Relocation Matrix: Leaving One Jurisdiction and Entering Another

The individual country articles are arranged by jurisdiction: residence thresholds, exit taxes, year splitting, treaties, reporting. Each page answers the question "how is country X built". Someone who is actually leaving asks a different one — "I am walking out of A and into B, what breaks at the join". That answer sits on no single page, because it exists only as the sum of two legal systems: the year rule of the country of departure adds to the year rule of the country of arrival, the price of exit adds to the entry basis, the tail adds to the entry regime.

Writing that sum out pair by pair is not an option. Nineteen jurisdictions produce three hundred and forty-two directed pairs; a text of that shape is dead on publication and will not survive the first tax reform. The matrix is built the other way round: every jurisdiction has two faces — how people leave it and how people enter it — and both are described in a single row. There are not three hundred and forty-two pairs but nineteen rows, out of which the reader assembles the pair.

This page adds precisely the interaction layer and the traps that are visible only at the join. Everything that belongs to a single jurisdiction on its own is handed over by link and not repeated here.

The technique: a row describes a jurisdiction, the reader assembles the pair

The operation is simple, and the whole page exists for its sake. A pair A→B is read in three steps.

• Step one: in the Exit table, take the row for country A — when residence breaks, what the exit costs, what trails behind. That is everything A takes from the departing person and after them.
• Step two: in the Entry table, take the row for country B — how residence arises and which treaty layer applies. That is everything B demands of the arriving person.
• Step three: the two rows are added along six axes and reconciled against one another — not against each country's own calendar separately, but against a single shared timeline of dates.

An example of the assembly. A move from Spain to the UAE: from the Exit table comes the Spanish mechanism — status is assigned for the whole calendar year, there is no splitting, at a census of ten out of fifteen periods article 95 bis LIRPF engages, and Modelo 720 trails behind the years of residence; from the Entry table comes the Emirati one — Cabinet Decision 85/2022 with three tests and an annual residence certificate. The reverse direction, UAE→Spain, is read from the same two rows, but the halves swap places: from the Exit table the Emirati exit, where there is neither tax nor tail, from the Entry table the Spanish entry with its calendar year and its family presumption. The result differs — and that is exactly why direction matters.

Why A→B does not equal B→A

Asymmetry is not a side effect but the architecture of the subject. It arises from at least four independent sources, and each of them works in one direction only.

Gap or overlap: two year rules added together

The United Kingdom knows year splitting: where one of the eight statutory cases is met, the tax year from 6 April to 5 April divides into a UK part and an overseas part, and the splitting date is set by the case itself. Italy knows no splitting at all under domestic law — status is assigned for the whole calendar year, and a partial year is reachable only through a treaty rule laid over a status already assigned. Russia and Spain settle the outcome by the calendar year: Russian status is determined by the number of days in the calendar year, Spanish status by 183 days in the calendar year or by the core of economic interests.

The addition produces a result that appears on neither page separately. A move from a "whole year" country to a "whole year" country — from Spain to Italy, for instance — is capable of producing a year in which both sides treat the person as their resident for all twelve months. A move from a splitting country into a "whole year" country creates no such overlap on the exit side, but does create one on the entry side. And the reverse direction of the same pair may produce neither overlap nor gap — because the order in which the two year rules apply has changed.

The price of exit against the entry basis

The country of departure is entitled to tax unrealised gains at the moment of departure; the three provisions below are compared by residence census and threshold.

The question the country-by-country analyses never ask: does the departing person obtain a new basis on the entry side — a market-value valuation of assets as at the date of arrival.

The answer depends on the country of arrival, and it falls into three statutory models rather than two; they are set out in the next section. The UK rebasing rule to 5 April 2017 under Schedule 11 to the Finance Act 2025 is addressed to former users of the remittance basis, not to new arrivals. The practical consequence: where the country of departure has already taken tax on a paper gain and the country of arrival, on the eventual sale, computes the gain from the original acquisition cost, one and the same gain is taxed twice.

