
Which countries keep taxing citizens after they leave? 17 jurisdictions ranked on verified primary law, plus the Watch board tracking who's next.
Most tax systems attach to residence. You leave, and eventually you stop being a taxpayer. A minority attach to the passport itself. This index measures whether a country's tax claim survives your departure because of your nationality, and how much of your life it still touches once you're gone.
Passport indexes rank what a passport gets you. This one measures what it costs you after you leave.
| # | Jurisdiction | Tier | Severity | The rule | How long | Flags | Evidence |
|---|---|---|---|---|---|---|---|
| 1 | 🇺🇸 United States | 1 | 94 | Worldwide taxation of all citizens and green-card holders; exit itself is taxed (§877A); tax debt can revoke your passport (§7345) | Perpetual | ⬇ loosening | A |
| 2 | 🇪🇷 Eritrea | 1 | 90 | 2% Recovery & Rehabilitation Tax on all diaspora income, collected through consulates; non-payment blocks documents and entry | Perpetual | ⚠ coercive | A law / C practice |
| 3 | 🇲🇲 Myanmar | 1 | 88 | Foreign-salary exemption for non-resident citizens abolished Oct 2023; 2% flat or progressive, whichever lower; paid at the embassy or no passport renewal | Perpetual | ⚠ coercive ⬆ | A law / C practice |
| 4 | 🇫🇷🇲🇨 France–Monaco | 2 | 80 | French nationals who move to Monaco are taxed as French residents under Art. 7-1 of the 1963 convention, with wealth tax (IFI) added for post-1989 movers; a second nationality does not help | Perpetual | A (BOFiP + Conseil d'État) | |
| 5 | 🇭🇺 Hungary | 1 | 72 | Every Hungarian citizen is tax resident unless a dual national with no Hungarian home; the US treaty termination (effective 2024) made US-based mono-nationals a live case | Perpetual (while mono-national) | 🛡 treaty-shielded | A |
| 6 | 🇹🇯 Tajikistan | 2 | 68 | The Tax Code deems citizens of Tajikistan tax residents; citizens in state service abroad are residents regardless of duration; a foreign permanent domicile appears to break the deeming (carve-out under final translation) | Perpetual (while citizen, absent foreign domicile) | ◌ enforcement gap | A law / C practice |
| 7 | 🇯🇵 Japan | 3 | 66 | Worldwide inheritance & gift tax reach for Japanese-national heirs/donees where either side had a Japanese jūsho within 10 years; foreign nationals in the same position are limited taxpayers | 10 years | A | |
| 7 | 🇳🇱 Netherlands | 3 | 66 | Dutch nationals deemed resident for gift & inheritance tax for a decade after emigrating (non-nationals: 1 year, gifts); upheld by the CJEU in Van Hilten-van der Heijden | 10 years | A (statute + CJEU) | |
| 9 | 🇸🇪 Sweden | 2 | 63 | Five-year reversed burden of proof on essential ties for departing Swedish citizens (non-citizens only after 10 years' residence); citizenship is itself the first statutory tie factor | 5 years | ◐ hybrid | A (Riksdag + Skatteverket) |
| 10 | 🇩🇪 Germany | 3 | 62 | Extended unlimited inheritance-tax liability for German nationals for 5 years after departure (10 for US movers); §§2/4 AStG extend reach to year ten for low-tax movers; upheld by the BFH | 5–10 years | A | |
| 11 | 🇪🇸 Spain | 2 | 61 | Art. 8.2 LIRPF "cuarentena fiscal": nationals moving to a listed non-cooperative jurisdiction stay full IRPF taxpayers, automatically, with no escape clause | Year of move + 4 | A (AEAT + statute) | |
| 11 | 🇫🇮 Finland | 2 | 61 | Finnish citizens remain resident for 3 years after departure unless they claim and prove no essential ties; covers every departing Finn | 3 years | A (Verohallinto + KHO) | |
| 13 | 🇮🇹 Italy | 2 | 56 | Citizens moving to blacklisted states are presumed still resident, burden reversed, indefinitely, year by year; catches even transfers routed through a clean third country (Cass. 14240/2021) | Indefinite, rebuttable | A (statute + Cassazione) | |
| 14 | 🇲🇽 Mexico | 2 | 54 | Moves to preferential-regime jurisdictions keep you resident for the year of notice + 5; plus a rebuttable presumption over all nationals and an automatic rule for officials abroad | Year + 5 | A (statute) | |
| 14 | 🇵🇹 Portugal | 2 | 54 | Blacklist quarantine for Portuguese nationals, year of move + 4. Rebuttable, though: proof of legitimate reasons (a posting by a Portuguese employer, say) defeats it. Spain's rule has no such exit | Year of move + 4 | A (Portal das Finanças + CAAD) | |
