Cross-border tax planning - A timeline for moving countries

This is part one of our cross-border tax planning series, which guides you through each stage of the journey:

• Part 2: Pre-departure planning – tax residency, exit tax, and asset planning
• Part 3: After the move – income, reporting, and ongoing compliance

You’ve made the decision to move abroad and chosen your dream destination. Now the real work begins: understanding the tax implications. What should be done before you leave, the move itself, what’s needed once you’ve arrived, and when can you consider the process complete?

The timeline below provides a practical guide, showing what to consider at each stage, when to act, and where professional advice can make the most impact.

Stage 1: The decision is made - strategic planning stage

Ideally, you want to start planning about 12 months before departure. This allows you to map out what structures you need, whether they must be established before leaving, and which tasks can wait until you arrive.

At this point, consider:

• Your assets: what you own, where it sits, how it generates income.
• Your income streams: what continues post-move, what will end.
• Your estate: what structures will be optimal for your future residency and heirs.

You also need to review whether your current country imposes exit taxes and how your new country treats capital gains, income, and inheritance.

Stage 2: Planning before departure

Once you know your position, detailed planning begins. Some structures, like trusts or investment vehicles, require one to two months to establish and are often only effective if set up while still tax resident.

Exit tax and deemed disposals

South Africa, for example, treats you as having disposed of worldwide assets when you leave, triggering Capital Gains Tax. Understanding this allows you to decide whether to hold, dispose, or restructure assets beforehand.

How the new country taxes assets

• Australia resets asset values upon residency, simplifying transition.
• UK taxes capital gains over the full ownership period, even pre-arrival, which can increase taxes if not planned properly.

Estate planning

Changing tax residency is an opportunity to reassess estate structures. Consider:

• How inheritance taxes differ in the new jurisdiction (e.g., UK rates up to 40%).
• Whether assets held offshore are acceptable in your new country.
• Planning for future moves to optimise structures and compliance.

Stage 3: Income and reporting

Pre-move planning should also include your income streams:

• Pre-move: What is reportable and taxable in the current country?
• Post-move: What is reportable in the new country?
• Overlap: Ensure proper timing of tax returns to optimise foreign tax credits.

Salary structures, rental income, and ongoing investments must be considered to avoid double taxation. Often, filing the old country’s tax return first ensures an accurate credit application in the new jurisdiction.

Stage 4: The move itself

The move introduces logistical and tax considerations:

• Family, goods, and pets must be relocated.
• Obtain a tax number in the new country, either before or after arrival, depending on the rules.
• Employer assistance may help, but some tasks must be done personally.

Exit reporting requirements in the country you’re leaving differ widely:

• UK: handled through the tax return.
• South Africa: processed separately, only six months after departure.

Stage 5: After departure

Leaving a country doesn’t end obligations. Ongoing reporting may be required if you retain assets or earn income there.

Retirement planning becomes key:

• Different jurisdictions have specific rules for access and taxation.
• South Africa allows pensions and provident funds to be paid out immediately, while retirement annuities remain locked for three years.

Stage 6: When does it end?

The endpoint varies:

• Some people conclude planning once assets and income ties are severed.
• Others continue with cross-border tax obligations for property, investments, or business interests.

Planning windows between residencies can be valuable: leaving one country but not yet resident in another can allow restructuring that would otherwise be impossible.

Common mistakes

• Starting asset or estate planning too late.
• Ignoring retirement planning when changing tax residency.
• Misunderstanding timing for reporting and tax credits.

Final thoughts

Coordinated advice in both the country you are leaving and the one you are moving to is essential. Working with a firm that understands how the two tax systems interact ensures nothing is overlooked, and decisions are fully aligned.

At Sable International, we are fully regulated across multiple jurisdictions and specialise in managing cross-border complexity. Our team provides expert support across tax, investments, foreign exchange, and related planning, helping you protect your assets, optimise your tax position, and plan effectively for the future.

A well-planned move is not just about compliance; it safeguards your assets, maximises your income, and secures your family’s future. Get in touch with us today to start your personalised cross-border tax and estate planning journey. Email [email protected] or call +27 (0) 21 657 1517.