Every client who has ever sat across from me can recite the cost of leaving. They have priced it to the decimal. The exit tax, the advisers, the property sale at an awkward moment in the market, the school fees in the new country, the flights back to see an ageing mother. Some of them arrive with a spreadsheet. The cost of leaving is vivid, itemised, and frightening.
Then I ask them a question that almost nobody has ever asked themselves: what does staying cost?
Silence. Not because the answer is zero. Because nobody has done the arithmetic. Staying feels free, the way the default option always feels free. You do not sign anything. You do not book a removal van. You simply wake up in the same house, in the same tax system, and another year begins.
But staying is not the absence of a decision. It is a decision, renewed every single year, with a price attached. And in 2026 that price is rising faster than at any point in my twenty years of doing this work.
Let me show you the invoice.
Belgium, or What "It Cannot Happen Here" Looks Like
For decades, Belgium was the quiet answer whenever a European investor asked me where private capital gains went untaxed. Not a palm-tree jurisdiction. A founding member of the EU, host of its institutions, with high income taxes and high social charges, and yet: sell your shares as a private investor and, in the normal case, no capital gains tax. Generations of Belgian families built their planning on that assumption. It felt permanent, in the way that only things which have always been true feel permanent.
It ended on 1 January 2026. Belgium now levies a 10% tax on realised capital gains on financial assets: shares, bonds, ETFs, certain insurance wrappers, crypto, even investment gold. There is an annual exemption of 10,000 euros, a separate regime for substantial shareholdings, and a step-up so that only gains accruing after 31 December 2025 are caught. EY has a clean summary of the mechanics, and I encourage you to read it, not because you necessarily care about Belgium, but because of what it demonstrates.
What it demonstrates is this: a tax advantage that had held for longer than most people's living memory was removed by one coalition agreement. No referendum. No transition decade. One government formation, one legislative push, and the assumption underneath thousands of family balance sheets was gone. Everyone who stayed in Belgium through 2025 on the theory that nothing ever changes there has now been repriced. The step-up softens the blow for the past. It does nothing for the future, which is the part you still have to live in.
The Belgians who moved in 2023 or 2024 paid the cost of leaving once. The Belgians who stayed will pay the cost of staying every year from now on.
The United Kingdom Buried a 200 Year Old Regime
I live and work in London. I watched this one from the front row.
The remittance basis for non-domiciled residents was part of the British tax landscape for over two centuries. It survived world wars, Labour landslides, and decades of hostile headlines. Sophisticated people assured each other at dinner parties that it would be reformed at the edges but never abolished, because the Treasury needed the money the non-doms brought.
It was abolished with effect from 6 April 2025. The government's own policy paper is admirably blunt: domicile is no longer a relevant connecting factor, the remittance basis is gone, and in its place stands a four year regime for new arrivals, after which the UK taxes you on your worldwide income and gains like anyone else. I wrote about what the end of non-dom means in practice when it happened, so I will not repeat the mechanics here.
The point, for tonight, is the speed. From "clearly here to stay" to "gone" took, in effect, two budgets. The people who restructured early did so calmly, with full option menus in front of them. The people who waited found themselves making major life decisions against a legislative deadline, which is the single worst way to make them. Some are still in the UK, paying worldwide tax on structures designed for a regime that no longer exists. That is the cost of staying, and it compounds annually.
Norway Is Running the Experiment in Public
Norway kept its wealth tax when almost every other developed country abandoned theirs, and then raised it. What followed has been covered extensively in the mainstream press: the Guardian reported in 2023 that wealthy Norwegians were leaving at a record rate, with Switzerland the favoured destination, and the flow has included some of the country's best known industrialists and founders.
I want to be careful with numbers here, because emigration statistics for the wealthy are notoriously slippery, and I have written before about my scepticism of headline millionaire migration figures. So let me put it qualitatively, which is how I actually hold it: the direction is not in dispute. Norwegian entrepreneurs with real operating businesses have relocated themselves and their holding structures abroad in numbers that Norway has not seen before, the government has responded by tightening the rules on leaving rather than reconsidering the rules on staying, and every Norwegian founder I have spoken to in the last two years has at minimum run the numbers on an exit.