| 16 | 🇹🇷 Turkey | 2 | 47 | Citizens abroad attached to Turkish public institutions or Turkey-headquartered enterprises remain fully taxable; nationals presumed resident absent documented residence abroad | While affiliated | 🛡 partial | A (GİB) |
| 16 | 🇮🇳 India | 2 | 47 | Citizens with >₹15 lakh Indian-source income who are tax-resident nowhere are deemed resident (RNOR); retained in the new Income Tax Act 2025 | Indefinite while nowhere-taxed | A (Income Tax Dept) |
Monitored, unscored: 🇨🇳 China. The domicile concept ties to household registration (hukou), which only citizens hold, and there was reported enforcement against citizens abroad in 2020. Evidence is Grade C, so China publishes as a monitored case until the legal mechanics are clear.
Reading the board. One country has industrialized citizenship-based taxation. Two dictatorships run coercive versions through their passport offices. One micro-treaty makes an entire nationality permanently taxable in a single destination. Below them sits a long tail of democracies with nationality hooks that most advisors never mention. That gap between #1 and everything democratic is what the board actually shows.
A note on what severity measures: coverage and escapability, not rate. Eritrea's 2% scores near the US regime because the axis asks how much of your life the claim touches and how hard it is to shake off. The invoice amount is a different question, and the dashboard carries a rate-burden field next to every score so both readings are visible.
What the verification pass changed. We expected Portugal to mirror Spain. It doesn't. The statute contains an escape clause ("razões atendíveis") that Spain's rule lacks, so Portugal fell from 61 to 54 and the two rules everyone treats as twins turn out to differ where it counts. You only see this at statute level; every secondary summary we checked missed it. France–Monaco moved the other way, up to 80: the French tax administration's own doctrine confirms that a second nationality does not defeat Article 7-1, and Article 7-3 extends the claim to wealth tax. Tajikistan left quarantine and entered the index, because the official code text deems citizens residents. We could not find that finding anywhere in English. And we corrected ourselves on the Zucman mechanism: its tools are exit taxes and collector-of-last-resort rules, which are residence-based, so an earlier draft's description of it as nationality-based was wrong and is now changelogged as such.
Separate instrument, separate logic. Every input is a recorded institutional event: a vote, a filing, a published document. No sentiment.
| Jurisdiction / body | Watch score | Highest rung reached | Direction | The story |
|---|---|---|---|---|
| 🇫🇷 France | 38 | Committee adoption, two budgets running | ⬆ | The impôt universel ciblé (nationals, >~€230k income, destinations taxing ≥40% below France, 3-of-last-10-years residence) passed the finance committee in Oct 2025 and lost the Assembly floor vote by one vote, with support spanning LFI to the RN. The EU-law dampener applies but is nuanced: de Lasteyrie constrains exit taxes on unrealized gains, while Van Hilten-van der Heijden upheld a nationality-based trailing fiction. The CJEU is not a blanket bar. |
| 🇺🇸 United States | 15 (repeal side) | Bill tabled, awaiting reintroduction + JCT score | ⬇ | The LaHood residence-based taxation bill has presidential endorsement and bicameral coordination; excluded from the 2025 tax act; not law, not imminent. Still: the only top-of-index country actively debating exit from CBT. |
| G20 / UN track | adjacent | Blueprint + ministerial endorsements | ⬆ | The Zucman blueprint's anti-relocation tools are strengthened exit taxes on departing residents and "tax collector of last resort" mechanisms. Residence-based, so outside this index's scope rule. Tracked anyway, because it normalizes trailing taxation of the wealthy and feeds the precedent amplifier of endorsing countries. |
| 🇮🇳 India | — | Enacted (sits in Index) | ⬌ | Watch note: the ₹15 lakh threshold and RNOR scope are the two levers a future Finance Act would tighten. |
One thing: whether, and how much, a country's tax claim on a person survives their departure because of their nationality. Three questions per jurisdiction. Does nationality create or extend a tax claim (classification)? How much of a non-resident citizen's economic life does the claim cover, and how hard is it to escape (severity)? And for countries without such a claim, how likely are they to introduce one (Watch, a separate instrument)?
