Capital gains after relocation to the EU
You relocate to a country within the European Union and become tax resident there. Assets were acquired before relocation: shares, crypto, business interests, real estate, or other capital assets. From your perspective, the logic seems intuitive: capital gains accrued before moving should belong to the past and fall outside the EU tax net. From the perspective of EU tax authorities, the decisive factor is when the gain is realised, not when it economically accrued. Tax residency at the moment of disposal determines whether — and how — the gain is taxed. As a result, capital gains realised after relocation can become fully taxable in the EU, even if most of the appreciation occurred abroad.
Input Data
- Tax profile: new EU tax resident
- Relocation timing: before or during the tax year
- Asset type: shares, crypto, business interests, funds, real estate
- Acquisition: prior to EU relocation
- Disposal: after EU tax residency is established
- Holding structure: personal or through entities
- Assumption: pre-move appreciation is not taxable in the EU
Jurisdiction Conflict
EU country of residence — taxation at realisation
- Tax residency triggers worldwide taxation
- Gains assessed at moment of sale or disposal
- Limited recognition of pre-residency appreciation
Former country — exit or continuing tax claims
- Potential exit tax or trailing taxation rules
- Disputes over valuation at departure
- Overlap in taxing rights
Timing mismatch
- Economic gain accrued pre-move
- Legal realisation post-move
- Different valuation baselines applied
The conflict is not about ownership. It is about which country has the right to tax the gain when it is realised.
AI Analysis
Scenario A — Full taxation in the EU
- Gain taxed without step-up or apportionment
- Original acquisition cost used
- Risk: high effective tax burden
Scenario B — Double taxation risk
- Former country asserts exit or residual tax
- EU taxes full gain on disposal
- Risk: incomplete relief
Scenario C — Revaluation dispute
- Disagreement on market value at relocation date
- Documentation insufficient
- Risk: reassessment and penalties
Key risk indicators
- Relocation shortly before asset disposal
- High unrealised gains at time of move
- Lack of valuation at entry into the EU
- Assets held in non-transparent structures
- Assuming informal "step-up" applies
- No coordination between exit and entry taxation
Output of Richys AI Analysis
- Timeline of residency and asset holding
- Gain allocation and realisation analysis
- Exposure modelling by jurisdiction
- Step-up and valuation recognition testing
- Double taxation risk mapping
- Identification of documentation gaps
Expert Boundary
Involvement of a verified EU expert is required for:
- country-specific capital gains rules
- recognition of entry valuation or step-up
- exit tax interaction
- defensive positioning in audits or assessments
Case Conclusion
Relocating to the EU does not reset the tax history of your assets. Capital gains taxation follows realisation under residency rules, not the geography of past appreciation.
The main risk lies in assuming that pre-move gains are protected by default. Without explicit valuation, coordination, and legal grounding, the EU may tax the full gain at disposal.
A structured case analysis clarifies where taxing rights arise, how gains are measured after relocation, and where expert input is required before unrealised appreciation turns into assessed tax.
Start case analysisThis case is for illustration purposes only. Real outcomes depend on residence, income structure, documents and timing. For your specific situation, use structured case analysis with AI and verified EU experts.
Mathieu Fiscalis
AI assistant – Taxes & Cross-Border Tax