Leaving Australia for tax purposes is not a single decision. It is a sequence: when to cease residence, how the deemed disposal applies, what happens to the trust, how super is treated, and which destination jurisdiction fits the post departure structure.

This guide is for the audience Cadena works with most: founders, family business owners, HNW individuals, crypto operators, and location independent earners who have decided Australia no longer fits the next ten years of their plan. The question is rarely "should I leave". It is "how do I leave without an avoidable tax bill on the way out". Australian side execution sits with our sister firm, Cadena Legal. International structuring, jurisdiction selection, and post arrival design sit here.

What ceasing Australian residence triggers

Three things change at once when Australian tax residence ends. Worldwide income exposure stops. CGT exposure narrows to taxable Australian property. And the assets owned the day before departure are treated, for CGT purposes, as if sold on that date. That last point is CGT event I1, the deemed disposal on departure, and it is the cost item most clients have not modelled before the first conversation.

The I1 gain can be disregarded by election. The trade off is that the elected assets are treated as taxable Australian property until they are sold, which keeps the future sale inside the Australian net. The election defers tax against a different exit point; it does not remove it. Whether to elect depends on the asset mix, the destination, and whether that destination provides its own step up or grandfathering rule.

The five asset categories

Departure economics differ by asset class. Exposures sort into five categories:

• Listed shares and managed funds. The I1 calculation is mechanical. The choice is to crystallise pre departure at a known rate, defer through the election, or restructure into a holding entity beforehand. Time horizon and destination determine which fits.
• Crypto. Cost base, transfer mechanics, and timing of any move off Australian domiciled exchanges all matter. Crypto departures more often fail on operational grounds, where wallets, exchanges, and on chain history make the residency date hard to evidence, than on legal ones.
• Direct Australian real estate. Taxable Australian property, so I1 does not apply. The live questions are negative gearing post departure, withholding on rent, foreign resident CGT withholding on sale, and main residence treatment.
• Australian private company shares. Often TAP if the company is land rich, otherwise inside I1. The 2026 to 27 Budget changes to trust treatment and CGT discount strengthen the case for restructuring before departure rather than after.
• Foreign assets already owned. Outside I1 only if structured properly. Foreign assets held personally sit inside I1. Foreign assets held through a foreign company or trust may not, but attribution rules can still pull the income back while the client remains Australian resident.

Trusts and the post departure problem

Discretionary trusts, family trusts, and any structure where the client is a beneficiary of a non resident entity do not resolve themselves on departure. Australian rules continue to apply to trusts touched by Australian residents both before and after they leave. Section 99B and the transferor trust provisions sit behind most of the post departure trust surprises clients see two or three years out.

A trust that fit the Australian structure rarely fits the post departure one. The options are to wind it down before departure, migrate it, or settle a new vehicle in a jurisdiction that aligns with the new residency. The decision belongs at the start of the planning, not at the end.

Superannuation

Super stays in Australia. The post departure questions are contributions, withdrawals, and how the destination jurisdiction treats those distributions. A move to the UAE is treated differently from a move to the US, and a move to New Zealand triggers the transitional resident regime. Super is one of the items where destination drives the outcome more than departure mechanics.

After the 2026-27 Federal Budget

The Federal Budget reintroduced CGT indexation, set a 30 per cent minimum tax on trust distributions, and tightened negative gearing. Each item changes the departure calculation. CGT indexation interacts with the I1 election. The 30 per cent trust minimum strengthens the case for restructuring before departure. The negative gearing changes affect how Australian property is held post departure. No single change forces a decision. Together, they shift the economics for clients who were already weighing the move.