The Expat Tax Return: A Country-by-Country Guide

Leaving your home country rarely means cutting all ties with your home tax authority. Depending on your nationality, your source of income and your new residence, you may still owe a tax return, a disclosure of foreign accounts, or even tax itself, years after you have moved. Reporting obligations for non-residents (and, for Americans, citizens) are poorly understood, and the cost of getting them wrong ranges from late-filing penalties to criminal exposure in the worst cases.

This guide walks through what is actually required of expats from six major countries: France, the United States, the United Kingdom, Canada, Australia and Germany. The goal is not to replace a tax adviser, but to help you understand which obligations apply to your situation so you can ask the right questions.

Disclaimer: This content is general information, not personalised tax advice. Cross-border tax rules change frequently. Consult a qualified cross-border tax specialist for your specific case.

The universal principle: residence vs source

Most tax systems work on two basic concepts that you should understand before anything else.

Tax residence is the country that taxes you on your worldwide income. Residence is usually determined by a combination of physical presence (often 183 days), the location of your main home, and the centre of your economic or family interests. The tests differ between countries but the logic is the same: one country is your primary taxing authority.

Source is the country where the income is generated. A rental property, a salary paid by a local employer, a capital gain on a local asset, or a pension from a local system usually remain taxable at source even after you leave.

Tax treaties between countries (there are over 3,000 worldwide, well documented by the OECD) decide which country gets to tax what, and how double taxation is eliminated (usually through a credit or an exemption). If you are moving between two countries with a treaty, read it. If you are moving between two countries without a treaty, be very careful: double taxation is real and fully legal.

The United States is the big exception. It is one of only two countries in the world (with Eritrea) that taxes its citizens on worldwide income regardless of where they live. This is called citizenship-based taxation, and it changes everything.

United States: citizenship-based taxation

American citizens and green card holders are required to file a US federal tax return every year, no matter where they live, as long as their income exceeds the standard filing threshold. The canonical starting point is the IRS page for taxpayers living abroad.

Key filings:

• Form 1040: the standard US return. Expats get an automatic extension to June 15 (vs April 15 domestically), with a further extension to October 15 on request.
• Form 2555, Foreign Earned Income Exclusion (FEIE): you can exclude up to roughly 126,500 USD of foreign salary or self-employment income in 2025, provided you pass either the Physical Presence Test (330 days abroad over 12 months) or the Bona Fide Residence Test.
• Form 1116, Foreign Tax Credit: a credit for income tax actually paid to a foreign country. Often more valuable than the FEIE in high-tax jurisdictions.
• FBAR (FinCEN Form 114): if the aggregate of your non-US bank and investment accounts exceeds 10,000 USD at any point in the year, you must file an FBAR separately from your tax return. Penalties for non-wilful failure start at around 10,000 USD per account per year.
• Form 8938 (FATCA): an additional disclosure of foreign financial assets when they exceed certain thresholds (50,000 USD for single filers in the US, 200,000 USD for single filers abroad, on the last day of the year).

Common mistakes: Americans abroad often assume that because they pay tax locally, they do not need to file in the US. They do. They also often overlook passive foreign investment companies (PFICs), which include most non-US mutual funds and ETFs and trigger a punitive tax regime if held by a US person.

United Kingdom: residence, domicile and Self Assessment

The UK uses the Statutory Residence Test (SRT) to determine tax residence, a relatively objective set of rules based on days present and ties to the UK. Details are on gov.uk.

Key filings:

• Self Assessment (SA100): UK residents and most non-residents with UK-source income must file online by 31 January following the end of the tax year (which runs April 6 to April 5). Paper filing deadline is 31 October.
• Form SA109 (Residence, remittance basis): the supplementary form where you declare your residence status and, if applicable, claim the remittance basis.
• Form P85: submitted when you leave the UK mid-year to request a refund of overpaid PAYE and formally notify HMRC.
• Non-Resident Capital Gains Tax (NRCGT): non-residents selling UK property must report and pay within 60 days of completion, regardless of whether a gain arises.

The non-dom regime was abolished. Since 6 April 2025, the long-standing remittance basis for non-domiciled residents has been replaced by a residence-based regime offering four years of exemption on foreign income and gains for new arrivals who have not been UK-resident for the previous ten years. HMRC’s guidance on the new regime for new residents should be consulted before any move.

Common mistakes: Britons who leave mid-year often forget to file the P85 and SA109 for the year of departure, and end up taxed as UK residents on their post-departure worldwide income. Split-year treatment is not automatic; you have to claim it.

Canada: worldwide income and the departure tax

Canada taxes its residents on worldwide income. When you cease to be a Canadian tax resident, you trigger a deemed disposition of most of your assets. This is Canada’s version of an exit tax.

Key filings:

• T1 General: the annual income tax return, due 30 April (15 June if you or your spouse is self-employed, but any balance owed is still due 30 April).
• Departure return: in the year you leave, you file a return indicating the date you became a non-resident. You report worldwide income up to that date and Canadian-source income after.
• Form T1161, List of properties by an emigrant of Canada: required if the total fair market value of your property when you leave exceeds 25,000 CAD (excluding cash, pensions and some other categories).
• Form T1243, Deemed disposition of property: reports the capital gain triggered by your departure.
• Form NR73, Determination of Residency Status (Leaving Canada): optional, but useful if your residency status is ambiguous. The CRA’s leaving Canada guide is the reference.
• Withholding tax (Part XIII): Canadian-source passive income paid to non-residents (dividends, rent, royalties) is generally subject to 25 % withholding, reduced by tax treaty.