A rule is in scope only if nationality or citizenship of the taxing state is a necessary element of the connecting factor. If the same rule would catch a foreigner in identical circumstances, it's out.
This single test carries most of the index's defensive weight. The most predictable attack on any CBT publication is conflation: padding the list with exit taxes, temporary non-residence rules, and residence-history tails that apply to anyone regardless of passport. Those rules are real, and they matter to clients. They are not citizenship-based taxation, and mixing them in hands critics an easy kill shot. We applied the test against our own work in this release. The Zucman blueprint's anti-relocation mechanism, described in an earlier draft as nationality-based, is built on exit taxes over departing residents and collector-of-last-resort rules. That's residence-based, so we reclassified it.
In scope: the US worldwide regime and its expatriation tax; Eritrea's Recovery and Rehabilitation Tax; Hungary's citizen-residence rule; Myanmar's non-resident citizen tax; Tajikistan's citizen-residence deeming; Turkey's Art. 3 full liability for state-affiliated citizens abroad; Spain's and Portugal's national-quarantine rules; Mexico's Art. 9 nationality rules; Italy's citizen presumption; Finland's and Sweden's citizen-triggered tail presumptions; the nationality-conditioned inheritance and gift tails of the Netherlands, Germany and Japan; the France–Monaco convention's Article 7; India's deemed residency for nowhere-taxed citizens.
Out of scope (Annex C, with reasons): UK temporary non-residence; Norway's exit tax and three-year rule; Canada's departure tax; Ireland's ordinary-residence tail; Spain's Art. 95 bis and France's Art. 167 bis exit taxes; Germany's §6 AStG exit tax (its §2 AStG, which is nationality-conditioned, is included instead); sub-national rules; taxes on non-citizens conditioned on citizenship status (the 2025 US remittance excise); and the Zucman/G20 mechanisms (residence-based; tracked as adjacent).
Borderline rules mixing nationality with other triggers carry a hybrid flag and are scored on the nationality leg only. Sweden's presumption, which covers citizens and ten-year former residents alike, is the standing example.
Instrument 1, the CBT Index: enacted law only. Instrument 2, the CBT Watch: proposals and introduction risk, scored on institutional facts. They publish side by side and never combine into one number. Blending enacted law with speculation about future law is the second most predictable attack, and a fair one. A jurisdiction exits the Watch and enters the Index the day a rule takes legal effect, and vice versa on repeal.
We considered a third pillar, public opinion, and dropped it entirely. Sentiment scoring is unfalsifiable, and one unfalsifiable component contaminates the whole instrument. Political appetite shows up better in the feasibility ladder (Section 6), which counts votes.
Tier 1 — Full CBT. Nationality alone sustains worldwide (or near-worldwide) income taxation of non-resident citizens as a general rule. Members: United States, Eritrea, Myanmar (since October 2023), Hungary (for mono-nationals, with treaty override where a treaty exists).
Tier 2 — Conditional CBT. Nationality sustains full tax residence in defined circumstances: destination-based, status-based, gap-based, or defeasible deeming. Members: France–Monaco, Tajikistan, Sweden ◐, Spain, Finland, Italy, Mexico, Portugal, Turkey, India.
Tier 3 — Targeted nationality tails. Nationality extends liability for specific taxes after departure rather than general income-tax residence. Members: Japan, Netherlands, Germany.
