Which country taxes your capital gains after you move
A capital gain is taxed where you are tax resident when you sell, and for some assets also where the asset is. Each country has its own test for tax residency, so in a move year the sale date decides which country taxes the gain.
For people who change countries every 1 to 2 years, the sale date is the part of digital nomad taxes on investments they set themselves, so a large sale can wait until a move is complete.
Most tax treaties copy the OECD Model Tax Convention, which gives each kind of income its own article: Article 6 for rent, Article 18 for private pensions, taxable only in your country of residence, and Article 13 for gains, split by the asset you sell.
Who may tax a capital gain under the OECD Model Tax Convention
| What you sell | Who may tax the gain | Article |
|---|---|---|
| Land and buildings | The country where it is, and your country of residence | 13(1) |
| Business assets of a permanent establishment | The country where the permanent establishment is, and your country of residence | 13(2) |
| Shares or partnership interests that got more than 50% of their value from real estate in the 365 days before the sale | The country where the real estate is, and your country of residence | 13(4) |
| Shares in other companies, listed or not, plus funds, bonds, crypto and other property | Only your country of residence on the day of the sale | 13(5) |
Where both countries may tax, your country of residence gives way: it either exempts the gain or deducts the tax already paid in the other country (OECD Model, Articles 23 A and 23 B).
Selling shares before or after you move
For shares and most other investments, Article 13(5) leaves the gain to 1 country: wherever you are resident on the day you sell. That puts a price on the sale date, because a gain on listed shares held over a year costs nothing in the UAE (PwC), Singapore (IRAS) or Hong Kong (PwC), and 24% in the UK (GOV.UK).
Source: Each country's tax authority, statute or PwC Worldwide Tax Summaries page, listed under Sources Swiss exemption excludes professional securities dealers.
Show the numbers
| Top rate | |
|---|---|
| United Arab Emirates | 0% |
| Singapore | 0% |
| Hong Kong | 0% |
| Switzerland | 0% |
| United States | 20% |
| United Kingdom | 24% |
| Portugal | 28% |
| Spain | 30% |
| France | 31.4% |
Portugal's 28% covers shares held 365 days or more; shorter holdings are taxed at progressive rates once income, gain included, reaches the top bracket (CIRS Article 72). Spain's 30% applies only to the slice of savings income above €300,000 (about $341,000) (PwC), and France's 31.4% flat tax rises by 3% to 4% on a single person's income above €250,000 (about $284,000) (PwC).
Most countries with no capital gains tax get there in 1 of 3 ways: no personal income tax (the UAE, the Bahamas), no tax on individuals' capital gains (Hong Kong, Mauritius, and Singapore for investors), or a territorial system that leaves foreign-source gains untaxed (Panama, Paraguay, Georgia).
Under split year treatment, the UK divides the tax year you leave into a UK part and an overseas part and normally charges capital gains tax only on the UK part (HMRC HS278), so a sale soon after you leave can fall outside UK tax, subject to the return rule below.
Selling before the move wins when the new country charges more, a Singapore resident moving to France for example, or when an exit tax would catch the gain anyway. Selling after wins when the new country exempts the gain, your old residence has clearly ended and no return rule can reach the sale.
Non-resident capital gains tax on property you leave behind
Moving never takes land and buildings out of the country where they are: that country keeps the right to tax the gain (OECD Model, Article 13(1)), so a non-resident seller files and pays there, then reports the gain in the new country, which gives relief.
In 4 of the 5 countries below, the buyer withholds part of the price at the sale; in the UK you report and pay the tax yourself.
