Close the avoidance routes by design. Citizenship-based taxation on worldwide wealth, a deemed-disposal exit charge crystallising liability the moment someone ceases UK tax residence — not only on renouncing citizenship — an equity-stake mechanism so illiquid family businesses aren't forced into liquidation, and real-time public transparency of every valuation and relief claimed.
Current Assessment
At 95%, contesting valuations or leaving the country becomes the most valuable financial move open to any significant estate. This claim is the design meant to close the routes that make that possible. The tax applies to every class of asset (property, shares, private companies, intellectual property, crypto, art, pensions and foundations). An exit tax is triggered by ceasing to be UK tax resident, not only by giving up citizenship. And a deferred-payment and equity-stake mechanism means a business owner isn't forced into a fire sale.
Evidence
Three comparable countries already have exit taxes that treat assets as sold when someone leaves. The US (IRC §877A) does so on expatriation, taxing gains above $910,000 at normal capital gains rates.1 France (Article 167 bis) triggers on a change of tax residence after 6 of the previous 10 years as a resident, with payment deferred for moves within the EU/EEA.2 Norway tightened its rules in 2022: unrealised gains above NOK 3 million are taxed at 37.8% on departure, with deferral capped at 12 years.3 The UK Treasury seriously considered a similar 20% "settling-up charge" for the November 2025 Budget, expected to raise around £2bn a year. It wasn't adopted, but it shows the mechanism isn't a fringe idea.4 Wealthy departures from Norway roughly doubled in the two years after 2022, when it both raised its wealth tax and tightened its exit tax: 261 residents with assets above NOK 10m left in 2022 and 254 in 2023. The exit tax's own effect can't be separated from the wealth tax rise.5
At a 95% rate, contesting valuations or leaving the UK before death becomes the main financial consideration for any significant estate, a far stronger incentive than any of the three precedent countries face, since none taxes transfers at anything like 95%. The precedents show that an exit tax raises the cost of leaving and recovers some revenue from those who go anyway. Norway's doubling of departures after a much smaller change shows it doesn't stop people leaving. At 95% the incentive to leave is much stronger than anything these mechanisms have been tested against, so the expectation of similar but incomplete effectiveness is this project's own inference from the three cases, not something any of them shows for a rate this high.
No exit tax, relying on the inheritance tax alone and accepting the departures that follow; an exit tax triggered only by giving up citizenship; or this claim's design, triggered by residence, applied to every asset class, with deferred payment and an equity stake for businesses that can't easily be sold.
Choosing a residence-triggered exit tax over a citizenship-only trigger or none at all reflects a judgement that protecting the tax base is worth the added complexity, and worth the risk of pushing out some people who would otherwise have stayed. A reader who gives more weight to people's freedom to move, or who thinks that risk is larger than this project does, isn't wrong about the evidence; they weigh it differently.
Citizenship-based taxation on worldwide wealth; an exit charge triggered by ceasing UK tax residence, not only by giving up citizenship; deferred payment through an equity stake so family businesses that can't easily be sold aren't forced to sell; and real-time publication of every valuation and relief claimed. The claim's open question, how many countries would need to cooperate for this to work, is set out in the Assumptions below instead of being treated as settled.
Assumptions
- An exit tax raises the cost of leaving without preventing it. Norway is the evidence here: wealthy departures roughly doubled in the two years after its 2022 changes, though those combined a wealth tax rise with the exit tax tightening, so the exit tax's own effect can't be isolated. As the pillar puts it, an exit tax recovers revenue from those who leave anyway; it doesn't stop them leaving.
- International cooperation helps but isn't needed for the tax to partly work. Physical assets can't move, and registered shares can be traced whether or not other countries cooperate. The claim doesn't depend on every country taking part to capture most UK wealth, which is held in forms that can't leave the country or have no reason to.
- The smallest workable group of cooperating countries is unknown. The Gaps Register records this as unresolved.
Cross-Pillar Relationships
| Pillar | Connection |
|---|---|
| Tax Avoidance | This claim extends that pillar's exit tax proposal on one point, the trigger (residence, not only citizenship), building on the US precedent this page also cites. |
| Wealth Tax or Inheritance Tax? | Identifies a real change of tax residence, kept up for years and checked at death, as the main avoidance route under the current system: the route this claim's exit tax is meant to close. |
Challenges
No challenges submitted yet. Submit one via Challenge a Claim.
Update History
- 23 October 2026: Rewritten in plain prose. No change to the claim or its figures.
- 14 October 2026: Audit. Norway's post-2022 doubling of wealthy departures (261 in 2022, 254 in 2023; Civita via Reuters) is now attributed to the combined 2022 changes, a wealth tax rise as well as the exit tax tightening, instead of to the exit tax alone.