Exit Tax and a Second Passport: UK, Germany and the Netherlands in 2026

A second passport does not change where you pay tax: tax residence follows where you live and the domestic law of the country you leave. As at October 2026, the United Kingdom has no general exit tax on individuals, Germany taxes unrealised gains on shareholdings of 1% or more under §6 AStG, and the Netherlands issues a protective assessment on substantial interests of 5% or more.

This guide sets out, from primary sources, what each country does when a resident leaves and where citizenship by investment fits. It is information, not tax advice: confirm every rule with a qualified adviser in each country before acting.

Does a second passport change your tax residence?

A second passport does not change your tax residence in the United Kingdom, Germany or the Netherlands, because all three tax individuals on residence, not on nationality. Holding Caribbean or any other citizenship leaves your existing tax position exactly where it is until your residence, home and centre of life genuinely move under each country's own rules.

The OECD makes the same point for the Common Reporting Standard (CRS): its guidance on residence and citizenship by investment schemes states that the mere right to reside in a jurisdiction, or the fact of holding its citizenship, does not by itself make a person tax resident there, and does not extinguish tax residence in the former country. Banks must collect self-certifications listing every tax residence you hold.

A second citizenship is therefore a mobility, family and contingency asset. It can sit comfortably alongside a tax plan, but it is never the tax plan. For the full treatment of how residence, citizenship and CRS reporting interact, see our guide to tax residence versus citizenship for CBI citizens.

What is an exit tax?

An exit tax is a charge that a country levies when a taxpayer ceases to be resident, usually by treating certain assets as sold at market value on the day of departure. The purpose is to tax gains that built up during residence before the country loses the right to tax them; Germany and the Netherlands have such rules, the United Kingdom does not.

Exit charges differ in what they cover, what triggers them and how payment can be deferred, and they interact with rules that follow you after departure. The table below summarises the three regimes as read from official sources on 2 October 2026.

Does the United Kingdom have an exit tax in 2026?

The United Kingdom has no general exit tax on individuals in 2026: leaving the UK does not trigger a deemed disposal of your assets. UK law instead relies on the temporary non-residence rules, the Statutory Residence Test, capital gains tax on UK land for non-residents, and a residence-based inheritance tax test with a tail of up to 10 years.

Proposals for a departure charge on wealthy leavers have been reported in the press, but none had been legislated as at 2 October 2026. Because UK fiscal policy can change at any Budget, anyone planning a move should check the position at the time of departure rather than rely on today's statute alone.

What does follow you is set out clearly in GOV.UK guidance. Under the temporary non-residence rules (HMRC helpsheet HS278), if you had sole UK residence in at least 4 of the 7 tax years before you left and you return within 5 years, certain gains realised while abroad are taxed in the year you come back. Non-residents also must report and may pay capital gains tax on disposals of UK property or land, whatever their residence.

What changed for UK non-doms on 6 April 2025?

The UK abolished the remittance basis and the non-dom regime from 6 April 2025 under Finance Act 2025. Domicile no longer decides how foreign income and gains are taxed; residence does. New arrivals after at least 10 consecutive years of non-residence can claim the 4-year foreign income and gains (FIG) regime instead.

The statutory changes sit in Part 2 of the Finance Act 2025 on legislation.gov.uk: section 40 makes the remittance basis unavailable after the 2024-25 tax year, Chapter 1 introduces relief for foreign income and gains of individuals becoming UK resident, and section 44 replaces the domicile test for excluded property with a long-term residence test for inheritance tax.

According to GOV.UK guidance on the 4-year FIG regime, a qualifying individual who claims the regime pays no UK tax on eligible foreign income and gains for up to 4 tax years from the start of UK residence, but gives up the personal allowance and the capital gains tax annual exempt amount for any year of claim. After the 4 years, worldwide income and gains are taxed on the normal basis.

How does the UK inheritance tax residence test work after leaving?

Since 6 April 2025, UK inheritance tax on worldwide assets applies to long-term UK residents: anyone UK tax resident for at least 10 of the previous 20 tax years. Long-term residence status continues after departure for a tail of 3 to 10 tax years, depending on how long you lived in the UK.