What 5 countries take when a non-resident sells property there, checked October 12, 2026
| Country | Gains a non-resident pays on | Collected at the sale | Watch for |
|---|---|---|---|
| United Kingdom | UK residential, non-residential and mixed-use property and land (GOV.UK), and shares in a company that gets at least 75% of its value from UK land if you held 25% or more of it at any time in the 2 years before the sale (TCGA 1992, Schedule 1A) | Nothing withheld; you report and pay within 60 days of completion | Older holdings: gain usually measured from the value on April 5, 2015 (homes) or April 5, 2019 (other property) |
| Spain | Gains on Spanish assets, at 19% (PwC) | 3% of the price, withheld by the buyer as an advance payment of your tax | The seller must be represented by a lawyer or legal representative |
| United States | US real property interests (IRS) | Generally 15% of the amount realized, withheld by the buyer | No withholding if the buyer will live there and the amount realized is $300,000 or less |
| Australia | Taxable Australian property, which includes real property and some indirect interests in it (PwC) | 15% of the gross proceeds, credited against your final tax | No main residence exemption for foreign residents, bar narrow life-event cases; no CGT discount on gains after May 8, 2012 |
| Canada | Taxable Canadian property, such as Canadian real property and unlisted shares of Canadian companies (CRA) | 25% of the price, or 50% for depreciable property and real property held as inventory, withheld by the buyer unless you hold a clearance certificate (Income Tax Act, section 116) | 50% of a capital gain is taxable, at ordinary rates (PwC) |
For a UK leaver, this is a part of UK tax for non-residents with no end date: a London apartment kept after the move stays inside UK capital gains tax for as long as you own it (GOV.UK).
Renting the property out instead of selling it keeps it in the same tax net: the country where it is may tax the rent under Article 6, so foreign rental income tax is paid in the same country as the eventual gain, with relief in your new one.
Selling a Madrid apartment after moving to Lisbon
Filed in both countries
She becomes Portuguese resident in March 2026 and sells the Madrid apartment in October. The buyer withholds 3% of the price, she files a Spanish non-resident return on the gain at 19% (PwC) with the withholding counted as paid, and she reports the gain in Portugal with relief for the Spanish tax.
Assumed the move ended it
Same sale, but she assumes leaving Spain ended its claim and files nothing there. The withholding is only an advance (PwC), so Spain can assess the rest, and Portugal has no Spanish tax to give relief for.
Shares that count as property
Put a London rental into a company you own outright, move abroad and sell the shares, and the UK can still tax the gain, because the company gets at least 75% of its value from UK land and you hold 25% or more of it (TCGA 1992, Schedule 1A); property funds and REITs follow separate rules (HMRC CG73930). A treaty that follows the OECD Model keeps that right where more than 50% of the value came from real estate in the 365 days before the sale (OECD Model, Article 13(4)). For a stake of that size, selling the company instead of the building does not move the gain to your new country.
Exit taxes: when leaving counts as selling
Some countries do not wait for a sale: an exit tax on unrealized gains treats assets as sold at market value when your residence ends, taxing the gain built up while you lived there even if you keep them.
Exit taxes on gains in 5 countries, checked October 12, 2026
| Move | Who it reaches | What is treated as sold |
|---|---|---|
| Leaving Canada | Anyone who stops being resident | Most property, at fair market value; exceptions include Canadian real property, RRSPs and other registered plans, and property you owned when you became resident if you were resident 60 months or less in the 10 years before leaving (CRA) |
| Leaving Australia | Residents who stop being resident | Assets that are not taxable Australian property, unless you elect to keep them in the Australian tax net (PwC) |
| Leaving Germany | People with unlimited German tax liability for at least 7 of the last 12 years | Shares in a company in which you held at least 1% at any time in the last 5 years, at fair market value (AStG section 6, EStG section 17) |
| Leaving Spain | Residents for at least 10 of the 15 tax years before the last one they file as residents | Shares worth more than €4,000,000 (about $4,550,000) in total, or a stake above 25% in one entity when that stake is worth more than €1,000,000 (about $1,140,000) (AEAT) |
| Giving up US citizenship | Covered expatriates: net worth of $2 million or more, average annual net income tax above $211,000 (2026), or no certification of 5 years of compliance | All property, at fair market value the day before expatriation; gains above $910,000 (2026) are taxed (IRS, Rev. Proc. 2025-32) |
Canada lets you elect on Form T1244, by April 30 of the year after you leave, to pay the departure tax without interest when you sell, though the CRA asks for security once the federal tax on the deemed sale passes CAD 16,500 (about $11,600) (CRA).
