The moving abroad tax checklist at a glance
A move has 3 tax stages, and each depends on the one before: the regime you can claim depends on where you are resident, and that depends on whether the old country has let you go.
The 3 stages of a move and what each one settles
| Stage | When | What to settle |
|---|---|---|
| Before you move | 6 to 12 months ahead | Exit tests, new residence, exit tax, asset sales, social security, your employer |
| The move year | Departure to the end of both tax years | Deregistration, departure filings, split or full-year residence, banks |
| After you arrive | The first 12 months | Registration, regime claims, the first return, a residency certificate |
Before you move: choose where you will be tax resident
Start with the exit tests of the country you are leaving, because becoming non-resident for tax means failing all of them, ties as well as days. Under the UK statutory residence test, a leaver is automatically non-resident with fewer than 16 UK days in a tax year if they were UK resident in any of the previous 3 tax years, or fewer than 46 if they were not. Full-time work abroad also qualifies, with fewer than 91 UK days and fewer than 31 days of more than 3 hours' work in the UK (HMRC, RDR3).
Then set the new country's residence test against them, because it decides when you become taxable there and which regimes you can claim. Days are only one test: under the tax residency rules of most countries, a home, a family that moves with you or a center of economic interests can make you resident sooner.
Price the new country before you commit. Once you are resident there, its income tax and social contributions decide most of the bill, so the digital nomad taxes you will actually pay are the 2 added together, plus a US return if you hold a US passport. If you are still choosing, a side-by-side comparison of 2 or 3 countries at your own income says more than any headline rate.
Before you move: exit taxes and when to sell
Some countries charge tax on the way out, whether or not you sell anything. When you stop being resident in Canada, you are treated as having sold most of your property at fair market value on the day you leave, so the gain is taxed in your departure year (CRA).
Canadian real estate, pensions, RRSPs, RRIFs and TFSAs are not caught, and neither is property you brought with you if you were resident for 60 months or less in the 10 years before leaving Canada.
Canada's deferral has a deadline
Form T1244 lets you defer Canada's departure tax on shares you still hold until you actually sell, with no interest, but the election is due by April 30 of the year after you emigrate. If the deferred federal tax is above the CRA's security threshold, you also have to arrange security with the CRA before that April 30 (CRA).
The Dutch rules for emigrants can produce a protective assessment for future tax, which you do not have to pay as long as you meet its conditions (Belastingdienst). Germany and Spain also treat leaving as a sale of some shareholdings: Germany after 7 of the previous 12 years as a resident taxpayer (AStG, section 6), and Spain after 10 of the previous 15 years once your shares are worth more than €4,000,000 (about $4,550,000), or more than €1,000,000 (about $1,140,000) for a stake above 25% (Agencia Tributaria). That is why the exit tax in the country you leave has to be priced before the move date is fixed.
Without an exit tax, the date you sell still decides which country taxes the gain. Under the OECD Model Tax Convention, gains on shares are taxable only where the seller is resident (Article 13(5)), unless more than 50% of the company's value came from real estate in the other country at any time in the 365 days before the sale (Article 13(4)), so capital gains tax when moving abroad turns on whether you sell before or after your residence changes.
The UK adds a return rule: if you were solely UK resident in at least 4 of the 7 tax years before leaving and come back within 5 years, gains on assets you held before leaving are taxed in the year you return (HMRC, HS278).
Who may tax investment income after you move, under the OECD Model
| Income | Who may tax it after the move | Step before you go |
|---|---|---|
| Gains on shares (Article 13(5)) | Only your country of residence when you sell, unless the company's value comes mostly from real estate (Article 13(4)) | Decide which sales fall before the move date |
| Rent (Article 6) | The country where the property is, and your new country | Keep filing where the property is; your new country treats the rent as foreign rental income and gives relief for the tax paid there |
| Private pensions (Article 18) | Only your country of residence | Claim treaty relief so home withholding stops; a government pension (Article 19) usually stays taxable in the paying country, a split that shapes foreign pension tax |
| Dividends (Article 10) | Your new country, plus the company's country at up to 15% | Give brokers your new residence so treaty rates apply |
Before you move: social security and your employer
Social contributions follow their own rules and can land in a different country from income tax, so get the paperwork before you go: an A1 keeps a posting elsewhere in the EU of up to 24 months in your home system (European Commission), and a certificate of coverage does the same under one of the US's 31 totalization agreements.
With neither, you join the new country's system or pay into none, and paying into none leaves a gap in your pension record, which is why social security for digital nomads has to be settled before the flight.
If you are employed, your employer has to agree to the move. Under Article 15 of the OECD Model, salary can be taxed where you physically do the work, and the 183-day exception covers only short stays while you remain resident at home, so after a real move working remotely from another country starts with the employer agreeing the country and the payroll.
Before you move: 6 to 12 months ahead
- List every exit test of the country you are leaving and plan to fail each one.
- Pick your new country and read its residence test: days, home and family.
- Check for an exit tax and the date its deferral election is due.
- Decide which shares, crypto or property to sell before the move date.
- Request an A1 or a certificate of coverage before you leave, or plan to join the new country's system.
- Get your employer's written approval for the country and the payroll.
The move year: deregistering and departure filings
Most countries expect to hear that you have gone. The Netherlands asks you to deregister from your municipality before you leave, keep the certificate for the authorities that will ask for it, and file a return for the year of emigration (Belastingdienst).
UK leavers who do not normally file Self Assessment send form P85 when they leave so HMRC can work out any refund for the year of departure, while Self Assessment filers report the move on the SA109 residence pages instead (GOV.UK).
