Singapore VCC insights

Exit Tax Moving to Singapore: Six Home-Country Departure Taxes Compared

By VCC Editorial Team · Published 17 October 2026

Short answer: Singapore does not tax capital gains, but it cannot switch off the exit tax your home country charges when you leave. Norway, South Korea, Japan, Australia, Canada and the United States each tax unrealised gains on departure in some form, with different triggers, thresholds and deferral routes. Some keep a residence or inheritance tail for years afterwards.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

The exit tax moving to Singapore is not a Singapore tax. It is the bill your current country issues on the way out, usually by treating you as having sold your portfolio on the day you leave. For a principal with a founder stake or family investment company, it can be the largest tax event of the relocation. This guide compares six departure regimes using only each country’s own tax authority, plus the Singapore position from the Inland Revenue Authority of Singapore (IRAS). All sources were checked on 17 October 2026. The UK position is covered in our guide for the UK non-dom moving to Singapore, and US estate tax on US assets in our note on US estate tax for Singapore residents.

What is an exit tax, and why does Singapore not neutralise it?

An exit tax charges unrealised gains when a taxpayer stops being resident or, in the US case, gives up citizenship or long-term residency. Singapore cannot neutralise it because the charge arises before Singapore residence begins, and Singapore has no general capital gains tax against which a foreign charge could be credited.

Exit tax moving to Singapore: how do the six regimes compare?

The table summarises each regime as published by the relevant authority on 17 October 2026.

Country	Trigger	What is taxed	Threshold	Deferral	Tail
Norway	Ceasing tax residence, including becoming treaty-resident elsewhere	Shares, fund units, share savings accounts, options, related derivatives, some foreign pension accounts	NOK 3,000,000 basic deduction	Instalments over 12 years or full deferral for 12 years; security generally required outside the EEA	Residents of 10 years or more stay taxable for the departure year plus at least three years
South Korea	Departure of a resident major shareholder	Valuation gain on Korean shares	Five of last ten years resident; major shareholder at prior year end	Until disposal, with tax administrator and security; due if unsold after 5 years	Not addressed on the NTS page
Japan	Ceasing domicile or residence in Japan	Securities, silent partnership interests, open margin and derivative positions	JPY 100 million; more than five of last ten years in Japan	5 years, extendable to 10, with tax agent and security; interest tax applies	Worldwide inheritance tax for heirs where a Japanese national had a Japanese domicile within ten years of death
Australia	Ceasing tax residence	CGT assets other than taxable Australian property	None stated	Choice to disregard; assets become taxable Australian property	Taxable Australian property stays within Australian CGT
Canada	Ceasing residence	Most property at fair market value	Form T1161 reporting above C$25,000	Form T1244 by 30 April, interest-free; security above C$16,500 federal tax	Section 116 procedures on later sales of taxable Canadian property
United States	Relinquishing citizenship or ending long-term residency	Worldwide property of a covered expatriate	Net income tax above US$206,000 (2025), net worth US$2 million, or failed certification	Election to defer tax on property deemed sold	40% section 2801 tax on US recipients of gifts and bequests

How does Norway’s exit tax work after the 2024 reforms?

Norway taxes the gain accrued while you were Norwegian tax resident, and since 20 March 2024 the tax must be paid within 12 years unless you move back first.

Skatteetaten (the Norwegian Tax Administration) applies the charge when a person becomes resident in another country under a tax treaty, emigrates for tax purposes or moves to Svalbard. In-scope assets include Norwegian and foreign shares, fund units, share savings accounts, unit-linked capital insurance accounts, employee options, derivatives over such assets and foreign pension accounts treated as investment accounts, such as US IRA and 401(k) plans.

A NOK 3,000,000 basic deduction applies, and for moves outside the European Economic Area (EEA) losses are ignored. The taxpayer elects in the return to pay immediately, pay by instalments over 12 years or defer in full for 12 years, generally against security outside the EEA. From 7 October 2024, 70% of any distribution received during deferral, including loans from the company, goes towards the deferred tax. Unreported exit tax can be assessed up to 15 years after the move, and deferral ends on death unless assets pass with full continuity to Norwegian-resident heirs.

