuals and an exit tax alongside it. When a Belgian resident transfers residence abroad, unrealised gains on covered financial assets, including listed and unlisted shares, bonds, fund units, crypto-assets and unit-linked insurance, accrued since 1 January 2026 are treated as realised.
Because the regime only taxes growth from 1 January 2026, historic gains built up before that date are outside it. Two Royal Decrees of 18 May 2026 add filing detail, and the tax authority has not yet published its full guidance on deferral and security, so anyone leaving Belgium in 2026 should plan on the statutory text and confirm the mechanics before the departure date.
Spain: article 95 bis
Spain's exit tax under article 95 bis of the personal income tax law applies to someone who has been Spanish tax resident for at least ten of the fifteen years before the last year of residence, and whose shares or fund units are worth more than 4 million euros in total, or whose stake in a single entity exceeds 25 percent with a value above 1 million euros. The unrealised gain is included in the final Spanish return at savings income rates, which run up to 30 percent for 2026.
Deferral is available for temporary work-related moves and for moves to a country with a tax treaty containing an exchange of information clause. If the person returns to Spain within five years without having sold the assets, or ten years for work moves, the charge is cancelled and any tax paid is refunded.
How to compare your own exposure
Three questions settle most cases. How many of the last ten to fifteen years were you resident, because that decides whether Germany, France or Spain can charge at all. What do you hold and at what percentage, because the Dutch 5 percent and German 1 percent thresholds are low while the French and Spanish value thresholds are high. And where are you going, because an EU or EEA destination usually unlocks automatic deferral while a third country usually means security or immediate payment.
