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ConceptReviewed October 2026
The mechanism of treating assets as sold at their market value when a person or company ceases to be tax resident, even though no sale has taken place. It is the engine behind exit taxes and emigration capital gains charges, turning a move abroad into a taxable event.
Australia applies it as capital gains tax event I1 under section 104-160 of the Income Tax Assessment Act 1997, and Denmark deems shares sold on departure under section 38 of its Share Gains Taxation Act, each with a route to defer the resulting tax.
A definition of an established legal or tax concept for general information. It is not advice on any individual situation.
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