Direction decides everything. Spain → United Kingdom: article 95 bis fixes the gain on exit, the UK FIG regime keeps foreign gains outside the charge for the first four years of UK residence, and a sale inside that window produces no double count; a sale in the fifth year runs on the arising basis — from the original base cost, including the slice on which Spanish tax has already been paid. The reverse direction, United Kingdom → Spain, does not create the construction at all: there is no UK tax on unrealised gains on departure.

Whether the country of arrival grants a new basis

The exit charge fixes a value; the entry basis decides whether that value is ever recognised again. Countries of arrival occupy three statutory models and a fourth position in which the question does not arise at all.

The four positions are not interchangeable, and each does something different to an exit charge already paid. An unconditional step-up neutralises it as arithmetic, whether or not the country of departure levied anything. A conditional step-up neutralises it only where the departure state produced an assessment — the single mechanism in this list that makes two tax systems speak to each other directly, and it turns on a document rather than on a payment. Where there is no step-up the two charges are simply added and nothing but a treaty credit can reduce the sum; that is the point at which the worked pair below stops having an answer. And where the country of arrival does not tax the gain at all, the entry basis is moot only while the person stays: the original cost survives untouched and becomes live again in whichever country is entered next.

Case note: the deferral line and where it stops

That the price of exit changes with the direction of travel is not a policy observation. Two judgments made deferral the European norm and, by their own terms, left moves to third countries outside it.

de Lasteyrie du Saillant (C-9/02, 11 March 2004). A French national holding more than 25% of the profits of a French company moved his residence to Belgium in September 1998 and was charged under art. 167 bis CGI on gains he had not realised; suspension of payment existed but required a declaration, a French fiscal representative and sufficient security. The Court held that freedom of establishment "must be interpreted as precluding a Member State from establishing, in order to prevent a risk of tax avoidance, a mechanism for taxing as yet unrealised increases in value such as that laid down by Article 167a of the French Code Général des Impôts, where a taxpayer transfers his tax residence outside that State". The ratio is narrower than the headline: fixing the liability at the moment of departure is permissible, collecting it then — when a person who stayed would pay only on realisation — is not.

Wächtler (C-581/17, 26 February 2019). A German national, managing director and 50% shareholder of a Swiss company, transferred his domicile to Switzerland on 1 March 2011 and was charged immediately under §6 AStG; German law allowed deferral for a move to an EU or EEA state but not for a move to Switzerland. The Court read the Agreement on the Free Movement of Persons as precluding collection at the time of transfer where a person retaining domicile would be charged only on realisation. The proportionality reasoning is the load-bearing part: determining the liability at transfer is appropriate, but the impossibility of deferring payment cannot be justified by preservation of the tax base, since deferral surrenders no taxing right; the exchange-of-information machinery in the Germany–Switzerland treaty lets the departure state observe the eventual disposal, so refusing deferral goes beyond what is necessary; and where recovery is genuinely at risk, deferral against security rather than immediate collection is the proportionate answer.

The limit is what decides directions. Each judgment rests on a specific instrument — the Treaty freedoms in the first, the Agreement on the Free Movement of Persons in the second — and neither reaches a move to a state outside the European Union, the EEA and that Agreement. That is the whole reason a Spanish exit into the United Kingdom after Brexit meets art. 95 bis with no ten-year suspension behind it: nothing was enacted against British residents, the instrument the case law needs simply is not there for that pair.

The tail lives under the law of the country of departure

The third source of asymmetry is the most underrated. Obligations that trail behind a departing person are determined by the law of the country they left, and the regime of the country of arrival has no effect on them. Tails come in three kinds.