GOV.UK guidance on long-term UK residents sets out the tail: 10 to 13 years of UK residence gives a tail of 3 years, 14 years gives 4, 15 years gives 5, and the tail rises by one year for each further year, up to 10 years after departure. During the tail, inheritance tax can still be charged on overseas assets you own outright and on certain trusts you set up or added to.

This is the point UK families most often underestimate. Changing passport, or even moving abroad, does not end UK inheritance tax exposure overnight. Succession structures therefore need to be designed with the tail in mind; our guide to trusts, succession and family planning for CBI families explains how citizenship planning and estate planning fit together.

How does the UK Statutory Residence Test decide if you have left?

The UK Statutory Residence Test decides residence each tax year through automatic overseas tests, automatic UK tests and a sufficient ties test. You are automatically non-resident with fewer than 16 UK days if resident in any of the previous 3 tax years, and automatically resident with 183 days or more.

The HMRC guidance note RDR3 explains the sequence. If neither automatic test settles the question, the sufficient ties test weighs your UK days against family, accommodation, work, 90-day and country ties. People leaving the UK after a long period of residence face the strictest thresholds, because the 16-day limit applies to them rather than the 46-day limit available to those with no recent UK residence.

A Caribbean passport plays no part in that test: what counts is evidence of home, family, work and days.

What is the German exit tax under §6 AStG?

The German exit tax (Wegzugsbesteuerung) under §6 AStG treats shares of 1% or more in a company as sold at fair market value when an individual who has been fully tax liable in Germany for at least 7 of the last 12 years gives up German tax residence. The deemed gain is taxed as income.

The rule, as amended with effect from 1 January 2022, is set out in §6 of the Außensteuergesetz on gesetze-im-internet.de. It applies to holdings within the meaning of §17 EStG: a direct or indirect stake of at least 1% at any time in the previous 5 years, in German or foreign companies. Besides departure, it is triggered by gifts of such shares to non-residents and by any other loss of Germany's right to tax the gain.

Under the partial-income method in §3 No. 40 EStG, 40% of a §17 disposal price is tax exempt, so the deemed gain is taxed at progressive income tax rates on the remaining 60%, plus the solidarity surcharge where it applies. The resulting bill depends on your other income and on how the company is valued, which is why a professional valuation usually sits at the start of any German plan.

How can the German exit tax be paid or reversed?

Germany lets the §6 AStG exit tax be paid in 7 equal annual instalments, usually against security, and the claim lapses if you resume unlimited German tax liability within 7 years and the statutory conditions are met. Distributions exceeding a quarter of the shares' value make the outstanding amount due immediately.

Since 2022 the instalment regime applies to every destination, including EU and EEA states, replacing the earlier interest-free deferral for moves within Europe. The tax office may extend the 7-year return window by up to 5 more years where the return is planned and the absence is work-related or otherwise justified. A sale of the shares during the instalment period also brings the remaining tax forward.

Valuation, instalments, security and any restructuring are settled with the German adviser before the deregistration date, not after.

What is Germany's extended limited tax liability?

Germany's extended limited tax liability under §2 AStG can apply for 10 years after the year of departure to a German national who was fully tax liable in Germany for at least 5 of the last 10 years, moves to a low-tax country and keeps essential economic interests in Germany.

§2 AStG defines essential economic interests by reference to German business holdings, German-source income above 30% of total income or EUR 62,000, or German assets above 30% of total assets or EUR 154,000. It applies only where the German-source income concerned exceeds EUR 16,500 in the year. Low taxation means a tax burden more than one third lower than German income tax on the same income.

For a German considering a second citizenship, the relevant change is on the nationality side rather than the tax side. Since 27 June 2024 Germans no longer lose German nationality automatically when they acquire a foreign one: the former loss rule in §25 StAG has been repealed. Keeping German citizenship also keeps you within the scope of §2 AStG, which applies to German nationals, so a second passport is a mobility decision, not a German tax one.