The residence tail runs alongside. A person with ten years or more of Norwegian residence remains taxable for the year of departure and at least three further years, with no more than 61 days a year in Norway and no access to a Norwegian home, although a holiday home is permitted.

What do South Korea and Japan tax when a shareholder emigrates?

Both limit the charge to securities: Korea taxes major shareholders on Korean shares, while Japan taxes anyone leaving with JPY 100 million or more of securities and derivatives.

South Korea

The National Tax Service (NTS) explains that from 1 January 2018 a resident major shareholder leaving for reasons such as emigration is taxed on the valuation gain on Korean shares as capital gains. The person must have had a Korean domicile or residence for five or more of the ten years before departure and be a major shareholder at the end of the prior year under Article 167-8(1) of the Enforcement Decree of the Income Tax Act. For departures from 1 January 2019 the rate is 20% on a tax base up to KRW 300 million and 25% above.

A tax administrator must be appointed and a statement of Korean shareholdings filed by the day before departure, with a 2% penalty on the face value of shares for non-filing. Tax is due within three months from the end of the month of departure. Payment can be deferred until disposal against security, but falls due if shares are unsold after five years (ten for overseas study).

Japan

The National Tax Agency (NTA) explains that from 1 July 2015 a resident leaving Japan with securities, silent partnership interests, open margin trades or derivatives worth JPY 100 million or more, who lived in Japan for more than five of the previous ten years, is treated as having sold them at departure. Gifts or bequests to non-residents are caught in the same way, and reconstruction special income tax of 2.1% of base income tax is added for 2013 to 2037.

With a tax agent notified before departure, a declaration in the return and security for the tax and interest, payment can be deferred for five years, extendable to ten, with a continuation notice by 15 March each year. A return to Japan within that period, still holding the assets, allows the charge to be cancelled by a claim within four months. The inheritance tail is separate: under NTA guidance on heirs living abroad, a Japanese national who had a Japanese domicile within ten years before death is not a “non-resident decedent”, so heirs are generally taxed on worldwide assets.

How do Australia and Canada treat departing residents?

Both apply a broad deemed disposal, carve out domestic real estate and business assets, and allow postponement, but by different mechanisms.

Australia

The Australian Taxation Office (ATO) page “How changing residency affects CGT” (updated 22 June 2026) states that a person who stops being resident is taken to dispose of CGT assets at market value, except taxable Australian property such as Australian real estate and Australian business assets. The full 50% discount applies to the deemed disposal where the person was always resident while owning the asset, and temporary residents are exempt.

An individual may instead choose to disregard all gains and losses. The assets are then treated as taxable Australian property until a CGT event or a return to residence, so later growth stays within Australian CGT. The choice is evidenced by how the return is prepared.

Canada

The Canada Revenue Agency (CRA) page “Dispositions of property for emigrants of Canada” (modified 20 January 2026) deems emigrants to dispose of most property at fair market value on departure. Exceptions include Canadian real property, business property of a Canadian permanent establishment, registered plans listed in subsection 128.1(10) of the Income Tax Act, and property brought in by someone resident for 60 months or less in the prior ten years.

Gains are computed on Form T1243, and Form T1161 lists property where total value exceeds C$25,000, with a penalty of C$25 a day (maximum C$2,500). Form T1244 defers the tax, regardless of amount and without interest, until actual disposal; it is due by 30 April after the year of emigration, with security where deferred federal tax exceeds C$16,500 (C$13,777.50 for former Quebec residents). A returning resident can elect to unwind the deemed disposition on property still owned.

What does the United States expatriation tax catch?

The US regime is triggered by relinquishing citizenship or ending long-term residency, not by moving to Singapore. A US citizen who relocates without renouncing is outside section 877A.

The Internal Revenue Service (IRS) explains that for expatriations on or after 17 June 2008, section 877A applies to a covered expatriate: a person whose average annual net income tax for the five prior years exceeds an indexed amount (US$206,000 for 2025), whose net worth is US$2 million or more, or who fails to certify five years of compliance on Form 8854. All property is deemed sold on the day before expatriation, with gains reduced by an exclusion of US$890,000 for 2025, and the tax on property deemed sold may be deferred by election. Failure to file Form 8854 can attract a US$10,000 penalty.

