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You hold shares and you are leaving

“I own shares in a company and I am about to leave”

An exit tax is a charge on unrealised gains that some countries apply when a long-term resident stops being tax resident. It is triggered by a shareholding above a threshold plus a minimum number of resident years — not by leaving as such. Most people who leave owe nothing. Those who do owe it cannot fix it afterwards, because the charge crystallises on the day residency ends.

Who this affects

Founders and shareholders, not earners. If you invoice, freelance or draw a salary and hold no qualifying company shares, no European exit tax reaches you regardless of how much you earn.

Why it matters

The thresholds differ enormously between countries and the same cap table can produce a six-figure assessment in one and nothing in another. Germany catches a 1% stake. Spain needs €4M across the portfolio, or 25% of a company worth over €1M. The Netherlands applies no minimum-residency test at all, so a recent arrival is fully inside its regime where the identical person leaving Munich or Madrid would walk away owing nothing.

What they actually look at

  • The size of your shareholding on the day residency ends, directly and indirectly held
  • How many of the last 10, 12 or 15 years you were tax resident, depending on the country
  • Market value of the holding at the departure date, minus what you paid for it
  • Whether an intermediate holding company genuinely changes the analysis, which it usually does not

How it is resolved

  • Establish which of the conditions you actually meet — most people fail one and are outside the regime entirely
  • Where a threshold is a cliff rather than a slope, selling below it before departure can exit the regime completely
  • Staging the exit across tax years: one more resident year is often cheaper than a mishandled charge
  • Commissioning a defensible valuation in advance rather than letting the authority reconstruct one later

The common mistake

Discovering the charge after landing. Every mitigation route runs through the departure date, and restructuring afterwards does not undo a charge that has already crystallised.

When the door closes

The day your tax residency ends. After it, the valuation is fixed and the options are closed.

Read next

  • EU exit tax cheatsheet
  • Spain: Article 95 bis
  • Germany: §6 AStG
  • Netherlands: conserverende aanslag

Which profiles this complicates most

  • Tax residency for crypto founders and traders — “My net worth is mostly on-chain”

Related situations

  • I still run my European company from abroad
  • I left, but my income still comes from my old country

Find out which of the conditions you actually meet.

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