• Succession. The UK long-term resident status — residence in 10 of the last 20 tax years — keeps worldwide assets inside the inheritance tax perimeter for a further three to ten years after departure depending on the length of the record, and the "10 out of 20" count itself resets only after ten consecutive years of non-residence. The US section 2801 shifts a 40% charge onto the US recipient of future gifts and bequests from a covered expatriate — with no expiry. Which state charges a succession and which law governs it are separate questions, and a move can change one of them without touching the other.
• Reporting. Russian currency residence is tied to citizenship and is never lost: notification of the opening of a foreign account within a month and the annual account-movement report by 1 June remain obligations, and only the exemption in Part 8 of Article 12 of Federal Law No. 173-FZ lifts them — more than 183 days outside Russia in a calendar year. A US green card holder stays inside the worldwide-income system until the status is formally surrendered, not until departure.
• Source. UK land and property stay within UK capital gains tax for a non-resident, with a return and payment within 60 days; French real estate of a non-resident stays within IFI where net value exceeds EUR 1.3m, and SCI shares count towards the base; remuneration of a remote worker of a Russian company remains Russian-source income taxed at 13–22% regardless of tax status. Real property is the tail that never detaches, because the charge follows the situs and not the owner — buying abroad.

The country of arrival shortens none of these tails. The zero rate of the UAE and an Emirati residence certificate do not cut the UK inheritance tax tail by a single year; the Italian exemption from inheritance and gift tax on foreign assets during the article 24-bis TUIR regime closes the Italian side, not the British one.

Treaty status as a parameter of the pair

The fourth source is the treaty itself, which has three states: in force, suspended, absent. Without a treaty in force, the ladder in article 4(2) of the OECD Model Convention does not engage, and both states are entitled to treat the person as their resident under domestic law simultaneously.

The Russian case shows that suspension can be partial and asymmetric. Decree No. 585 of 8 August 2023, given statutory footing by Federal Law No. 598-FZ of 19 December 2023, suspended the distributive articles of agreements with 38 jurisdictions; article 4 on residence, the mutual agreement procedure and exchange of information remained in force on the Russian side. Partners responded differently.

• The United States suspended the same articles in mirror image from 16 August 2024, leaving article 22 on relief untouched.
• France confirmed the reciprocal step by note of 12 February 2024 with retroactive effect to 8 August 2023.
• The Czech Republic confirmed it by note of 13 September 2023.
• The United Kingdom went furthest and suspended the convention in its entirety, notifying Russia on 4 February 2025: from 1 April 2025 for corporation tax and from 6 April 2025 for income tax and capital gains tax — which means the tie-breaker is switched off for that pair as well.

Treaty status depends on the pair, not on the country. Hong Kong is not on the Decree No. 585 list and the agreement applies unchanged; Singapore is on it (item 36) and its articles 5–22 and 24 are suspended; the UAE is outside the list, and the new agreement of 17 February 2025 applies in full from 1 January 2026 with withholding capped at 10%. Georgia has no treaty with Russia at all. Hence the rule: the treaty layer is checked not by the country row but by the specific direction and on the specific date.

The six axes of the matrix

Both halves of a row are built on the same six axes, and a pair should be reconciled along the same six.

• The moment the old residence breaks and the moment the new one arises: does the year split on the date of the move, or is status assigned for the whole period.
• The price of exit: tax on unrealised gains, the duty to file the final returns, irreversible loss of a preferential regime.
• The tail: what continues to apply after departure and for how many years.
• Entry: the basis of stay and its connection to tax status — a residence permit does not by itself make a tax resident, and that works in both directions.
• Treaty: in force, suspended, absent; does the tie-breaker engage.
• Visibility: the moment at which both administrations learn about the move.

The matrix: nineteen jurisdictions from both sides

The Exit table — the side of the country of departure: when residence breaks, what the exit costs and what trails behind.

Each cell is reduced to the provision, the term and the threshold; the conditions, exceptions and tails for each country are set out in the detail below.

The Entry table — the side of the country of arrival: how residence arises and which treaty layer applies.

The rows are the same and in the same order: a pair A→B is row A from the Exit table plus row B from here; the entry regimes and filing deadlines are in the detail below.

Bringing the counters onto one scale

A separate piece of work, without which the pair will not reconcile: two countries count the same twenty-four hours by different rules, and their calendars cannot simply be added together.