Notice the pattern, because it repeats everywhere: when a country starts losing taxpayers, its first instinct is rarely to become more attractive. It is to make the door heavier. Which brings me to Germany.
Germany Widened the Definition of Leaving
Germany's Wegzugsbesteuerung, the tax on unrealised gains in company shareholdings when you emigrate, has been tightening for years. Since 2025 it also reaches large fund and ETF positions held by private investors, which quietly moved a whole class of people into scope who had previously assumed the leaving tax was a problem for founders and GmbH owners only. If you are German with a substantial portfolio and a vague plan to emigrate "at some point", you owe it to yourself to understand this regime in detail. My colleagues maintain a thorough German language guide to the Wegzugsbesteuerung and how to plan around it legally, and I would start there.
Here is the uncomfortable logic of it. Every year you stay, your untaxed gains grow, and with them the notional bill that crystallises on the day you finally leave. The leaving tax is not really a tax on leaving. It is a tax on having stayed too long. The cost of staying and the cost of leaving turn out to be the same number, observed at different points in time, and it only ever gets bigger.
France Is Telling You Where This Goes
France already has an exit tax. During the debates on the 2026 budget, the National Assembly went further and adopted an amendment that would have restored the old, much harsher regime, with a fifteen year monitoring period for those who leave. That amendment did not survive into the final Finance Act, and the current shorter monitoring periods still apply. I am reporting only what happened, not what was rumoured, because plenty of nonsense circulated last autumn.
But do not let the outcome obscure the signal. A majority in a major European parliament voted, in an ordinary budget cycle, to make leaving dramatically more expensive. It failed this time on legislative mechanics, not on principle. The direction of travel in France, as in Norway, as in Germany, is the same: the price of the door is going up. Nobody anywhere is legislating to make leaving cheaper.
The Arithmetic Nobody Does
So here is the calculation I walk clients through, and which I am inviting you to do honestly for yourself.
The cost of staying has two components. The first is the visible one: the taxes you actually pay each year in a high tax country, on income, on gains, on wealth where it exists, compounding negatively against everything you are trying to build. That number is large but at least it appears on paper.
The second component is the one that ruins people, and it never appears on any statement: the option value you burn. Every year you stay, some doors close. Belgium's no capital gains era is over for anyone who had not already realised gains or left. The UK remittance basis is gone for good; the people who could have used it and did not will never get that option back. Regimes you could enter today, residence programmes, favourable rulings, step-ups, grandfather clauses, will not all exist in three years, and the ones that survive will have longer queues and stricter terms. When I look back at twenty years of client files, the pattern is brutal: the expensive mistakes were almost never the moves people made. They were the moves people did not make while the window stood open.
Staying is a yearly renewed subscription whose price rises every year and whose cancellation fee rises every year too. The one thing it never does is stay constant.
And the windows close faster than people believe. Before 2009, a few hundred Americans a year renounced their citizenship; since FATCA it has run in the thousands, year after year, with waiting lists at consulates. Those are people executing, at real expense, a decision that would have been nearly free a decade earlier. The UK is generating its own leaver statistics right now, and whatever the precise figure turns out to be, every departure represents someone who concluded the cost of staying had finally, visibly, exceeded the cost of going.
What I Actually Advise
Not that everyone should leave. That is the caricature, and it is wrong. Plenty of my clients stay where they are, for family, for business, for love of home, and staying can be entirely rational once you know the price. What I advise is narrower and harder: price both sides, every year, deliberately. Know what your country costs you. Know what leaving would cost you today, because that number changes. Build the optionality now, the second residence, the compliant structure, the banking outside your home system, so that if the arithmetic flips, you can act in months rather than years.
The people in trouble in 2026 are not the ones who stayed. They are the ones who never knew staying was a choice.
Work with Sebastian
If you have never actually priced the cost of staying, that is the conversation to have, calmly and with real numbers, before the next window closes. Book a consultation.