Planning a move with a German, Dutch or UK tax history? Mirabello Consultancy coordinates the citizenship side with your tax advisers in each country, so that the order of steps is right from the start. Book a free, confidential consultation with our team in Zurich, Dubai or Hong Kong SAR.

How does the Dutch protective assessment on emigration work?

The Netherlands imposes a protective assessment (conserverende aanslag) when a resident with a substantial interest of 5% or more in a company emigrates: the shares are deemed disposed of and the gain is added to Box 2 income, taxed in 2026 at 24.5% up to EUR 68,843 and 31% above.

The Belastingdienst guidance on protective assessments explains that the same mechanism applies to pensions and annuities on which you enjoyed tax relief. For emigration to an EU or EEA country, payment is deferred automatically, without interest. For other destinations, deferral requires security such as a bank guarantee, a mortgage right or a pledge, with Norway, Iceland and Liechtenstein treated like EU states.

Timing rules differ by asset. Pension and annuity assessments can be cancelled after 10 years of compliance. For substantial interests, anyone who emigrated after 15 September 2015 receives a lifetime deferral instead: the assessment is never cancelled and becomes payable on later events such as a sale or certain dividends. The Box 2 rates and the 5% definition are published by the Belastingdienst.

What is the current Box 3 position in the Netherlands?

In 2026, Dutch Box 3 taxes savings and investments at 36% on a deemed return of 1.28% on bank balances and 6.00% on investments, with 2.70% deductible on debts and a tax-free allowance of EUR 59,357 per person. Taxpayers may show a lower actual return in their final assessment.

These figures come from the Belastingdienst page on the 2026 provisional assessment. Box 3 is not an exit tax: portfolio holdings below 5% are not deemed sold on emigration and drop out of Dutch Box 3 once you are no longer resident, apart from Dutch real estate, which remains taxable in the Netherlands.

The regime is in flux. The bill for a new system based on actual returns (Wet werkelijk rendement box 3, bill 36.748) was adopted by the Tweede Kamer on 12 February 2026 and is still pending in the Eerste Kamer as at 2 October 2026, with an intended start of 1 January 2028 and amendments announced by the government. Any Dutch plan should be re-checked against the final text.

Can Dutch citizens keep their nationality if they take a second passport?

As a rule, Dutch citizens lose Dutch nationality when they voluntarily acquire another citizenship, including citizenship by investment. The Dutch government lists three exceptions: birth and main residence in the new country, at least 5 uninterrupted years of main residence there as a minor, or acquiring a spouse's or registered partner's nationality.

This comes from the Government of the Netherlands page on automatic loss of Dutch citizenship, and none of the exceptions covers an investment route. For a Dutch citizen, a Caribbean passport is therefore not an add-on but a replacement, with consequences for EU rights, family and retirement that go far beyond tax. It needs careful reflection and specialist advice before any application.

The position is different for British and German citizens. The United Kingdom allows dual citizenship, and Germany has accepted multiple nationality since 27 June 2024.

Where does citizenship by investment fit in a cross-border plan?

Citizenship by investment fits into a cross-border plan as a mobility and contingency layer: it gives a family a second nationality, wider travel options and a fallback, but it does not move tax residence, end an exit charge or replace advice. Caribbean programmes start from USD 200,000 in Dominica.

The five Eastern Caribbean programmes are the most established. Each is a government-run route in which a contribution or qualifying investment, full due diligence and approval lead to citizenship for life, passed on to future generations. The table below uses the figures of record from our data backbone, cross-checked against each official programme site.

A regional regulator, ECCIRA (the Eastern Caribbean Citizenship by Investment Regulatory Authority), was established in December 2025 with an office in Grenada but is not yet operating; the Eastern Caribbean Central Bank expects it to begin later in 2026. Its proposed 30-day presence rule is not in force. Our country-by-country guide to the rules in force and the full comparison of all five programmes cover the detail.

What is Dominica citizenship by investment?

Dominica citizenship by investment grants citizenship from a USD 200,000 contribution to the Economic Diversification Fund for a single applicant, with no residence requirement. See the Dominica programme page.

