Hardest countries to leave for tax 2026

Norway, Sweden, Germany, Canada and Australia are among the hardest countries to stop being tax resident in 2026. Norway keeps people who have lived there for 10 years or more resident for the year they move and at least three more years, Sweden presumes its citizens and 10-year residents stay taxable for five years after leaving, and Germany can keep taxing its nationals on more of their German income for ten years after a move to a low-tax country. Canada and Australia keep you resident until you cut your ties or set up a permanent home abroad, and both treat you as selling assets when you go.

Most countries let you go once you have moved abroad and stayed under their day count. These 39, out of the 153 TaxPilot covers, have the rules most likely to hold on to you. A few others, such as Moldova, Poland and South Korea, charge an exit tax and are covered in our exit tax guide. This guide groups the 39 by the rule that holds on to you: tails that run after you leave, look-back day counts, domicile and ties tests, exit taxes and formal deregistration.

For each country you will see why it is hard to leave and what you need to do. The rules are for the 2026 tax year, and the scenario is simple: you live in the country now and want to move your tax residence somewhere else.

What's changed: a few of these rules moved in 2026. Australia's wider foreign resident CGT rules apply from 1 October 2026, with no grandfathering for assets already held. Mozambique replaced its residence test on 1 January 2026, so there is no day count any more: your main home, your work and your economic interests decide it. Nigeria's Tax Act 2025 took effect on 1 January 2026, and you are non-resident only in a year you fail all six of its residence tests. Botswana's Income Tax Act, 2026 applies from 1 July 2026 and treats you as selling your foreign assets when you stop being resident. India's Income-tax Act 2025 replaced the 1961 Act on 1 April 2026 but kept the residence tests. Germany's exit tax also reaches large fund holdings for anyone leaving after 31 December 2024. The UK Budget is on 28 October 2026, and anything announced there is Proposed, not law.

Which countries are hardest to stop being tax resident in?

These are the 14 countries where our country guides rate leaving as hard. Each has a rule that can keep you resident, or taxed as if you were, after you think you have gone.

📋 The hardest countries to stop being tax resident in 2026

Eleven more are sticky in a narrower set of cases: France, Germany, Iceland, India, Ireland, Italy, Kazakhstan, Lithuania, Slovakia, Slovenia and Spain. The full list of all 39, with what to do in each, is further down.

The graphic shows eight of the stickiest rules, from Norway's three-year rule and Sweden's five-year presumption to the UK's 16-day ties test and US green cards, which stay in force until you give them up.

How we compare countries

We read the residence rules in each of TaxPilot's 153 country guides for 2026 and picked out the countries where leaving takes more than moving abroad and staying under a day count. Each of the 39 countries in this guide has at least one of these:

• a tail that keeps you resident, or taxable, for years after you leave

• a day count that looks back over earlier years or rolls across the calendar

• a domicile, home or ties test that days alone cannot break

• an exit tax that treats you as selling assets when you go

• a registration, application or status you have to formally end

Many countries have more than one, so each sits under its main rule and the others are noted. The all-in rates in our country guides assume you stay put, so exit taxes are flagged there but never added to the figures or ratings for any profile, crypto included. Your new country matters too, because a treaty tie-breaker only helps if you are resident there.

The hardest countries explained

Norway: the three-year rule

Reporting your move to the National Population Register does not end your tax residence. You stay taxable on your worldwide income until you are granted tax emigration, which you claim in your tax return. If you have lived in Norway for less than 10 years, residence can end in the year you move abroad permanently, spend no more than 61 days in Norway and neither you nor your family has access to a Norwegian home (a holiday home is allowed).

After 10 years, the three-year rule applies: you stay resident for the year you move and at least three more, meeting the 61-day and no-home conditions in each. Norway also has an exit tax on shares, funds and similar assets. For moves from 20 March 2024 the first NOK 3 million of net gains is deducted, and you can pay over 12 years or defer. Moving back within 12 years cancels it.

👉 Norwegian Tax Administration: tax emigration and the three-year rule

👉 Norway expat tax guide

Sweden: the five-year presumption

You stay fully taxable in Sweden for as long as you keep an essential connection. The Tax Agency looks at a year-round home, family in Sweden, a business or a significant shareholding in a Swedish company, and property.

If you are a Swedish citizen or lived in Sweden for at least ten years, the burden is reversed for five years after you leave: you are presumed to keep the connection unless you prove you do not. Separately, gains on Swedish shares can be taxed if you lived in Sweden at any time in the previous ten years. A treaty can limit both rules. Once non-resident, Swedish pensions and pay for work in Sweden normally fall under SINK, at 22.5% in 2026.

