Moving to Malta is not just about what happens when you arrive. It is about what happens in the country you leave.
Most residency and tax guides focus entirely on the destination. They tell you about the 15% flat rate, the non-dom exemption, the zero capital gains tax. What they do not tell you is that your home country may want a parting payment before you go — and that if you leave without planning it correctly, you may face a bill you did not see coming.
Here is what British, Irish, and Australian residents need to know before they buy their plane tickets.
Leaving the United Kingdom
The UK does not have a classic “exit tax” on unrealised gains. What it has is more nuanced — and in some ways more dangerous, because it catches people off guard.
CGT on departure year: In the tax year you leave the UK, you are UK-resident for part of the year and non-resident for the rest (under the Statutory Residence Test’s split-year rules). Gains realised on UK assets after your departure date may escape UK CGT. Gains on non-UK assets realised after departure are generally not taxable in the UK. But gains realised before your departure date — even if you have already committed to leaving — are taxed at UK rates (20% for most assets, 24% for residential property).
The “Temporary Non-Residence” trap: If you leave the UK, realise gains abroad, and return within 5 years, HMRC will tax those gains as if you had been UK-resident the whole time. This is the rule that catches entrepreneurs who move to Malta, sell a business after two years, and then move back. You must stay outside the UK for at least five complete tax years for gains realised during your absence to be permanently outside HMRC’s reach.
The 90-day rule: Under the UK Statutory Residence Test, you become non-resident if you spend fewer than 16 days in the UK in a tax year (if you have been a resident for the previous 3 or more years, you get up to 45 days — but only if you have no UK ties). Keep a diary. Count the days. HMRC does.
Pension implications: UK pension funds remain subject to UK rules regardless of where you live. The recent changes to UK pension taxation (the removal of the pension lifetime allowance) and the proposed inclusion of pension funds in estates for IHT purposes — being debated as of 2025 — may affect the planning calculus significantly. Get specific advice on your pension position before you leave.
What to do: Take formal tax advice on your departure date, your split-year treatment, and any assets you plan to realise in the near term. Do not realise significant gains in the same tax year you plan to leave — if you can avoid it, leave first.
Leaving Ireland
Ireland has one of the most aggressive exit tax regimes in the EU, introduced in the Finance Act 2019 as part of the EU’s Anti-Tax Avoidance Directive (ATAD) implementation — and going further than the directive required.
Irish Exit Tax (Section 627A TCA 1997): When an Irish tax-resident individual ceases to be Irish-resident, they are deemed to have disposed of and immediately reacquired all assets held at the date of departure at market value. CGT (currently 33%) is payable on the unrealised gains on those assets — not when they are actually sold, but at the moment of departure.
This is the textbook exit tax. If you have built up €2 million of unrealised gains in a share portfolio, company equity, or investment property, Revenue Ireland will send you a bill for €660,000 as you walk out the door.
The payment mechanism: The deemed disposal is treated as occurring on the date you cease to be Irish-resident. The CGT must be paid on the normal CGT payment dates. There is a deferral mechanism available for assets that remain in the EU/EEA — but it requires an annual reporting obligation and a guarantee or security in some cases.
What is caught: Shares, bonds, investment funds, company interests, most financial assets. Personal use assets (your home, a car) are generally outside scope.
What to do: This requires specific, detailed planning well in advance of leaving Ireland. The options include:
- Realising gains and paying Irish CGT before departure (pays the tax now but clears the obligation)
- Structuring holdings so that qualifying EU/EEA deferral applies
- Timing the departure to coincide with periods of low unrealised gain (difficult to control)
- Using the principal private residence relief on property where available
The Irish exit tax is one of the most punishing departure charges in Europe. If you are Irish-resident with a meaningful investment portfolio and you are planning to move to Malta, get Irish tax advice before you do anything else.
Leaving Australia
Australia’s tax system treats departing residents with particular aggression — and particular complexity.
Australian CGT on departure: When you cease to be an Australian tax resident, you are deemed to have disposed of most Australian and foreign assets at market value on the date of departure. The deemed disposal triggers CGT on unrealised gains. This is Australia’s exit tax — they call it the “cessation of residency” CGT event.
The exceptions: Australian real property (taxable Australian property) and assets of an Australian permanent establishment are not subject to the deemed disposal — they remain within Australia’s CGT net regardless of where you live, and CGT will apply when you actually sell them.
The 50% CGT discount: If you have held assets for more than 12 months, you may be entitled to the 50% CGT discount on gains — reducing the effective rate from 45% (top marginal rate) to approximately 22.5%. This discount is available at the time of deemed disposal on departure, provided the 12-month holding period has been met.
The practical sting: If you have significant shares, a business interest, or investment assets outside Australia, the deemed disposal on departure can create a substantial tax bill — payable immediately, before you have actually received any cash from selling those assets.
What to do:
- Consider realising gains on assets that are close to the 12-month mark before departure (to access the 50% discount while you are still resident)
- Timing departure carefully relative to the financial year (1 July to 30 June)
- Specifically planning for any Australian real property, which remains taxable regardless
- Getting ATO-specific advice on your residency status — Australian tax residency is a facts-and-circumstances test, and the ATO applies it strictly
The superannuation question: Australian superannuation remains in Australia regardless of where you live. You cannot generally access it until preservation age. It is not directly affected by the exit CGT event, but its interaction with the Maltese non-dom system — and whether Maltese or Australian tax applies to eventual withdrawals — requires specific planning.
The Common Thread
In all three countries — the UK, Ireland, and Australia — the tax man does not simply let you walk away. The mechanisms differ, but the principle is the same: years of tax-deferred capital appreciation are taxable on or around the date you leave.
The good news: with planning, the exposure can be significantly reduced. The bad news: the planning needs to happen before you leave, not after you have arrived in Malta and realised the problem.
[Book a consultation](/consultation) before you commit to a departure date. This is the conversation that pays for itself.