• The unit of count. HMRC counts a day by presence at midnight. Russia counts both the day of arrival and the day of departure as days spent in the country. The UAE, under MD 27/2023, counts any day or part of a day. Hong Kong, for the sixty-day exemption, counts the day of arrival and the day of departure each separately.
• The counting window. The United Kingdom and the UAE look at rolling 12 months, Russia and Spain at the calendar year, Italy at 183 days of the tax period (184 in a leap year), and the UK year runs from 6 April to 5 April.
• The consequence. The sum of days across a pair in the year of the move almost never equals 365. A single flight from Moscow to Dubai counts both as a Russian day of departure and as an Emirati day of presence: the same twenty-four hours are recorded by both sides. Conversely, a date fixed by a UK split-year case means nothing to the country of arrival — its own count starts from zero on its own calendar.

That is why the date of the break under the law of A and the date of entry under the law of B are written out in a single chronological sequence, each with the provision applied, and reconciled against that sequence rather than against each national calendar separately. Practical support comes from the quarterly breakdown in platform reporting: both DAC7 and the UK MRDP transmit amounts quarterly, which allows income to be allocated between periods of residence.

Traps at the join

A year of dual residence on a "whole year → whole year" transition

The mechanism. Neither the country of departure nor the country of arrival breaks the year on the date of the move: one assigns status by the outcome of the calendar year, the other for the whole tax period. In the year of the move both treat the person as their resident for all twelve months, and that is not an error but the correct result of applying both laws. Such a year can be cut only by a treaty rule laid over a status already assigned — for Italy that is quite literally the only available way to obtain a partial year.

The direction. Spain → Italy: Spanish status closes on the outcome of the calendar year, Italian status is assigned for the whole calendar year — and they overlap. If the treaty tie-breaker is switched off for the particular pair (as it is between Russia and the United Kingdom from April 2025), there is nothing to cut the overlap with at all, and worldwide income lands in two bases at once.

The gap: "resident nowhere" in the year of the move

This is the commonest form of self-deception, and its technical version is more dangerous than the ideological one. The perpetual traveler myth as a way of life is dealt with separately; the point here is different — the specific window between the loss of the old status and the arrival of the new one.

The mechanism. The date of the break under the law of A and the date on which status arises in B almost never coincide. Spanish status for the year is absent if fewer than 183 days are accumulated in the calendar year and there is no core of economic interests — which is already clear in February. Emirati status requires either 183 days across 12 months, or 90 days together with a valid residence permit and a home or work; the residence permit takes months to arrange. Between those two points lies a window in which neither country treats the person as a resident under domestic law.

What it costs. Without residence there is no certificate, and without a certificate the former country retains grounds for treating the person as its own. Without residence the tie-breaker does not engage: there is nothing to resolve, because formally there is only one claim. The bank reports under CRS regardless — on the data in the file, which is to say the old address or the country of citizenship. Citizenship-based taxation and source rules operate independently of residence altogether. And, decisively, on an audit the country of departure looks at ties, not at the calendar, so a window in which a person is "nowhere" is readily recharacterised as continuous residence in A — with an assessment for the whole year.

The direction. Spain → UAE produces a gap. The reverse direction, UAE → Spain, produces no gap at all: the Spanish count of 183 days runs on the calendar year and, once accumulated by the autumn, covers the months of that year lived in the Emirates as well. One pair, two directions, opposite results.

A gain taxed twice: the price of exit without a new basis

The mechanism. The country of departure taxes unrealised gains at the moment of departure and thereby fixes tax on a paper figure. The country of arrival, on the eventual real sale, computes the gain from the original acquisition cost — if it grants no new basis at the date of entry. Which of the four entry-basis positions the country of arrival occupies decides whether that happens. Where there is no new basis, the difference between the original cost and the value at the date of departure is taxed a second time.

The direction. Spain → United Kingdom: article 95 bis LIRPF takes its share on exit, the FIG regime keeps foreign gains outside the UK charge for the first four years — and a sale inside that window creates no double count. A sale in the fifth year runs on the arising basis from the original cost, and the same slice of gain is taxed again; rebasing to 5 April 2017 does not help here, being addressed to former users of the remittance basis. The reverse direction, United Kingdom → Spain, does not generate the construction: there is no UK tax on unrealised gains on departure.