👉 Swedish Tax Agency: moving from Sweden and the five-year rule

👉 Sweden expat tax guide

Germany: the home test, the exit tax and a 10-year tail

Any home you keep and use can make you resident, so you stop only when you give up both your German home and your habitual abode. Deregistering alone is not enough if you keep a flat available.

Two rules can follow you. The exit tax applies if you were fully taxable for seven of the last twelve years and held 1% or more of a company in the last five: 60% of the gain is taxed as if you sold, payable in seven yearly instalments. And German nationals who were fully taxable for five of the last ten years and move to a low-tax country while keeping essential economic interests in Germany stay taxable on more German income for the year they leave and ten more years. For inheritance and gift tax, nationals stay fully liable for five years if they have no German home.

👉 Foreign Tax Act section 2: extended limited tax liability (in German)

👉 Germany expat tax guide

Canada: cut your ties, then pay departure tax

Canada has no single day count for leaving. You stop being resident when you sever your residential ties, and three almost always matter: a home in Canada, a spouse or common-law partner there, and dependants there. The CRA usually takes the latest of the day you leave, the day your family leaves or the day you become resident elsewhere. Form NR73 gets you a non-binding opinion.

Departure tax then treats you as selling most of your property at market value, including shares, funds, crypto and property abroad, with half of each gain taxed. Canadian real estate, RRSPs, TFSAs and pensions are left out. You report it on Form T1243, list property worth over C$25,000 on Form T1161, and can elect on Form T1244 by 30 April of the following year to defer. If the deferred federal tax is over C$16,500, the CRA will want security.

👉 Canada Revenue Agency: dispositions of property when you leave Canada

👉 Canada expat tax guide

Australia: the domicile trap

Under the domicile test you stay resident unless you have a permanent place of abode outside Australia. Leave without setting up a home somewhere else, for example to travel as a digital nomad, and you can stay resident on your worldwide income. A simpler 183-day bright-line test was proposed in 2021 but still has not been legislated.

When you do stop being resident, CGT event I2 treats you as selling your worldwide assets other than taxable Australian property. You can choose to defer it, but those assets then stay inside Australian CGT until you sell them.

👉 ATO: how changing residency affects CGT

👉 Australia expat tax guide

UK: ties that bite on 16 days

Leaving the UK is harder than arriving. If you were UK resident in any of the previous three tax years, four UK ties make you resident on just 16 days, three ties on 46 days and two ties on 91 days. The ties are family, accommodation, work, more than 90 days in either of the previous two tax years and, for leavers, spending more days in the UK than in any other country.

Two tails follow. Come back within five years and some gains and income from your time away can be taxed on your return. And long-term residents stay in inheritance tax for up to 10 tax years after leaving: 3 years after 10 to 13 years of residence, rising to 10 years after 20 years.

👉 HMRC RDR3: guidance note for the Statutory Residence Test

👉 UK expat tax guide

USA: green cards do not end at the airport

If you became resident by day count, you stop once your weighted days fall below 183. A green card is different: you stay US tax resident until you give up the status in writing to US Citizenship and Immigration Services, or it is ended by the authorities or a court. Moving abroad does not end it.

Held a green card in at least 8 of the last 15 tax years? Giving it up brings the expatriation tax rules. You are a covered expatriate if your average annual net income tax is above US$211,000 (2026), your net worth is US$2 million or more, or you cannot certify five years of compliance on Form 8854. You are then taxed as if you sold everything the day before, with the first US$910,000 of gain excluded in 2026. Most foreign nationals leaving also need a sailing permit.

👉 IRS: expatriation tax for long-term residents

👉 USA expat tax guide

New Zealand: 325 days away and no home

Getting in takes more than 183 days in any 12 months, or a permanent place of abode. Getting out needs both halves: no permanent place of abode in New Zealand and more than 325 days away in any 12-month period. Your non-residence is then backdated to when you left.

When you become non-resident you are generally treated as selling your foreign shares within the FIF rules at market value just before the change.

👉 Inland Revenue: leaving New Zealand

👉 New Zealand expat tax guide

All 39 countries: why they are hard to leave and what to do

Each country appears once, under the rule that matters most. Where a country also has an exit tax or another catch, the table says so.

Tails that follow you after you leave

These countries keep taxing you for a set period after you go, usually because you are a national, a long-term resident or moving somewhere with low tax.

☑️ Countries with a residence tail after you leave (2026)

Look-back and rolling day counts

Here the day count looks backwards or rolls across the calendar, so the year you leave, or a short visit afterwards, can still be a resident year.

☑️ Countries where look-back day counts keep you resident (2026)

Domicile, home and ties tests

These countries look at your home, family and interests rather than a simple day count. Spending most of the year abroad is not enough while those ties stay put.

