Your share portfolio does not change when you change country. The State entitled to tax its gain does, and cross-border tax planning starts there.
Among tax planning fundamentals, a move is the one event where a date weighs as much as an amount. Leave France in 2026 with a EUR 400,000 unrealised gain, and the same EUR 125,600 charge can fall due on a sale, later, or on the day you leave. The order of events decides.
Cross-border tax planning is the work of placing a dated event (a departure, an arrival, a sale) in the right order, because the order decides which State taxes.
In the three conventions read here (UK-US, Article 13(5); UK-Spain, Article 13(6); UK-France, Article 14(5)), a share gain is taxable only in the seller's State of residence on the day of the sale.
| Question | Income taxed twice (a flow) | A move (an event) |
|---|---|---|
| What you face | Two bills on one income | A date that shifts taxing rights |
| What decides | Relief rules | The order of events |
| When to act | Once the income has arisen | Before residence changes |
Three limits follow: the State you leave may tax the departure, reach back after a short absence, or keep a treaty right.
Which State counts you as resident on a given day depends on each State's own tax residency tests. Two States can claim you for the same period. This guide takes your residence dates as given.
An investor resident in France for more than six of the last ten years holds listed shares worth EUR 1,200,000, bought for EUR 800,000, and leaves in 2026.
According to the French tax administration (2026), the 2026 flat rates are 12.8% income tax plus 18.6% social levies: EUR 51,200 plus EUR 74,400 on the EUR 400,000 gain, a French charge of EUR 125,600.
| Scenario | French charge | When payable |
|---|---|---|
| A. Sells in 2026, then moves | EUR 125,600 | Ordinary rules for a resident's sale |
| B. Moves to the UK, sells within 2 years | EUR 125,600, deferred automatically | When the sale ends the deferral |
| C. Moves to the UK, holds beyond 2 years | EUR 125,600, deferred, then discharged | Not payable; a later sale is taxed where you live |
| D. Moves to the UAE, no deferral request | EUR 125,600 | On departure, with no sale |
The order changes when the charge falls and whether it survives, not its amount. Even in C, taxation does not end: a later UK sale is taxed at 18% or 24% (rates from 6 April 2026).
These amounts are an illustration computed from the official 2026 rates, not official figures.
According to the OECD (2025), fourteen OECD countries, the United States among them, levy exit taxes that deem “a disposal of assets at market value immediately before departure”. They mostly hit shares, generally at the ordinary rate on gains, after a minimum residence period.
| Country | What is caught | Prior residence | Deferral or discharge | Rule as at |
|---|---|---|---|---|
| France | Portfolio above EUR 800,000, or rights to at least 50% of a company's profits | 6 of 10 years | Discharged after 2 years held (5 from EUR 2.57 million) | 2026 |
| Spain | Shares above EUR 4,000,000; holdings above 25% worth over EUR 1,000,000 | 10 of 15 tax periods | 5-year deferral on request | 2025 |
| Germany | Holdings of at least 1% | 7 of 12 years | Lapses on return within 7 years, shares kept | Current statute |
| Canada | Certain property, shares included, deemed sold at market value | None; property held on arrival excluded if resident 60 months or less in 10 years | Deferral by election, without interest, until sale; security may apply | 2026 |
| Norway | Latent gains above NOK 3,000,000 | Not covered here | Paid within 12 years | Moves from 20 March 2024 |
Each line: the country's own tax authority or statute, read October 2026.
The French exit tax is not reserved to business owners: a listed portfolio above EUR 800,000 is enough (2026).
The United States does not tax a move. It taxes giving up citizenship, or a green card held in at least 8 of the last 15 tax years. According to the IRS (2025), the tests for a covered expatriate for 2026 include average annual net income tax above USD 211,000 over five years, or net worth of USD 2 million or more; USD 910,000 of the deemed gain is excluded. Deferral costs interest, security and a waiver of treaty rights.
The United Kingdom is not among the countries the OECD lists: on a return, its rules look back at gains realised during an absence of five years or less.
Some countries treat a departure as a disposal of assets at market value immediately before you leave. These exit taxes mostly hit shares, after a minimum period of residence.
Canada (2026) treats a newcomer's property as reacquired at fair market value on arrival, and Norway (moves since 20 March 2024) taxes on exit only value built up during residence. Elsewhere, the United Kingdom included, no general rebasing rule was identified in the official sources read, so the new State may tax gain accrued before you came.