Flags (orthogonal to tiers):
| Flag | Meaning | Holders |
|---|---|---|
| ⚠ Coercive enforcement | Collection via document denial, consular pressure, or threats rather than ordinary assessment | Eritrea, Myanmar |
| 🛡 Treaty-shielded | Overridden where a tie-breaker treaty applies; bite concentrated in non-treaty cases | Hungary, Turkey (partial) |
| ◐ Hybrid | Nationality is one of several alternative triggers | Sweden |
| ◌ Enforcement gap | Statutory claim demonstrably broader than collection practice | Tajikistan |
| ⬇ Loosening / ⬆ Tightening | Active legislative movement toward repeal or expansion | US ⬇ · France, Myanmar ⬆ |
Treaty shields are volatile, so every one carries dates. The US notified Hungary on 8 July 2022, the treaty terminated on 8 January 2023, and it ceased to have effect for withholding on payments and for taxable periods beginning on or after 1 January 2024 (IRS Announcement 2024-5). The documented consequence: since 2024, Hungarian citizenship, or a registered Hungarian address for dual HU-US citizens, produces Hungarian tax residency with worldwide taxation and a foreign tax credit capped at 90% of the 15% rate. Shield status is re-verified every cycle.
Each entry receives two sub-scores, published separately and summed into a headline. We keep them separate because collapsing them hides the distinction clients pay for. Hungary's rule is narrow but permanent. Spain's is broader but time-boxed and avoidable by destination choice. One number can't hold both facts.
Rule-level scoring. The scoring unit is the rule, not the country. Jurisdictions with several nationality rules score each (Mexico has three; Germany, Sweden, Portugal and Tajikistan each have an officials rule alongside the main one), and the headline is the most severe charging rule. Pure burden-of-proof presumptions are typed presumption: they shift the burden rather than impose liability, so they display alongside but only set the headline where no charging rule exists, which is Italy's situation. This split exists because early calibration produced a rebuttable paperwork presumption outscoring Spain's inescapable five-year quarantine. Any competent reviewer would have shredded that, and they'd have been right to.
Axis 1 — Scope (0–50): how much of a non-resident citizen's economic life the claim covers.
| Component | Max | Anchors |
|---|---|---|
| Taxes covered | 15 | Income + gains + wealth transfer = 15 · income tax broadly = 10 · income + a wealth-tax component = 12 (documented interpolation) · single tax type (inheritance/gift, or a single flat levy) = 5 · single income category = 4 |
| Base within those taxes | 10 | Worldwide, all sources = 10 · worldwide with major categorical exclusions = 6 · source-limited = 3 |
| Population covered | 15 | All citizens = 15 · citizens absent a defined status escape (mono-nationals; no foreign permanent domicile) = 10 · listed-destination movers = 8 · nowhere-taxed only = 6 · state-affiliated only = 4 |
| Relief architecture | 10 | None = 10 · foreign tax credit only = 7 · FTC + exclusions = 4 · relief eliminates most liability in practice = 1 |
Axis 2 — Persistence (0–50): how long the claim lasts and how hard it is to defeat.
| Component | Max | Anchors |
|---|---|---|
| Duration | 20 | Perpetual = 20 · ≥10 years = 12 · indefinite but rebuttable/conditional = 10 · 5–6 years = 8 · ≤5 years = 6 |
| Defeat mechanism | 15 | Automatic, irrebuttable = 15 · rebuttable presumption (burden on taxpayer) = 8 · avoidable by destination or status choice = 6 · avoidable by simple filing/proof = 3 |
| Cost of the ultimate exit (renunciation) | 10 | Renunciation taxed or conditioned = 10 · fee/formalities only = 4 · free and effective = 2 |
| Enforcement apparatus | 5 | Extraterritorial reporting regime or document coercion = 5 · treaty collection assistance = 3 · none practical = 1 |
Worked example, United States: Scope 15+10+15+4 = 44. Persistence 20+15+10+5 = 50. Severity 94. On the verified board, only the two coercive regimes come within ten points, and the first entry driven by ordinary administration rather than passports (France–Monaco) sits fourteen points back. So the honest headline isn't that many countries have CBT. It's that one country industrialized it, two dictatorships enforce it through passport offices, one bilateral convention makes a whole nationality permanently taxable in a single destination, and a tail of democracies keeps nationality hooks their advisors rarely mention.