Common mistakes: underestimating the deemed disposition. Canadians with unrealised gains on stock portfolios, rental properties abroad, or crypto can trigger very large tax bills simply by moving, even if they never sell anything. Planning before departure is essential.

Australia: residency tests and the TFN

Australia taxes residents on worldwide income. Residency is determined through four tests (ordinary concepts, domicile, 183-day, Commonwealth superannuation), documented by the Australian Taxation Office (ATO).

Key filings:

• Individual tax return: due 31 October following the end of the financial year (1 July to 30 June). Later if filed through a registered tax agent.
• TFN (Tax File Number): your permanent tax ID; you keep it for life and must quote it on any Australian-source income, even as a non-resident.
• Capital Gains Tax on departure: when you cease Australian tax residency, you are deemed to have disposed of most non-Australian assets at market value. You can elect to defer this by keeping the assets taxable in Australia, a choice that needs careful modelling.
• Withholding: Australian-source dividends, interest and royalties paid to non-residents are subject to withholding (10–30 % depending on the type of income and the treaty).

Common mistakes: assuming you are a non-resident because you physically left. The ATO routinely reclassifies people who keep a home, family or strong ties in Australia. Keeping accurate day-count records and closing obvious ties (lease, car registration, Medicare) matters.

France: non-resident obligations and form 2042

France moves to a residence-based system that is relatively standard, but non-residents still have real obligations. The reference site is impots.gouv.fr.

Key filings:

• Form 2042: the main return. Non-residents declare French-source income (rentals, dividends from French companies, pensions from French sources, capital gains on French real estate).
• Form 2042-NR: supplementary form specifically for non-residents.
• Form 2047: required when reporting foreign income that, despite your residency, remains relevant under a treaty.
• Form 3916: declaration of foreign bank and investment accounts held by French tax residents. Even a single unreported account can trigger a 1,500 EUR penalty per account per year (or 10,000 EUR if in a non-cooperative jurisdiction).
• Exit tax (Article 167 bis CGI): may apply on unrealised gains above 800,000 EUR when leaving France, with significant deferral and exemption conditions.

Common mistakes: failing to update your address with the tax office, continuing to file as a resident for several years, and forgetting the 3916 form in the year of departure. For deeper coverage of French-specific cases, see our expat taxes hub.

Germany: unlimited vs limited liability

Germany distinguishes between unbeschränkte Steuerpflicht (unlimited liability, worldwide income) and beschränkte Steuerpflicht (limited liability, German-source income only). The deciding factor is whether you have a residence (Wohnsitz) or habitual abode in Germany.

Key filings:

• Einkommensteuererklärung (ESt 1 A / ESt 1 C): the main return. The C form is used by non-residents. Deadline is 31 July following the tax year, extended by several months when filed through a Steuerberater.
• Anlage WA-ESt: required in the year of departure to determine the exit-tax position on significant corporate shareholdings (1 % or more).
• Außensteuergesetz (AStG) § 6, exit tax: Germany levies tax on unrealised gains on substantial shareholdings when an individual ceases to be a German tax resident. Since 2022, the deferral regime has been considerably tightened.
• Extended limited tax liability: expats moving to a low-tax jurisdiction may remain subject to extended German tax liability for up to ten years.

Common mistakes: deregistering from the Einwohnermeldeamt (Anmeldung) is an administrative act, not a tax one. You are not automatically non-resident for tax purposes just because you left the population register.

Filing deadlines at a glance

Country	Tax year	Main filing deadline	Extension possible
US	1 Jan – 31 Dec	15 April (15 June abroad)	To 15 October (Form 4868)
UK	6 April – 5 April	31 January (online)	Limited, reasonable excuse only
Canada	1 Jan – 31 Dec	30 April	15 June if self-employed
Australia	1 July – 30 June	31 October	Via tax agent
France	1 Jan – 31 Dec	May–June (online, by zone)	Rarely granted
Germany	1 Jan – 31 Dec	31 July	To 28/29 Feb with a Steuerberater

Common mistakes across all countries

Some patterns appear regardless of nationality:

1. Assuming no income means no return. Many systems require a return even with zero income, especially in the year of departure.
2. Ignoring tax treaty tie-breakers. If two countries both claim you as resident, the treaty tells you which one wins. Read the article on residence.
3. Missing account-disclosure forms. FBAR, Form 8938, T1135 (Canada), 3916 (France): these are separate from your tax return and carry disproportionate penalties.
4. Triggering an exit tax by surprise. Canada, France, Germany, Australia and the Netherlands all have some version of it. Model it before you move, not after.
5. Not keeping evidence of departure. Flight tickets, rental contracts, utility bills in the new country, local tax residence certificates: they are your proof if you are ever audited.

What to do before your departure year ends

A short, practical checklist:

• Request a tax residence certificate from your new country once you have one. It is the single most useful document to defend your status.
• Close or update your accounts with your old tax authority (change of address, non-resident status).
• File any departure return or equivalent in the year you leave.
• Keep a day-count log for at least the first three years. Many residence tests look back several years.
• Consider a one-time consultation with a cross-border tax adviser covering both countries. The fee is a fraction of the cost of getting it wrong.

For further reading on related topics, see our articles on changing your tax residency, dividends received abroad, and the comparative expat tax burden by country.

And when the time comes to choose a destination, our country guides give you the local tax picture for each option: Portugal, Estonia, UAE / Dubai, Singapore, Georgia.