Published: 08-05-2025<\/p>\n\n\n\n
With the entry into force of Law 26\/2014, of November 27, Spain introduced a significant measure in the field of international taxation: the so-called exit tax<\/em> under the Personal Income Tax (IRPF). Published in the Official State Gazette (BOE) on November 28, 2014, this tax aims to prevent tax avoidance and ensure that the relocation of tax residence by individuals with substantial financial assets does not result in a loss of revenue for the Spanish tax authorities.<\/p>\n\n\n\n The exit tax applies to unrealized capital gains\u2014those not yet materialized through a sale\u2014arising from shares or holdings in certain entities when the taxpayer transfers their tax residence abroad before disposing of them. The goal is to prevent capital gains generated while the taxpayer was a Spanish resident from escaping national taxation simply due to a change in residence.<\/p>\n\n\n\n This tax regime only applies if the taxpayer has been a Spanish tax resident for at least 10 of the 15 tax years prior to the final year in which they are subject to IRPF. In addition to the residency condition, one of the following financial thresholds must be met:<\/p>\n\n\n\n The exit tax only applies to assets representing participation in the equity of companies or entities\u2014such as shares, corporate interests, or units in collective investment schemes. Other financial assets such as bonds, deposits, or derivatives are not affected.<\/p>\n\n\n\n If the taxpayer moves to a country within the European Union or the European Economic Area (Iceland, Liechtenstein, or Norway), and there is an effective exchange of tax information, payment of the exit tax may be deferred, provided that the taxpayer:<\/p>\n\n\n\n However, the tax must still be paid if, within the following 10 tax years:<\/p>\n\n\n\n If the relocation is temporary and the destination country is not classified as a tax haven or has a double taxation agreement with Spain, the taxpayer may request a deferral of the exit tax payment. This applies in two cases:<\/p>\n\n\n\n In both situations, the request must be submitted within the tax return period and is subject to providing adequate guarantees.<\/p>\n\n\n\n It is possible to recover the exit tax paid if the taxpayer returns to Spain as a tax resident without having disposed of the shares or interests. In that case, they may file an amended tax return and request a refund of the amount paid, including any late payment interest from the date of payment until the refund.<\/p>\n\n\n\n The exit tax is a fiscal tool designed to ensure that significant wealth is not excluded from taxation simply by changing tax residence. While it doesn\u2019t apply to everyone, individuals with major equity holdings or investment portfolios should carefully assess its impact before relocating.<\/p>\n\n\n\n Furthermore, with the upcoming increase in savings income tax rates from 2025, the overall tax burden may rise. Proper planning and foresight are essential.<\/p>\n\n\n\nWhat does the Exit Tax apply to?<\/strong><\/h2>\n\n\n\n
Scope of Application: Subjective and Objective Requirements<\/strong><\/h2>\n\n\n\n
Subjective Requirements<\/strong><\/h3>\n\n\n\n
For individuals who were covered under the special tax regime for inbound workers (the \u201cBeckham Law\u201d), years during which that regime applied are not counted. The calculation starts from the first year following the end of that regime.<\/p>\n\n\n\nObjective Requirements<\/strong><\/h3>\n\n\n\n
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Which assets are included?<\/strong><\/h2>\n\n\n\n
Special cases depending on the destination country<\/strong><\/h2>\n\n\n\n
Relocations within the EU or EEA<\/strong><\/h3>\n\n\n\n
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Temporary relocations to non-EU\/EEA countries<\/strong><\/h3>\n\n\n\n
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Exit Tax refunds<\/strong><\/h2>\n\n\n\n
Changing your tax residence? We can help.<\/strong><\/h3>\n\n\n\n