Where primary sources changed scores. Portugal's Art. 16(6) contains "salvo se o interessado provar que a mudança se deve a razões atendíveis": an escape clause for legitimate moves, notably temporary postings by a Portuguese-domiciled employer. Spain's Art. 8.2 has no such clause. Two rules that look identical on paper (nationals, blacklist, year + 4) diverge on the defeat component: Spain 15, automatic; Portugal 8, rebuttable. Portugal drops from 61 to 54. France–Monaco went the other way. BOFiP doctrine confirms Art. 7-1 applies regardless of whether the person also holds another nationality, and Art. 7-3 extends the claim to wealth tax (ISF, now IFI) for post-1989 movers, so taxes-covered interpolates to 12 and the entry rises to 80 at Grade A. These two are the clearest demonstrations of why the Grade A gate exists. We'd have published the wrong numbers without it.
Weight defensibility. All raw components publish. Every release carries a ±25% weight-perturbation sensitivity analysis with rank-stability statistics (Kendall's τ), and weight changes are changelogged with reasons. The calibration questions we know about are stated here rather than left for critics to find: the coverage-not-rate design (Eritrea's 2% near the US regime), the population score of broad Nordic presumptions, and the Tajikistan carve-out reading. The published 68 uses the milder interpretation; the harsher one scores higher.
Every input is something that happened on the record: a bill filed, a committee vote, a ministry study published. Never an inference about mood.
Base — the feasibility ladder (0–40): enacted (exits Watch) · passed one chamber = 40 · committee/first-reading adoption = 30 · government-sponsored bill or budget provision = 25 · opposition bill/amendment tabled = 15 · party platform or coalition agreement = 10 · official commission/ministry study = 8 · prominent academic or supranational blueprint = 5.
Amplifiers (up to +30): fiscal stress (+0–10, mechanical IMF WEO deficit/debt thresholds) · precedent of extraterritorial or emigrant-targeted tax legislation (+0–10) · recurrence across sessions (+0–10).
Dampeners (up to −30): binding legal constraint (−0–15) · treaty-network conflict (−0–10; CBT is neutered by existing tie-breakers unless the country renegotiates its network to add US-style saving clauses, a decade-scale project) · administrative capacity gap (−0–5; CRS delivers residence-based data, and taxing by citizenship needs a FATCA-equivalent).
On the EU-law dampener, the case law cuts both ways and the index says so. De Lasteyrie du Saillant (C-9/02) constrains exit taxes on unrealized gains within the EU. Van Hilten-van der Heijden (C-513/03) upheld the Dutch ten-year nationality fiction for inheritance tax against a free-movement-of-capital challenge. EU law is a real constraint on a French-style trailing income tax. It is not an absolute bar, and the dampener is calibrated accordingly. Standing workshop item.
Decay: ladder points halve after 24 months without formal activity. Direction tags (⬆⬌⬇) capture reverse movement the ladder can't.
Worked example, France: ladder 30 + recurrence 10 + precedent 8 + fiscal stress 8 − EU-law 12 − treaty-conflict 6 = 38. The qualitative note carries what makes it credible: the 2026 measure was rejected on the Assembly floor by one vote, with support spanning LFI to the RN. A one-vote miss with cross-spectrum backing is what this instrument exists to price, and no sentiment survey would have caught it.
Adjacent pressure (not scored as CBT): the Zucman blueprint presented under Brazil's 2024 G20 presidency proposes, verbatim, "strengthened exit taxes: keep taxing residents moving to non-participating countries" and "'tax collector of last resort' mechanisms" modeled on the corporate minimum tax. Both are residence-based and fail the scope rule. We track the file anyway because it normalizes trailing taxation of the wealthy and feeds the precedent amplifier of formally endorsing countries.
Every factual cell carries a citation (statute article or official document, with URL), an evidence grade, and a last-verified date.
Grade A — primary legal text, the tax authority's own guidance, or controlling court decisions, read in the original language. Grade B — major-firm technical summaries or official secondary documents; good enough for drafts, not for a published score. Grade C — credible journalism, NGO reporting, parliamentary testimony; used only for enforcement-practice findings, never for the existence or text of a rule, and always labeled in-line.
