Exit tax legislation swept across the European Union in 2020, transposing the Anti-Tax Avoidance Directive into national law. Five years later, the rules are live in all 27 member states, yet enforcement, payment schedules, and thresholds diverge sharply. For founders holding appreciated equity, expats with investment portfolios, or retirees relocating to lower-tax jurisdictions, the practical cost of leaving varies by tens or hundreds of thousands of euros depending on departure country.
The directive targets unrealized capital gains on shares, intellectual property, and certain financial instruments when a tax resident moves abroad. The policy aim is to prevent base erosion by taxing latent gains before they escape national jurisdiction. In practice, implementation ranges from immediate cash settlement to decade-long deferrals, and from blanket application to carve-outs for intra-EU moves. This article maps the rules in four representative states and links to the Libaros calculator for scenario modeling.
France
France applies exit tax to individuals holding at least 50 percent of a company or assets exceeding €800,000 in value. Unrealized gains are taxed at the flat capital-gains rate of 30 percent (12.8 percent income tax plus 17.2 percent social charges) upon departure. Payment is due immediately unless the taxpayer moves to another EU or EEA state, in which case a deferral of up to 15 years applies, with annual declarations required. Interest accrues on deferred amounts at the statutory rate published by the Direction Générale des Finances Publiques.
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For a founder with €2 million in unrealized equity gains, the upfront liability is €600,000. If the individual relocates to Portugal under the new IFICI regime, the liability is suspended but not forgiven; it crystallizes if shares are sold or if the taxpayer moves outside the EU. Failure to file annual deferral forms triggers immediate collection. The French tax authority (DGFiP) has published guidance in Bulletin Officiel des Finances Publiques BOI-RPPM-PVBMI-30-30, updated January 2024.
Poland
Poland enacted exit tax in Article 30da of the Personal Income Tax Act, effective from January 2021. The rule applies to individuals who have been Polish tax residents for at least four of the preceding five years and hold assets with unrealized gains exceeding PLN 4 million (approximately €900,000). The tax rate is 19 percent on the gain. Uniquely, Poland allows a 10-year interest-free deferral for moves to any EU or EEA country, with payment in five annual installments starting in year six.
A Polish resident with €1.5 million in appreciated startup equity faces a €285,000 liability (19 percent of €1.5 million). If she moves to Thailand, the full amount is due within three months of departure. If she moves to Germany, she files a deferral election (PIT-EX form) and pays nothing until year six, then €57,000 annually for five years. The deferral lapses if she disposes of the asset or moves outside the EU during the deferral period. The Polish Ministry of Finance confirmed this interpretation in a binding tax ruling published in case 0115-KDIT3.4011.629.2023.1.MC, dated March 2024.
United Kingdom
The UK introduced a temporary exit charge in Finance Act 2019, targeting individuals who held UK residential property indirectly through offshore structures. The charge was repealed in Finance Act 2025, effective April 2025, following lobbying by the British Property Federation and criticism that it overlapped with existing capital gains tax on UK property disposals by non-residents. As of May 2025, the UK imposes no general exit tax on unrealized gains for individuals ceasing UK tax residence.
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However, UK-source gains remain taxable for five years after departure under the temporary non-residence rules (TTNR) if the individual was UK resident for at least four of the seven years before leaving and returns within five years. For example, a London-based founder who relocates to Dubai and sells UK company shares within five years pays UK capital gains tax at 20 percent (or 28 percent for carried interest) on the disposal, even as a UAE resident. The TTNR rules are codified in Taxation of Chargeable Gains Act 1992, sections 10A-10C, and HMRC guidance is in Capital Gains Manual CG26700.
Thailand
Thailand does not impose an exit tax on individuals leaving the country, as it operates a territorial tax system with remittance-based taxation for foreign-source income. However, in April 2026, the Thai Cabinet approved a departure tax of 300 baht (approximately €8) per international flight, levied on passengers rather than residents. The aviation industry warned the measure could reduce inbound tourism by 2 percent, according to a statement by the Tourism Council of Thailand published on 29 April 2026. The departure tax is unrelated to capital gains or wealth and does not affect tax residency planning.
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For expats relocating from an EU state to Thailand, the relevant exit tax is determined by the departure country. A French resident moving to Bangkok with €1 million in unrealized equity gains pays €300,000 to France upon departure (or defers if moving via an interim EU state). Thailand itself imposes no tax on the gain, and foreign-source capital gains remitted after one calendar year are not taxable under current Thai Revenue Code provisions. The Thai Revenue Department has not published guidance on exit tax coordination with EU states.
Exit tax liability hinges on departure jurisdiction, asset type, holding period, and destination country. The Libaros Freedom Score framework evaluates these variables across five dimensions: tax burden (immediate vs deferred payment), passport mobility (EU vs third-country moves), residency options (deferral eligibility), property rights (asset portability), and lifestyle (net cost of relocation). For founders and investors, the choice of interim residency, the timing of asset sales, and the structure of equity holdings can shift liability by six figures. The rules are live, the enforcement is real, and the planning window is now.