Split year or full year: when the old residence ends
The UK treats you as resident for all of its April 6 to April 5 tax year, but the year can be split into a UK part and an overseas part when one of its split-year cases for leavers applies, each with conditions that must all be met (HMRC, RDR3). With split-year treatment, the overseas part starts on a date the case sets, which need not be your flight date. If you leave for full-time work abroad, it starts with the qualifying work period, on a day you do more than 3 hours of work overseas (Finance Act 2013, Sch 45 para 53); if you stop having a UK home, it starts on the day that home ends (HMRC, RFIG21140).
How the move year works in 5 Index countries
| Country | Rule for the year you arrive or leave |
|---|---|
| United Kingdom | Resident for the full tax year, split into a UK and an overseas part only when a split-year case applies |
| Spain | Spain's residence test counts the full calendar year with more than 183 days or the main economic base there; no split year |
| Ireland | Irish tax residence needs 183 days in the year, or 280 across 2 years with more than 30 in each; split-year treatment ignores employment income earned abroad before you arrive (Revenue) or after you leave (Revenue) |
| Greece | More than 183 days in total within any 12-month period makes you resident from your first day of presence (Greek tax residence; Income Tax Code, art. 4) |
| Georgia | Georgian tax residence covers the full year with 183 days in any 12-month period ending in it |
The country you left can count the full year while the country you joined counts you from arrival, so both can claim the same months. A treaty then settles dual tax residency with its tie-breakers, starting with where you have a permanent home, which is why the old lease should end before the new one starts.
Selling shares around a move from Spain
Sale after Spain lets go
Moves from Madrid to Lisbon on March 1 with 59 days in Spain that year, ends the Madrid lease and sells a €300,000 (about $341,000) ETF portfolio in June, well below the line for Spain's exit tax. Spain's residence test is not met for the year, so the gain falls to Portugal.
Sale inside a Spanish year
Moves on September 1 after 243 days in Spain and sells in October. Spain counts the full calendar year as resident, so the October gain can still be taxed in Spain unless the treaty tie-breaker hands it to Portugal.
Keep a day log with flights and entry stamps as evidence, because the rules for counting days for tax residency differ on partial days and short trips, and those details decide the years near a threshold.
Under the Common Reporting Standard, a bank collects a self-certification of your tax residence and tax number and reports the account to its own tax authority, which passes it to the country you named where an exchange is in place (Revenue, Ireland), so an old self-certification keeps sending your balances to the country you left.
The move year: what to file and who to tell
- Deregister where your country requires it, and keep the certificate.
- Tell the tax office: form P85 or SA109 in the UK, the emigration-year return in the Netherlands.
- File the departure-year return with any exit tax forms, such as Canada's T1243 or T1244.
- Check whether the old country splits the year, and time sales and bonuses around it.
- End or rent out the old home before the new lease starts.
- Update your tax residence with every bank, broker and crypto exchange.
After you arrive: register, claim regimes and file
Register with the new tax authority as soon as you are resident, and as self-employed before your first invoice. For a freelancer the registration also picks the regime and most of the bill, so freelancer taxes abroad come down to residence, registration, social contributions and VAT, in that order.
Some countries ease the first year: under Portugal's freelancer rules, a first-time self-employed person's social security starts on the first day of the 12th month after the work begins, and then charges 21.4% on 70% of service revenue (Segurança Social).
New-resident regimes have to be claimed inside short windows. Spain's is claimed on Form 149 within 6 months of the start date in your Spanish Social Security registration, by people not resident in Spain in the 5 previous tax years, and it is open to employees (remote ones included), company directors, certified entrepreneurs and highly qualified startup or research professionals, not ordinary freelancers (Agencia Tributaria). Spain's inbound worker regime then taxes salary at 24% up to €600,000 (about $683,000) for the year of arrival and 5 more (Agencia Tributaria).
Portugal's IFICI, a 20% rate for qualifying research, startup and other highly qualified jobs only, runs 10 consecutive years from the year you register as resident, after 5 years of non-residence (EBF, Article 58-A). Registration is due by January 15 of the year after you become resident (Deloitte), and a later one counts only from the year it is made. Each of the other tax incentives for new residents has its own look-back and window.
File the first return in the new country and claim relief for any tax the old country took on the same income. Once you qualify, ask for a tax residency certificate, the proof that banks, payers and the old tax office accept.
After you arrive: the first 12 months
- Register with the tax authority and get a tax number.
- Register as self-employed or open the company, and pick the regime before the first invoice.
- Register for social security, or hand over the A1 or certificate of coverage.
- Claim any new-resident regime inside its window, and note its end date.
- File the first return there and the last one at home, with relief for tax paid twice.
- Ask for a tax residency certificate as soon as you qualify.
Extra steps for US citizens moving abroad
A US passport keeps you filing a federal return on worldwide income every year after the move (IRS). Your state applies its own residence rules, and state taxes when moving abroad depend on closing that residence too.
In the move year you may not yet pass the 330-day physical presence test (IRS) or the bona fide residence test, so Form 2350 extends the filing date to give you time to qualify (IRS, Form 2350). The foreign earned income exclusion then removes up to $132,900 of 2026 earnings from income tax (IRS). It never covers the 15.3% self-employment tax abroad a freelancer owes (IRS), unless a totalization agreement and a certificate of coverage put you in the other country's system (IRS). FBAR filing applies once your foreign accounts together exceed $10,000 at any time in the year (FinCEN).
David's note
I would fix the move date last, after the exit tax, the asset sales and the regime windows are mapped. A date chosen around a lease or a school term can cost a full extra year of residence in the old country, and of everything on this list it is the hardest to undo once you have flown.