Several States offer regimes for new residents, listed without ranking, each line from its national source.
| Regime | Headline figure | Duration | Main access condition | Rule as at |
|---|---|---|---|---|
| United Kingdom, 4-year foreign income and gains regime | Relief on eligible foreign income and gains | 4 tax years | 10 prior tax years of non-UK residence | Since 6 April 2025 |
| Italy, substitute tax | EUR 300,000 a year on foreign income; EUR 50,000 per family member | Up to 15 years | Non-resident at least 9 of the 10 prior tax periods | Arrivals from 1 January 2026 |
| Spain, inbound workers | Employment income: 24% to EUR 600,000, 47% above | Move year plus 5 tax periods | Non-resident for 5 tax periods; work-linked move | 2025 |
| Portugal, IFICI | 20% on eligible employment and business income | 10 years | Non-resident for 5 years; eligible activity | Current rules |
| Switzerland, expenditure-based taxation | Tax on living costs; federal minimum base CHF 435,000 | While conditions are met | Foreign national, no Swiss gainful activity | 2026 |
| Malta, Global Residence Programme | 15% on foreign income received in Malta; minimum EUR 15,000 a year | While the status is held | Qualifying property bought or rented | Since 1 July 2013 |
| Cyprus, non-domiciled resident | No Special Defence Contribution on dividends and interest | Until resident 17 of 20 years | Resident without Cypriot domicile of origin | Read October 2026 |
Every regime has an entry test and an end date or condition, and terms move. The Italian amount was EUR 100,000 until 10 August 2024, then EUR 200,000.
The UAE is not a regime: according to the UAE Government portal (accessed October 2026), it levies no income tax on individuals, so the planning question lies in the State you leave.
Every wealth journey starts with a conversation. Our advisers are ready to understand your objectives, assess your circumstances, and build a strategy tailored to your goals.
Begin Your Journey With UsA change of residence moves one connecting factor only: you.
| Element | Follows you? | What it means |
|---|---|---|
| Income arising in the State left | No | That State generally keeps taxing it |
| Situs of the asset | No | US-listed stock stays within US estate tax (return above USD 60,000) |
| Withholding at source | No | Most US-source income: 30% unless a treaty applies; none listed with the UAE |
| Treaty tails on gains | Partly | UK-US convention (2001): the former State keeps a six-year right |
IRS, read October 2026: estates of non-resident non-citizens; treaty list updated through 26 September 2025.
Since 6 April 2025, UK inheritance tax can follow a long-term resident for up to 10 tax years after departure.
When two States tax the same income or gain, relief exists in domestic law and in treaties, by credit or exemption. It is claimed, never automatic. That is a different exercise from sequencing a move, covered under double taxation relief methods.
Keep working for the same company from your new home, and that home can give the company a taxable presence there. The exposure is the company's, not yours.
The 2025 Update to the OECD Model Tax Convention, approved on 18 November 2025, sets a benchmark: a home is generally not the enterprise's place of business where the individual works there “for less than 50 per cent of their total working time” over twelve months. At 50% or more, facts and circumstances decide, and working time is measured on actual conduct. Three OECD illustrations:
The term is set out under permanent establishment under a tax treaty.
Keep working for the same company from your new home, and that home can give the company a taxable presence there. Working time is measured on actual conduct.
| Phase | What is decided | Dated example |
|---|---|---|
| Before | End date of residence; exit tax exposure; deferral request | France (2026): a deferral on request is filed within the 90 days before the transfer |
| Pivot year | Whether a sale falls in a resident year | Spain (rule read October 2026): a calendar year of residence is never split |
| After | Deferrals, regime applications, look-back periods | Canada (2026): deferral election by 30 April of the following year |
What you declare and pay each year once settled is a separate subject.
Points to verify with qualified advisers in each State, not a sequence fitted to a profile.
The calendar changes little where:
.jpg)
Before the date your residence changes: some deadlines precede the move. In France, where the deferral is on request, its return is filed within the 90 days before the transfer (2026).
In Canada, for example (2026):
There is no general answer. Three things decide:
| Rule | How long it runs |
|---|---|
| French exit charge (2026) | 2 or 5 years of holding |
| Norwegian exit tax (moves from 20 March 2024) | Payable within 12 years |
No. Individuals are in scope as soon as residence changes:
This guide is provided for general information purposes only and does not constitute tax or financial advice. Rules and rates were read on official sources in October 2026 and may change; the worked example is an illustration. Outcomes depend on individual circumstances: seek qualified advice before acting.