The tail falls on the family. Under the Instructions for Form 708, a US citizen or domiciliary receiving a covered gift or bequest from a covered expatriate pays 40% on amounts above the annual exclusion, US$19,000 for 2025 and 2026, under final regulations effective 14 January 2025.

What does Singapore tax on arrival, and why is there no step-up?

Singapore generally does not tax capital gains, so there is nothing to rebase. There is no Singapore tax on later sales of investments, but also no Singapore cost uplift that a future country of residence would recognise.

IRAS guidance on gains from sale of property, shares and financial instruments states these are generally not taxable, unless trading in property. Under “Working out my tax residency”, a foreigner is resident for a Year of Assessment after at least 183 days in Singapore in the previous calendar year, or three consecutive years; Citizens and Permanent Residents are resident if they normally reside in Singapore. Resident individuals’ foreign-sourced income received in Singapore is exempt, other than through Singapore partnerships. See our guides to Singapore tax residence for family office principals and family office Singapore PR, and our sister site Singapore Employment Agency for passes.

For structures, section 10L of the Income Tax Act 1947 can tax foreign disposal gains received from 1 January 2024 by group entities lacking economic substance; the IRAS e-Tax Guide (6 June 2025) confirms it applies to entities, not individuals. Estate duty was removed for deaths on or after 15 February 2008, as explained in does Singapore have estate tax.

What should a principal do before leaving for Singapore?

The work is done in the departure country, before the move:

1. Fix the departure date under home-country residence rules and any treaty tie-breaker, because it sets the valuation day.
2. Value every in-scope asset as at departure, including unlisted holding companies and foreign pension accounts.
3. Test thresholds: NOK 3,000,000, Korea’s major-shareholder test, JPY 100 million, C$25,000 and the US covered-expatriate tests.
4. Appoint a Korean tax administrator or Japanese tax agent before leaving.
5. Decide whether to pay or defer and arrange security; Canada’s election is due by 30 April after the year of departure.
6. Diarise continuing duties: Norwegian updates during deferral, Japanese notices by 15 March, five or ten-year deadlines and US Form 8854.
7. Review dividends and loans from holding companies, given Norway’s 70% rule.
8. Only then move assets into a Singapore company, Variable Capital Company (VCC) or trust, so the transfer does not itself crystallise deferred tax.

Frequently asked questions

Does a tax treaty with Singapore remove the exit tax?

Not automatically. Norway’s charge is triggered precisely when you become resident elsewhere under a treaty, and each regime applies domestic law at departure. Any treaty relief must be checked against the specific treaty and asset.

If I hold my portfolio through a company, am I outside the exit tax?

Usually not. All six regimes reach shares, so the holding company shares are the asset deemed sold, and Norwegian deferred tax can be accelerated by company distributions or loans.

Can I avoid the charge by returning home later?

Partly. Japan cancels the charge on assets still held on return within the deferral period, Canada allows an unwinding election, and Norway’s 12-year payment rule does not apply if you move back first. The Korean and US pages reviewed offer no equivalent.

Will Singapore give me a higher cost base when I arrive?

No. Singapore generally does not tax capital gains on investments and has no arrival rebasing rule. A later country of residence applies its own cost base rules.

Which figures are most likely to change?

US thresholds are indexed and the IRS page lists figures only to 2025, so 2026 amounts should come from current Form 8854 instructions. Korea’s major-shareholder thresholds are set by decree and have changed over time.

Sources

• Skatteetaten: Utflyttingsskatt (exit tax)
• National Tax Service: capital gains tax on shares of departing residents
• National Tax Agency: Tax Answer No.1478, exit taxation on departure
• IRS: Expatriation tax
• IRAS: Working out my tax residency

Raffles Corporate Services helps principals relocating to Singapore sequence their exit, residence and family office structuring, from VCC incorporation and family office set-up to ongoing compliance. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 17 October 2026. The Editorial Team, Variable Capital Companies Act.