When you leave, Belgium and the Netherlands often still want to settle the tax on your accrued capital gains. Mapping this out in advance helps you avoid unpleasant surprises.
An exit tax is a levy your country of departure imposes on the latent capital gains in your shares or business at the moment you emigrate. Belgium is introducing such a regime (2026); the Netherlands has long had the protective assessment for a substantial interest (box 2). Both call for timely, well-considered planning.
As part of the new capital gains tax, Belgium provides for an exit regime: anyone who emigrates may be deemed to have disposed of their shares, so that the accrued capital gains are still brought into account. There are nuances (deferral of payment, guarantees, return within a certain period), but the principle is clear: leaving just before a major sale is not an escape route.
The precise modalities are evolving; we work with the current state of affairs.
Guide
Anyone emigrating with a substantial interest can face a conserving assessment on the latent gain. Whether you can defer it depends on how early and how carefully you plan.
A Dutch resident with a substantial interest (usually a shareholding of 5 percent or more) who emigrates receives a protective assessment: an assessment on the capital gain that only becomes collectible upon certain events (for example, a dividend distribution or sale). Payment is deferred subject to conditions. Box 3 (wealth) and the inheritance tax tail also play a role.
The rules are in flux; a timely analysis before departure is essential.
The common thread: plan in time and follow the right sequence. Those who build their structure well before a sale or emigration, with real substance, are in a stronger position than those who shift things at the last minute. We map out your exit position in advance and align the steps, so your departure is tax-compliant and defensible.
Within the law, not around it. We do tax optimisation and planning, always within legal boundaries. We do not cooperate with tax evasion, sham relocation or concealing assets. Genuine tax emigration requires a real move or a structure with sufficient substance. All figures on this page are general and indicative; they do not replace personal advice.
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