Publication gate: no severity score publishes unless every scored legal component is Grade A. As of this release, every index entry meets the gate on the law. The remaining Grade C material concerns enforcement practice only (Eritrea and Myanmar collection methods; Tajikistan's collection gap) and is labeled as such wherever it appears. That's by design, since practice in closed regimes is only observable through Grade C channels.
Quarantine: jurisdictions circulating on internet CBT lists that fail primary verification publish as quarantined, with the conflicting evidence shown. The mechanism has already produced its first result. Tajikistan entered quarantine on conflicting secondary claims and exited when the official code text settled the question. It went into the index, which is not the direction anyone expected.
Corrections and versioning: public dated changelog from v1.0; verified errors fixed within ten business days; material score changes announced. The changelog already records a self-correction (the Zucman mischaracterization) made before publication, which we consider a better credential than a clean sheet. External review by one international-tax academic and one practicing expatriation attorney is budgeted pre-launch, with reviewers named in the publication.
The index only uses data, rankings, definitions, or estimates from approved sources: national statutes and gazettes; tax-authority guidance (AEAT, BOFiP, GİB, Verohallinto, Skatteverket, Portal das Finanças, Income Tax Department of India, IRS, NAV); court decisions (CJEU, Conseil d'État, Cassazione, KHO, HFD, BFH, and Cassation-level Mexican and US authority); parliamentary records; IMF WEO and Eurostat for fiscal-stress inputs; UN DESA migrant-stock data and national consular registries (PERE, AIRE) for affected-population counts; IRS Statistics of Income and the Federal Register quarterly expatriation list; UN Security Council documents for the Eritrea record.
CitizenX's proprietary wealth-migration data appears in exactly one place, the exposure overlay, and never enters a severity or watch score. The scores are law; the overlay is us.
A legal survey is a reference document. The overlay is the part that produces new knowledge. Cross-referencing severity scores against CitizenX real-time wealth-migration data answers questions no law firm can: do high-persistence jurisdictions show suppressed HNWI outflow, or merely rerouted destinations? Did Spanish-national flows bend around the quarantine toward treaty-covered near-substitutes like the UAE? Does the French near-miss show up as anticipatory departure before any law exists? The overlay publishes as a separate chapter (feeding Exodus), attributed exclusively to CitizenX's real-time wealth migration data.
1. "You're conflating exit taxes and residence tails with CBT." The scope rule excludes them, Annex C logs every exclusion with the reason, and we enforced the rule against our own draft when the Zucman mechanism's text showed a residence basis.
2. "Treaties override half of it." Treaty-shielded entries are flagged, defeat mechanisms are priced, and the Hungary–US termination, dated to the IRS announcement with the quantified 2024 consequence, shows shields are revocable. Tracked per cycle.
3. "Statute isn't practice. Eritrea can't assess anyone." Enforcement is scored and graded separately: Grade C is allowed for practice, never for law. The coercive flag exists because Eritrea and Myanmar collect through passports rather than assessments. The enforcement-gap flag covers the mirror case, Tajikistan, where the statute claims more than the state collects.
4. "Only the US matters." The gap is published, not hidden. The US at 94 with the first ordinary-administration democracy fourteen points back is itself the finding. And the tail matters, because inheritance tails and quarantine rules are what a second-passport client's advisor tends not to mention.
5. "Your weights are arbitrary." All raw sub-scores publish, sensitivity analysis with rank-stability stats ships every release, and the calibration questions we know about are stated in Section 5 rather than discovered by critics. Re-weight it yourself.
6. "You have a commercial interest in scaring people." The methodology precedes the rankings publicly. Every scored legal cell is checkable primary law. The US carries a loosening tag, the France entry states the measure failed, and the changelog records our own pre-publication correction. An index built to scare would do none of that.
7. "The Watch is speculation." Every Watch input is a recorded institutional event with a citation. The one unfalsifiable pillar was deleted at design stage, and the adjacent-pressure category exists so that near-misses don't get inflated into CBT.