The same arithmetic is worth running for French article 167 bis, where deferral within the EU/EEA is automatic and holding the securities for between two and five years after departure removes the tax entirely — there the price of exit depends on what happens after the move.

The tail the new country does not shorten

The mechanism. The tail lives under the law of the country of departure, and the regime of the country of arrival affects its length in neither direction. The error is one of substitution: a person computes the tax profile of the new country and applies it to their whole position, whereas part of the obligations remain in the old system of coordinates.

The direction. United Kingdom → UAE: the Emirati side is clean — zero income tax, no federal inheritance tax, no CFC rules for individuals. The British side does not change at all: long-term resident status at 10 of the last 20 tax years keeps worldwide assets inside the inheritance tax perimeter for a further three to ten years after departure, a UK pension scheme remains a UK-situs asset, and from 6 April 2027 unused funds fall into the estate. Neither a TRC nor a golden visa shortens that period. The reverse direction, UAE → United Kingdom, produces no tail: on the Emirati side there is nothing to trail.

An entry rule broken by the days of the country of exit

The mechanism. Some entry regimes contain a condition formulated not about the country of entry but about the rest of the world — and that condition is tested against the actual calendar of the year of exit. The Cypriot 60-day rule requires simultaneously at least 60 days in Cyprus and no more than 183 days in any other single state.

The direction. Leaving a country where more than 183 days have already been accumulated by the date of departure closes the Cypriot sixty-day route for the whole transition year: the condition of "no more than 183 days in any other country" is broken by a fact that occurred before the decision to move was taken. What remains is the ordinary 183-day path in Cyprus, and in the year of the move that is usually unreachable. The reverse direction produces no such consequence: leaving Cyprus, a person does not carry its days along as an obstacle. Hence the rule of order: entry conditions are checked against the calendar already lived in the year of exit, not against the plan for the following year.

Visibility: a mismatch of self-certification and double reporting for the transition year

The mechanism. Under CRS a bank determines a client's residence from the self-certification and checks it against indicia — address, telephone, place of birth, standing instructions. Platform reporting is addressed by profile data: the seller's primary address, the state that issued the tax number, the VAT number. None of these channels knows the date of the break — each knows the date on which the data changed.

What it costs. Changing the self-certification before the actual move creates a year in which declared residence diverges from actual residence — a divergence that surfaces at the first reconciliation. Changing it later produces a report for the transition year that goes to the old country, while income for part of that year has already been declared in the new one. Double reporting for the transition year is entirely possible: part of the data goes to the old address, part to the new, and both administrations see the same period from different sides.

The order that works: first break the old residence by its own rules and fix the date, then accumulate the basis in the new country, then apply for the regime within the time allowed, and only then change the self-certifications — CRS, tax transparency, platform reporting.

One demand runs the other way: the account opened in the country of arrival asks for the source of the funds across years lived entirely under the law of the country of departure, so the evidence pack is assembled out of the old system and presented inside the new one.

The moment of visibility in the transition year

It is worth recording separately when exactly both administrations learn about the move, because that moment coincides with neither the date of the break nor the date of entry.

The financial channel works on the year-end balance and annual turnover: the bank passes data to its own tax authority once a year, and that authority passes it to colleagues in the owner's country of residence. Residence is taken from the self-certification rather than from the facts, and it changes when the client updates it. The platform channel is built more finely: DAC7 in the EU and the UK MRDP transmit amounts quarterly, and that is the only flow which by itself allows income to be allocated between periods of residence. The addressee is determined by the seller's residence rather than by where the platform is registered — that is, by those same profile fields.

