Debate continues in Australia on the recent capital Gains Tax and negative gearing tax changes. It is probably worth noting that Europe/UK may be moving toward taxing unrealised capital gains, especially now that the Netherlands have fully approved an unrealised gains tax commencing in 2028.
Hopefully Australian political parties will make election commitments ruling out any similar changes.
Netherlands — Fully approved unrealised gains tax (starting 2028)
In February 2026, the Dutch House of Representatives approved the Wet werkelijk rendement box 3, which imposes a 36% tax on both realised and unrealised gains on financial assets (stocks, bonds, crypto, savings). Effective 1 January 2028.
This is a true mark‑to‑market regime: assets are valued annually, and the change in value is taxed even without a sale.
United Kingdom — Considering unrealised gains taxation (debate stage)
The UK does not currently tax unrealised gains, but political debate has intensified around:
- Wealth taxes
- Mark‑to‑market systems
- Exit taxes
The Netherlands’ move has influenced discussions across Europe, including the UK, according to comparative analyses of European tax trends.
Norway — Wealth tax (includes unrealised gains)
Norway does not tax unrealised gains directly, but its annual wealth tax effectively taxes the market value of assets each year, which inherently includes unrealised appreciation. Wealth taxes are a form of unrealised‑gain taxation because the tax base is the current value of assets.
Spain — Wealth tax & solidarity tax
Spain also uses a wealth tax, levied annually on net assets above certain thresholds. As with Norway, this includes unrealised gains because the tax is based on asset value. Wealth taxes are explicitly identified as a mechanism that taxes unrealised appreciation.
France — Wealth tax on real estate (IFI)
France abolished its broad wealth tax in 2018 but kept a real‑estate wealth tax (IFI). Real estate is taxed annually based on market value, which includes unrealised gains. This fits the definition of unrealised‑gain taxation via wealth‑based assessment.
United States — Proposed, not enacted (federal level)
The U.S. does not tax unrealised gains broadly, but:
- The PFIC mark‑to‑market regime taxes annual unrealised gains on certain foreign investments.
- Several political proposals (e.g., billionaire minimum income tax) have sought to tax unrealised gains, but none have passed. PFIC MTM rules are cited as an example of targeted unrealised‑gain taxation.
Canada — Exit tax (deemed disposition)
Canada does not tax unrealised gains annually, but it does impose a deemed disposition (exit tax) when a taxpayer emigrates. This treats assets as sold at fair market value, triggering tax on unrealised gains. Deemed‑disposition rules are a recognised mechanism for taxing unrealised gains.