8. "Small N. A listicle with math." The unit is rules, not countries: 20+ scored rules across 17 jurisdictions plus a Watch board, refreshed on a fixed cycle with a changelog. Comparable in N to sovereign-rating coverage of a niche asset class, which is the correct genre comparison.
Full re-verification and re-score annually. Watch board quarterly. Event-triggered updates within ten business days of enactment, repeal, treaty termination, or a floor vote in a G20/EU legislature. Every update versioned.
Non-Latin-script primary texts (Myanmar's gazette, Japan's NTA text, Tajikistan's carve-out paragraph) have been verified through official or concordant channels but are scheduled for original-language reads at the first annual cycle, and this is stated per entry. Enforcement intensity in closed regimes is observable only through Grade C channels. The feasibility ladder is calibrated on parliamentary systems, and presidential and single-party systems map onto it imperfectly. The index measures rules as written plus documented practice. It does not predict individual outcomes, and says so.
United States — IRC (worldwide taxation; §877A; §7345); IRS expatriation-tax guidance; Federal Register quarterly expatriation list. Eritrea — RRT Proclamation (1995); Eritrean Embassy (Washington) published RRT terms; UNSC Resolution 2023 (2011); UK parliamentary written evidence (2025) on continued collection and entry denial [practice: C]. Myanmar — Union Taxation Law 2023 amendment (s.22, effective 1 Oct 2023) per PwC Worldwide Tax Summaries and Tilleke & Gibbins; Myanmar Consulate-General Chongqing tax-payment instructions and Notification 79/2023 reference (official); Irrawaddy / Myanmar Now enforcement reporting [practice: C]. France–Monaco — Convention of 18 May 1963, Art. 7-1 and 7-3; BOFiP BOI-INT-CVB-MCO-10 (updated 2 June 2021); BOI 14B-1-95 (dual nationality irrelevant); Conseil d'État and CAA Marseille (1 Sept 2009, n° 06MA02917) on born-in-Monaco nationals; Sénat parliamentary questions. Hungary — PIT Act (Act CXVII of 1995) resident definition per Hungary's OECD tax-residency filing and Grant Thornton; IRS Announcement 2024-5 (treaty terminated 8 Jan 2023; ceased effect 1 Jan 2024); irs.gov Hungary treaty-documents page; Andersen Hungary on post-treaty consequences. Tajikistan — Tax Code No. 1844 of 23 Dec 2021 (as amended through Dec 2025), individuals-resident article: citizens deemed residents (pt 3), citizens in state service abroad residents regardless of duration (pt 2), foreign-permanent-domicile qualifier (scope under original-language confirmation); official texts via mfa.tj and the National Legislation Centre (ncz.tj), consolidated versions via Paragraph/SpinForm; enforcement gap re worker remittances [practice: C]. Japan — Inheritance Tax Act (Act No. 73 of 1950), Arts. 1-3 and 2; 2013 reform, 2017 temporary-foreigner carve-out, 2018 repeal of the foreigner tail; concordant confirmations incl. PwC Worldwide Tax Summaries and specialist counsel; NTA original-text read scheduled at first cycle. Netherlands — Successiewet 1956, Art. 3(1) (ten-year national fiction) and 3(2) (one-year gift rule), statutory text verbatim; CJEU C-513/03 Van Hilten-van der Heijden (2006) upholding the fiction; Besluit voorkoming dubbele belasting 2001 for relief. Sweden — Inkomstskattelag (1999:1229) 3 kap. 3, 4 (diplomats), 7 §§ via Riksdagen; Skatteverket rättslig vägledning on the femårsregeln and burden shift; HFD 2020:25; legislative history (1966 presumption; 1985 extension) via SOU 1997:77. Germany — ErbStG §2(1)(1)(b) (5-year national tail; 10 years for US movers via Art. 3 of the ratification act of 15 Sept 2000 to the DE-US estate-treaty protocol) and §2(1)(1)(c) (public-service nationals abroad); AStG §2 (10-year extended limited income liability) and §4 (extended inheritance reach; 30% foreign-tax escape); BFH upholding constitutionality (on appeal from FG München 4 K 