Russia is a special case. Automatic exchange with most Western jurisdictions has effectively stopped: Switzerland dropped off the Federal Tax Service list by Order No. ED-7-17/986@ of 28.10.2022, 26 EU states by Order No. ED-7-17/916@ of 30.10.2024, and the list in force is set by Order No. ED-7-17/883@ of 14.10.2025. Invisibility does not follow from this: the currency resident's duties to notify accounts and to file the annual account-movement report apply whether or not the data arrived, and the RUB 600,000 threshold exemption does not work at all for accounts in excluded jurisdictions.

A worked pair: Spain → United Kingdom with a major shareholding

The abstractions above name the constructions; this section carries one directed pair through them with figures, so it is visible where a single gain is charged once, where it is charged twice, and where the treaty leaves the answer open. Spain → United Kingdom is the natural case: Spain has an exit charge on unrealised gains, the United Kingdom has a four-year window that suppresses foreign gains and then switches off. The numbers below are illustrative and invented; the provisions, rates and dates are not.

The actor: an individual tax-resident in Spain under the general regime for twelve years — long enough for the exit charge to engage, since article 95 bis LIRPF requires residence in 10 of the last 15 periods and years under the Beckham regime do not count. The person holds a single shareholding acquired for EUR 2,000,000, worth EUR 6,000,000 on the date Spanish residence is lost. It is an operating company, not one deriving its value principally from immovable property — how the entity and the shares are characterised decides which treaty article applies, and here it is the general rule for shares rather than the land-rich exception.

The year of the break: the exit deemed disposal

Residence before and after settles cleanly if the calendars are read on each side's own terms: Spain assigns status by the calendar-year count, the United Kingdom by the Statutory Residence Test, and a move planned around both leaves the person Spanish-resident to the break and UK-resident from arrival.

The exit deemed disposal follows from the break. Article 95 bis treats the shareholding as sold the day residence ends: the latent gain of EUR 6,000,000 − EUR 2,000,000 = EUR 4,000,000 enters the savings base and is taxed on the 2025 scale of 19 / 21 / 23 / 27 / 30% — EUR 1,181,880.

The EUR 6,000,000 is not a price anyone offered. For shares not admitted to trading, art. 95 bis(3) prescribes the figure: the greater of the net equity attributable to the shares in the balance sheet of the last financial year closed before the charge accrues, and the amount produced by capitalising at 20% the average of the results of the three closed financial years. On the invented figures used here — net equity of EUR 3,200,000 attributable to the holding, average results of EUR 1,200,000 across the three closed years — the capitalisation gives EUR 1,200,000 ÷ 0.20 = EUR 6,000,000, the greater of the two, and that is the exit value. What the holder thinks the company is worth does not enter the computation.

The formula is also where the charge is most sensitive, and to a variable that has nothing to do with the move. Hold everything else constant and shift the three-year average result alone from EUR 1,200,000 to EUR 800,000: the capitalisation yields EUR 4,000,000, the latent gain falls to EUR 2,000,000 and the exit tax to EUR 581,880 — 49.2% of the base case, out of one line of the profit and loss account. At that valuation the threshold in letter a) of art. 95 bis(1), which requires a market value exceeding EUR 4,000,000, is no longer met, and the charge survives only through letter b): a stake above 25% worth more than EUR 1,000,000. On the same facts a holder below that percentage falls out of the exit charge altogether.

Because the United Kingdom has been a third country since Brexit, the automatic EU/EEA diferimiento in art. 95 bis(6) — under which the gain is brought into charge only if, within the ten following years, the shares are transferred inter vivos or the person ceases to be resident in an EU or EEA state — is not available for this direction.

What remains is the aplazamiento in art. 95 bis(4): granted on application where the move is a temporary posting, running to at most 30 June of the year following the end of the five-year period, extendable by up to five further years while the posting lasts, and extinguished outright where Spanish taxpayer status is regained within that time without the shares having been transferred.

A move that is not a posting, or a person who does not come back, falls outside it and the charge is due in the final Spanish return. That is the first place direction shows itself: the same provision, applied to a move inside the EU/EEA, would suspend rather than collect — and what makes it suspend is the case law set out above, not the wording of art. 95 bis alone.