What is Antigua and Barbuda citizenship by investment?

Antigua and Barbuda citizenship by investment grants citizenship from a USD 230,000 National Development Fund donation, with 5 days of presence required in the first 5 years. See the Antigua and Barbuda programme page.

What is Grenada citizenship by investment?

Grenada citizenship by investment grants citizenship from a USD 235,000 National Transformation Fund donation, with no residence requirement. See the Grenada programme page.

What is St Lucia citizenship by investment?

St Lucia citizenship by investment grants citizenship from a USD 240,000 National Economic Fund contribution for an applicant and up to 3 dependants. See the St Lucia programme page.

What is St Kitts and Nevis citizenship by investment?

St Kitts and Nevis citizenship by investment grants citizenship from a USD 250,000 Sustainable Island State Contribution for a main applicant or family of up to 4. See the St Kitts and Nevis programme page.

In what order should you plan an exit and a second passport?

A responsible plan runs in a fixed order: first understand your current tax position and any exit charge with a qualified adviser in your home country, then decide where you will genuinely live, then align banking and structures, and only then treat a second citizenship as the mobility layer that supports the plan.

1. Map the home-country position. Identify which assets an exit rule touches: UK land and the inheritance tax tail, German shareholdings of 1% or more, Dutch substantial interests of 5% or more and pensions. Obtain valuations where needed.
2. Decide where you will actually live. Tax residence follows real life: home, family, work and days. A new country of residence has its own rules and, often, its own residence permit. Residence routes such as the Portugal Golden Residence Permit or the UAE Golden Visa grant a right to live somewhere; whether you become tax resident there depends on that country's law and on how you live.
3. Check treaties and timing. Departure dates, the end of the tax year, treaty tie-breakers and temporary non-residence windows all affect the outcome.
4. Align banking and structures. Banks will ask for every tax residence under CRS. Our guides to banking with a Caribbean passport and Caribbean IBC company formation explain what is realistic.
5. Add the second citizenship. Choose a programme for its mobility, family and contingency value, using the citizenship by investment programme hub to compare routes. Dutch citizens must weigh the loss of Dutch nationality first.

How does CRS reporting affect second citizens?

Under the OECD Common Reporting Standard, banks report accounts to every jurisdiction where the holder is tax resident, not to the country of the passport used to open the account. Citizenship of a Caribbean state does not stop reporting to the UK, Germany or the Netherlands while you remain resident there.

The OECD also monitors residence and citizenship by investment schemes that could be misused to hide tax residence. It treats as potentially high risk any scheme that gives access to a personal income tax rate below 10% on offshore financial assets without requiring at least 90 days of physical presence, and it expects financial institutions to take its analysis into account in their due diligence. Honest disclosure of every tax residence is the only sound approach, and it is the one we insist on.

What mistakes should you avoid?

The most common mistakes are assuming a new passport ends tax residence, leaving before valuing shares caught by an exit tax, overlooking the UK inheritance tax tail, failing to declare every tax residence to banks, and, for Dutch citizens, applying for another nationality without realising Dutch nationality is lost.

• Confusing citizenship with residence. No tax authority in this guide treats a foreign passport as a reason to stop taxing a resident.
• Acting before advice. German and Dutch exit charges are crystallised on the departure date; restructuring after that date is far harder.
• Ignoring the return. Coming back to the UK within 5 years, or to Germany within 7, changes how gains and exit charges are treated.
• Relying on outdated rules. The UK non-dom regime ended on 6 April 2025, and Dutch Box 3 is mid-reform. Articles written before those dates may be wrong.

How Mirabello Consultancy helps

Mirabello Consultancy is a Swiss investment migration advisory with offices in Zurich, Dubai and Hong Kong SAR. We handle the citizenship and residence side of a move: programme selection, due diligence preparation, source-of-funds documentation and the application itself, in 11 languages. We work alongside your own tax advisers in the UK, Germany or the Netherlands, so that the citizenship step follows the tax analysis rather than leading it.

We are IMC members and ACAMS-certified, and we recommend a programme only when it genuinely fits your family.