1286/18). Spain — Art. 8.2 Ley 35/2006 (statutory text); AEAT Manual Práctico IRPF; administracion.gob.es; Orden HFP/115/2023 (list); DGT V1310-22 / V1323-22 (Gibraltar agreement: post-2019 national movers exclusively Spanish residents). Finland — Tuloverolaki 11 §; Verohallinto official guidance "Yleinen ja rajoitettu verovelvollisuus" (via Edilex official channel); KHO 2021:172; KHO 2013:93; KHO 1981 t. 3184 (mid-year severance). Italy — Art. 2(2-bis) TUIR (DPR 917/1986, statutory text verbatim; introduced by Art. 10, L. 448/1998); DM 4 May 1999 list as amended (Switzerland removed effective 1 Jan 2024 by DM 20 July 2023); Cass. 14240/2021 (indirect transfers); Cass. 6501/2015 (rebuttal standard); Cass. 21437/2014 (presumption cuts both ways); D.Lgs. 209/2023 left 2-bis untouched. Mexico — CFF Art. 9 (statutory text, diputados.gob.mx); Nov 2021 reform (tail 3→5 years; EoI + collection-assistance escape). Portugal — Art. 16 CIRS (Portal das Finanças official text; nationality quarantine at n.º 6 current numbering, with razões-atendíveis escape); CAAD arbitration decisions quoting the provision (e.g., P155/2022-T); Art. 16(1)(d) officials rule. Turkey — GVK (Law 193) Art. 3(2); GİB non-resident taxpayer guidebook (2026, official); Communiqué Serial No. 210. India — s.6(1A) Income-tax Act 1961 (statutory text, incometaxindia.gov.in); Income Tax Department FAQ confirming retention in the Income Tax Act 2025 (from April 2026). France Watch — amendment I-CF380 (PLF 2026 committee adoption, KPMG Avocats note, Oct 2025); floor rejection by one vote (ASFE); PLF 2025 committee adoption (Fiscalonline); Assemblée Nationale records. US Watch — H.R. 10468 (18 Dec 2024); OBBBA exclusion (Jul 2025); reintroduction pending JCT score (ACA, mid-2026). G20/UN adjacent — Zucman blueprint and slides (gabriel-zucman.eu; EU Tax Observatory executive summary): "strengthened exit taxes… residents moving to non-participating countries"; "tax collector of last resort"; UNRISD WP 2026-02 on presidency continuity and the 125–9–46 UN vote.
Small, and stated. Original-language reads at first annual cycle: Japan NTA text; Tajikistan carve-out paragraph and article-number confirmation in the 2021 consolidation; Myanmar gazette text for the 10% non-salary rate (currently Grade C detail on an otherwise Grade A rule). China monitored entry: IIT domicile mechanics. Calibration workshop (rate-burden question; Nordic population scores; Tajikistan reading; EU-law dampener re Van Hilten). External reviewers engaged and named. Counsel review of ⚠ coercive-flag entries. Media-liability/E&O cover.
UK temporary non-residence — nationality-blind. Norway exit tax and three-year rule — nationality-blind. Canada departure tax — nationality-blind. Australia CGT event I1 — nationality-blind. Ireland ordinary residence — residence-history, not nationality. Spain 95 bis / France 167 bis / Germany §6 AStG exit taxes — residence-triggered (Germany §2 AStG is nationality-conditioned and included instead). South Africa — residence basis since 2001; historical note. US 2025 remittance excise on non-verified-citizen senders — nationality-conditioned but targets non-citizens; adjacent phenomenon, unscored. Zucman/G20 anti-relocation mechanisms — residence-based (exit taxes on departing residents; collector-of-last-resort); adjacent, monitored, not CBT.
Resolved: Tajikistan (entered on conflicting secondary claims; resolved by official code text; reclassified Tier 2 — see changelog). Historical precedents (Watch context, not scored): the Philippines taxed non-resident citizens' foreign income until its 1997 reform; Mexico taxed on nationality before its 1980-era shift; the US regime dates to the Civil War revenue acts and survived Cook v. Tait (1924); Myanmar's 2023 move reversed a 2012 exemption. Dormant CBT can reactivate inside one budget cycle, which is the Watch's reason to exist.
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