The UAE end is easy; the exit is where tax hides: Australia deems a disposal on departure, the UK claws back if you return within five years and keeps long-term residents in the IHT net, the US never lets citizens go, and China's question is residency and reporting, not an exit charge.
Relocation tax planning has two halves. The UAE half — 183 or 90 days, a TRC, no personal income tax — is genuinely simple. The home-country half is where six-figure surprises live.
The comparison
| Country | Exit charge? | The real trap |
|---|---|---|
| Australia | Deemed disposal on departure | Defer election keeps you in the net, discount lost |
| United Kingdom | None on individuals | 5-year temporary non-residence clawback; IHT residence tail |
| United States | Only on renunciation | Citizens taxed worldwide wherever they live |
| China | None | Residency hard to shed; CRS reporting; FX remittance |
Australia: the deemed disposal
Ceasing Australian residency triggers CGT event I1 — a deemed sale of assets that aren't taxable Australian property: shares, crypto, foreign portfolios. Gains crystallise on departure day. The deferral election exists but keeps those assets in the Australian net, with later gains taxed without the CGT discount. Timing, the main-residence exemption and choosing what to realise pre-departure is the planning core — covered in depth in our Australian residency guide and main-residence exemption piece.
United Kingdom: the long tail
No exit charge — but two regimes do the same work. Temporary non-residence: realise gains or certain income while abroad and return within five years, and the UK taxes them as if you never left. Selling the company from Dubai in year two and moving home in year four is a fully taxable round trip. And with inheritance tax now residence-based, long-term UK residents stay in the IHT net for years after leaving. A UK exit is a five-to-ten-year plan; the TRF analysis shows how transitional windows fit in.
United States: the net that travels
US citizens and green-card holders are taxed on worldwide income wherever they live. Dubai removes the second layer of tax, not the American one — the toolkit is exclusions, credits and structuring, as set out in our US citizens guide. The only true exit is renunciation, which for covered expatriates triggers the expatriation tax — a decision with consequences far beyond tax.
China: residency, reporting, remittance
No formal exit tax — but domicile-based residency is hard to shed for those with a hukou and family in China, CRS reports UAE accounts home, and the foreign-exchange rules govern how wealth lawfully moves. The planning is a residency-and-compliance exercise, mapped in our CRS and Chinese residency guide and served in Mandarin by the China Desk.
How we help
Neo Legal plans the exit and the arrival as one programme — pre-departure realisations, residency severance, the UAE structure and the TRC — with Australian workstreams in-house through Cornwalls and Chinese matters in Mandarin. Part of our tax practice.
This article is general information as at July 2026 and is not legal advice. Exit rules are jurisdiction-specific and change; obtain coordinated advice in both countries before departure.