☑️ Countries where domicile, home or ties tests keep you resident (2026)

Exit taxes

In these five the residence rules are not the main problem. Leaving itself is a tax event, because you are treated as selling assets on the way out. Ten more countries in this guide also have one: Australia, Canada, Denmark, France, Germany, Israel, Norway, Spain, Sri Lanka and the USA, and New Zealand treats FIF shares as sold. Our countries with an exit tax guide covers how each one works.

☑️ Countries where an exit tax is the main hurdle (2026)

👉 Countries with an exit tax

Registration, deregistration and paperwork

In these countries a formal step decides when residence ends: an application, a deregistration or a status you have to give up.

☑️ Countries where paperwork decides when you leave (2026)

Traps and what to check before you leave

• A home you keep. A flat or house still available to you keeps you resident in Germany, Denmark, Saint Lucia and Tanzania, and is a key tie in Canada, Australia and the UK.

• Family left behind. A spouse or children who stay can keep you resident in Canada, France, Italy and Mozambique.

• Moving somewhere with low tax. Germany, Spain, Italy, Ecuador and Lithuania have extra rules for people moving to low-tax countries, and Iceland wants proof you are taxed as a resident in your new country.

• Return visits. Look-back tests in the UK, India, Guernsey, Tanzania and Colombia can turn a short visit into a resident year, and in Venezuela a long stay one year makes the next year resident too.

• Coming back early. The UK taxes some income and gains if you return within five years, and Suriname treats a return within a year as never having left. Going back can also cancel an exit tax: within seven years in Germany, 12 in Norway.

• Inheritance tax tails. UK long-term residents stay in for up to 10 years, German nationals for five and Dutch nationals for 10.

• Regimes that unwind. Leave Italy within four years of using the impatriate regime and you repay the tax saved, with interest. Israel cancels its 2026 earned income break backwards if you stop being resident in 2028 or 2029 and spend fewer than 75 days there that year.

• Treaties. A tie-breaker can make you resident only in your new country, but it does not stop Germany's exit tax, and Germany has no treaty in force with the UAE.

• Evidence. Keep travel records, a lease or employment contract abroad and a tax residence certificate from your new country. Greece wants that certificate with your application, and DIAN in Colombia can ask you to prove where you were.

Check how easily you become resident in your next country too. If you never become resident anywhere else, Australia, Ecuador and Iceland can keep you resident by default.

👉 Easiest countries to become tax resident

Frequently asked questions

Which country is hardest to stop being tax resident in?

There is no single answer, but Norway, Sweden and Germany have the longest tails: three more years after 10 years in Norway, a five-year presumption in Sweden and a 10-year rule for German nationals moving to low-tax countries. Canada and Australia make you cut ties and treat you as selling assets when you go.

Does spending fewer than 183 days in a country end my tax residence?

Not always. In the UK four ties make you resident on 16 days, Canada and Australia look at your ties and home when you leave, not your days, and France has no 183-day test at all. India, Guernsey and Tanzania use look-backs that catch short return visits.

Can I stop being tax resident if I travel full time as a digital nomad?

Often not. Australia keeps you resident without a permanent place of abode abroad, Ecuador keeps you resident if you spent no more than 183 days in any other single country, and New Zealand needs more than 325 days away and no home there.

Which countries charge an exit tax when you leave?

In this list: Australia, Austria, Botswana, Canada, Denmark, France, Germany, Israel, Japan, the Netherlands, Norway, South Africa, Spain, Sri Lanka and the USA (for covered expatriates). See our countries with an exit tax guide.

How long does Sweden tax you after you leave?

For as long as you keep an essential connection. Swedish citizens and people who lived there for ten years or more are presumed to keep it for five years unless they prove otherwise, and gains on Swedish shares can be taxed for ten years.

Do I have to tell the tax office I am leaving?

In some countries it decides your status. Greece needs an application to AADE by early March of the following year, Norway needs a tax emigration claim in your return, Slovenia issues a non-resident decision, Gabon wants a provisional return 30 days before you go and South Africa uses the RAV01 form.

Does a double tax treaty solve the problem?

Partly. If you are resident in two countries, the tie-breaker can make you resident only in your new one, but it does not stop Germany's exit tax, for example, and it cannot help if you are not resident anywhere else.

Where to go next

👉 Countries with an exit tax

👉 Easiest countries to become tax resident

👉 Countries that don't tax foreign income

👉 Countries with no income tax

👉 Special tax regimes for new residents

👉 Best digital nomad visas

👉 UK expat tax guide

👉 Canada expat tax guide

👉 Norway expat tax guide