Your Company When You Leave a High-Tax Country: Keep, Close or Relocate

Business Setup guide

Quick answer — what happens to your company when you leave a high-tax country? Your company does not leave with you. It usually stays tax resident where it was incorporated or where it is managed, and several countries — including Germany, Austria, France, the Netherlands, Denmark and Canada — can tax the unrealised gain on your shares when you emigrate. Founders choose between keeping the company and managing it from abroad, closing it, or relocating or restructuring it.

Executive Summary & Context

Most guides to becoming location-independent focus on where to go. For founders who already own a company, the harder question is what to leave behind. A German GmbH, a French SASU, a Dutch BV or a UK Ltd was built for a founder who lives in that country. Once you leave, three things change at once: your personal tax residency, the company's place of management, and the way your home country taxes your shares.

Handled well, the departure can be clean: the company continues, you pay yourself in a tax-efficient way from abroad, and any exit tax is deferred or paid in instalments. Handled badly, you can face an exit tax bill on value you never received, a company that remains fully taxable at home, and a new country that also claims a share of the profits.

Who this guide is for

Who it is not for

This guide is not for owners who are staying in their country, for employees changing jobs abroad, or for settled expats. For personal tax corridors, such as moving from France to Portugal, see our relocation guides instead.

Comparing all the situations a founder can be in? Go back to our overview on structuring your business when you go location-independent.

Legal Entities & Comparison Matrix

The table compares how the main departure countries treat a founder who leaves with shares in their own company.

CountryTypical entityExit tax on shares?Main triggerDeferral or relief
GermanyGmbHYesAt least 1% of a company, after long German residenceInterest-free instalments over seven years; relief if you return within a set period
AustriaGmbHYesUnrealised gains on sharesInstalments for moves within the EU/EEA
FranceSASU / EURLYesShares worth €800,000 or more, or at least 50% of a company's profitsAutomatic deferral for many destinations; discharged after a holding period
NetherlandsBVYes (protective assessment)Substantial interest of 5% or moreCollected on a sale or certain distributions; no automatic lapse for emigrations since 2015
DenmarkApSYesUnrealised gains on sharesDeferral available in many cases
SwedenABNo immediate exit taxGains on Swedish shares taxable for 10 years after leavingLimited by tax treaties
United KingdomLtdNo exit tax for individualsTemporary non-residence rules for returns within five years—
CanadaCorporationYes (departure tax)Deemed disposition of most assetsSecurity can be posted instead of paying immediately
United StatesLLC or corporationNo exit for moving; citizens stay taxableCitizenship-based taxationForeign tax credits, FEIE for earned income

Read each country guide

Substance, Residence & Compliance Governance

After you leave, your company sits between two countries: the one where it is registered and the one where you now live and work. Four rules decide where it is taxed.

1. Your company's residence does not follow you automatically

Most countries treat a company incorporated there as resident there, and many also treat a company as resident where it is effectively managed. After you move, your old company may therefore be resident in your old country by incorporation and in your new country by management. The tax treaty between them then decides, often through a tie-breaker based on effective management or a mutual agreement between tax authorities.

2. Your new home can become a permanent establishment

If you run the company from your new country, your home office or regular workplace there can create a permanent establishment of the company. Part of its profits would then be taxed in your new country, with registration and filings there.

3. Exit tax on your shares

Several countries tax the unrealised gain on shares in your company when you cease to be resident, as if you had sold them. Thresholds, deferral options and the time after which the tax lapses differ widely. If your company has grown in value, this can be the largest single cost of leaving.

4. Paying yourself across the border

AML/KYC and administration

Banks will update your file when your address and tax residence change, and may ask for a tax residency certificate from your new country. Update beneficial-ownership registers, company registers and tax authorities with your new address, and keep a registered office or domiciliation service in the company's country.

Setup Costs & Economic Model

There are three ways to deal with your company, and each has its own cost profile.

OptionWhat it involvesMain costsWorks best when
Keep the companyIt stays in your old country; you manage it from abroadDomiciliation, local accounting, possible permanent establishment filings in your new country, exit tax on shares if applicableClients, contracts or staff are tied to the old country
Close the companyLiquidate before or after you leaveLiquidation fees, tax on distributed reserves, possible exit tax if you leave firstThe business is personal to you and can restart abroad
Relocate or restructureMove the business to a new entity in your new country, sell assets or transfer the company's seatLegal fees, corporate exit tax on transferred assets, valuation costsYou will build the business from your new home long term

The economic model

The cheapest option depends on three numbers:

  1. The current value of your shares compared with what you paid for them — this drives any exit tax.
  2. The reserves inside the company — these are taxed when distributed or liquidated.
  3. The future profit you expect — this decides how much the corporate tax rate in your old versus new country matters.

A founder with a small company and few reserves may simply close it and start again abroad. A founder with a valuable company may keep it, defer the exit tax and plan distributions carefully. Model all three options before your departure date.

Step-by-Step Formation & Business Banking

Start planning six to twelve months before you leave. Most of the expensive mistakes happen in the last few weeks.

  1. Value your company and estimate any exit tax on your shares under your country's rules.
  2. Decide between keep, close and relocate, using the cost profile above and your expected future profits.
  3. Check the tax treaty between your old and new country: company residence tie-breaker, dividend withholding, director's fees and social security.
  4. Plan the timing of distributions. Paying a dividend or liquidating before or after you leave can change the tax dramatically.
  5. Apply for any exit tax deferral or instalment plan and arrange security if required.
  6. Set up the governance you will keep: who signs, where board decisions are taken, and whether you need a local director or registered office.
  7. Deregister personally from your old country and register in your new one; obtain a tax residency certificate when you qualify.
  8. Update banks, registers and tax authorities with your new address and tax residence.

Business banking after you leave

Most banks keep the company account open after you move, but they will review your file. Expect questions about your new residence, the company's activity and where it is managed. If your bank restricts non-resident managers, add an account with a payment institution in the company's country or region before you leave.

The Founder Exit Guide lists everything to do in the 12 months before and after your departure — get it when you plan your company's exit with Heavnn.

Frequently Asked Questions (FAQ)

Can I keep my company when I move abroad?

Yes, in most countries. The company stays registered and taxed where it is, and you manage it as a non-resident. Check whether your new country could treat the company as managed there or as having a permanent establishment there.

What is an exit tax on company shares?

It is a tax some countries charge when you stop being resident, calculated as if you had sold your shares at their market value. Germany, Austria, France, the Netherlands, Denmark and Canada all have versions of it, with different thresholds and deferral options.

Should I close my company before leaving?

It depends on its value and reserves. Closing first can avoid cross-border complications but triggers tax on distributed reserves. Keeping it can make sense if it has clients, staff or contracts tied to the country, or if exit tax can be deferred.

Will my company still be taxed in my old country after I leave?

Usually yes, if it remains incorporated there. Your new country may also tax part of its profits if you manage it from there. The tax treaty decides how double taxation is avoided.

How do I pay myself from my old company once I live abroad?

Most founders use dividends, which face withholding tax in the company's country and tax in their new country. Salary or director's fees can remain taxable in the old country under some treaties and may keep you in its social security system.

Plan Your Company's Exit with Heavnn

The best time to plan your company's exit is six months before you leave. Heavnn models keep, close and relocate side by side for your situation.

Plan your exit with Heavnn →

This guide is general information, not tax or legal advice. Rules are summarised as of October 2026.

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