The entry basis and three sale timings

The entry basis is the hinge. The United Kingdom grants a new arrival no step-up: the rebasing to 5 April 2017 is a transitional relief reserved for former users of the remittance basis, not for people arriving now. The UK base cost of the shareholding therefore stays at the original EUR 2,000,000, and the FIG regime suppresses foreign gains only while its four years run. Those two facts — a fixed original cost and a window that ends — produce three different outcomes for one and the same sale of the shareholding, depending only on when it happens.

Year 5: the same slice and the credit question

The subsequent disposal in year 5 is where the two systems collide. The United Kingdom computes from the original cost, so it recaptures the whole cost-to-sale gain of EUR 5,000,000: of that, EUR 4,000,000 has already borne the Spanish exit tax, and only the EUR 1,000,000 increment between the exit valuation and the sale price is genuinely new UK gain. The exit charge did not disappear when the person left; it sits under Spanish law, spent, while the United Kingdom charges the same slice a second time.

Under article 13(6) of the UK–Spain convention the year-5 gain is taxable only in the United Kingdom, because the person is UK-resident when the sale happens — Spain has no treaty claim on that disposal at all. The UK credit in article 22(2)(a) is given only for Spanish tax computed by reference to the same chargeable gains; the Spanish charge was a deemed disposal in the exit year, the UK charge an actual disposal five years later — a different event, in a different year, on a different measure.

The preferential period is the whole reason the second and third rows differ. A sale the day before the fourth anniversary is exempt in the United Kingdom; a sale the day after runs on the arising basis from the original cost. The window changes nothing about the Spanish exit tax already paid — it decides only whether the United Kingdom adds a second charge on top of it. This is also where the person may forget that the company itself can move with them: a shareholding actively managed from the new country can drag the company into corporate residence there under a management-and-control test, a separate charge on a separate taxpayer.

The reverse direction: United Kingdom → Spain

Reverse the direction and the double count vanishes. United Kingdom → Spain with the same shareholding carries no exit charge on unrealised gains, because that layer belongs to Spain and not to the United Kingdom; the only British tail is the temporary-non-residence rule, which recharges a gain realised during an absence of five years or less in the year of return and bites only if the person comes back.

On the Spanish side a new arrival again gets no entry step-up, but under the Beckham regime a disposal of the non-Spanish company is foreign-source and outside the Spanish charge for the year of the move plus five; only once Beckham ends does Spain tax the full gain from original cost — one charge, at one point, never two on the same slice. The exit-tax layer is the axis on which the pair is asymmetric: one shareholding, one pair, two directions — A→B manufactures a gain taxed twice with the credit left open, B→A does not.

The limits of the matrix: who is missing

The matrix is honest exactly to the extent that both sides of a jurisdiction are described symmetrically. Seven jurisdictions that used to appear on one side only — Portugal, Germany, Canada, Serbia, Türkiye, Kazakhstan and Armenia — now carry both rows, so nineteen jurisdictions can be paired in either direction. Three remain one-sided, and they are set out below.

For these three only the Entry row can be assembled; the exit row, for anyone leaving them, has to be built up from primary sources. On the seven newly symmetric rows the Exit cell is deliberately narrow: it states how residence breaks and whether a departure charge exists, and where one does — Germany's Wegzugsteuer and Canada's deemed disposition — the mechanics stay with the comparative table of exit tax, which sets eleven jurisdictions against trigger, residence census, threshold, rate, deferral and the tail after departure. Serbia, Türkiye, Kazakhstan and Armenia levy nothing on unrealised gains, which makes their exit side short rather than unexamined: the whole cost of leaving them sits in the day count and in what remains taxable at source.

The practical consequence is straightforward: a row from the matrix can be taken whole or taken from one side only. A pair in which both halves are described reads through to the end; a pair with one half missing calls for separate verification, and pretending the gap is not there costs more than admitting it.

The non-tax entitlements attaching to the arriving status also sit outside this matrix: the tuition rate, the admission pool and a child's route to citizenship are owned by What a Status Is Worth Beyond Entry.