Germany spreads the bill instead: on application, you pay in 7 equal annual installments, generally against security, and the balance falls due early if you sell the shares (AStG section 6).
Under the Netherlands' exit rules, a substantial shareholding in a Dutch company counts as sold when you emigrate, and the tax on it goes into a protective assessment, as does tax on Dutch pension and annuity rights (Belastingdienst). You pay all or part of the shareholding assessment if you sell the shares, a dividend is paid on them or the company ceases to exist.
Portugal treats losing Portuguese residence as a disposal of crypto-assets and excludes only gains on coins held 365 days or more (CIRS Article 10(22) and 10(25)), so for a nomad leaving Portugal, crypto held under a year is taxed by the move itself, sale or no sale.
Capital gains after you leave: the UK 5-year rule and other claims
Under the UK's temporary non-residence rule, if you had sole UK residence in at least 4 of the 7 tax years before the year you left and your time abroad does not exceed 5 years, gains you made while away on assets you held before leaving are treated as arising in the tax year you return (HMRC HS278).
Assets you bought after leaving are generally outside the rule, with exceptions for assets tied to your UK years, such as those whose cost was reduced by rollover relief (HMRC HS278).
| Sold in the 2026 to 2027 tax year, before leaving24% on the gain above the £3,000 (about $3,980) allowance | £47,280 (about $62,700) |
|---|---|
| Sold in year 2 in Singapore, non-UK resident for 6 yearsOutside UK tax; Singapore does not tax it | £0 |
| Sold in year 2 in Singapore, back in the UK in year 4Taxed in the year of return (2026 to 2027 rates shown); no Singapore tax to credit | £47,280 (about $62,700) |
Rates and allowance for 2026 to 2027 from GOV.UK; return rule from HMRC HS278. Assumes sole UK residence in 4 of the 7 tax years before leaving and no other gains that year.
Germany's return rule works in your favor: the exit tax lapses if you become a German taxpayer again within 7 years, extendable by up to 5, and still hold the shares, among other conditions (AStG section 6).
A Spanish national who moves to a country Spain classes as a tax haven stays a Spanish taxpayer in the year of the move and the following 4 years (Personal Income Tax Act, Article 8.2).
US citizens: capital gains stay taxable in the US
The US taxes citizens on worldwide income wherever they live (IRS), so for US expats a move to a country with no capital gains tax changes the foreign tax on a sale, not the US tax.
Gains on assets held more than 1 year are taxed at 0%, 15% or 20% depending on taxable income (IRS Topic 409), plus the 3.8% net investment income tax once modified adjusted gross income passes $200,000 for a single filer or $250,000 for a married couple filing jointly (IRS).
The foreign earned income exclusion does not reach gains, which the IRS lists as unearned income (IRS). The foreign tax credit does: foreign income tax paid on the same gain, such as to the country where a property is, reduces the US tax on it (IRS).
Moving with shares or property: the steps in order
Before you sell or move
- List every asset with its purchase date, cost and value, marked as property, shares in a property-rich company or an ordinary investment.
- Check the old country's exit tax, its thresholds and its deferral deadline.
- Get a dated market valuation of each large holding for the day your residence ends.
- Fix the date your old residence ends, by becoming non-resident for tax under every test there, and the date the new one starts.
- Time large share sales after both dates, or before the move if the new country charges more; comparing what the same sale costs in 2 or 3 candidate countries shows which order wins.
- For property you keep, note the deadline for a non-resident sale, such as the UK's 60 days.
- Ask the new country for a tax residency certificate before a large sale.
David's note
If there is any real chance you move back to the UK within 5 years, I would plan every sale of an asset you held on departure as if you had never left. The return rule turns a tax-free sale abroad into a UK bill in the year you come back, often after the money is spent.
