Cost of exit tax: simulation based on 3 numerical examples in 2026

How much is the exit tax? The basic calculation

Exit tax = (value of securities on the day of departure − purchase price) × 31.4 % for a departure in 2026. The result is called the theoretical exit tax. It becomes due, in particular, if the securities are sold, repurchased, redeemed, or cancelled during the deferral period, if you subsequently leave for a country that does not qualify for automatic deferral, or if the follow-up declarations are not filed within thirty days of a formal notice. It is cancelled if you still hold the securities after 2 years, or 5 years if their total value exceeded €2.57 million at departure. Returning to France with the securities also cancels the tax.

What value should you use for your securities on the day of departure?

The unrealized capital gain is calculated on a share-by-share basis: it is the value of the shares on the day of departure, less their acquisition price (article 167 bis of the CGI).

For listed shares, the value used is the last known price on the date of departure, or the average of the last 30 prices.

For unlisted securities, it is up to you to estimate their fair value, that is, the price a buyer would pay on that date. This figure directly determines the tax calculated.

For securities received by gift or inheritance, the acquisition price is the value used to calculate transfer taxes.

An unrealized loss on one line does not reduce the unrealized gains on other lines, and it does not carry over.

Securities purchased before 2018: the allowance for holding period

By default, the unrealized capital gain is taxed at 12.8 % of income tax, without any allowance.

If your securities were acquired or subscribed to before January 1, 2018, you can opt for the progressive tax scale. The capital gain used for income tax purposes is then reduced by an allowance for the holding period (Article 150-0 D, 1 ter of the French General Tax Code):

• 50 % for securities held for at least 2 years and less than 8 years on the day of departure; ;
• 65 % over 8 years old.

For shares of an SME created less than 10 years ago at the time of their acquisition, a reinforced allowance applies (article 150-0 D, 1 quater of the CGI): 50 % between 1 and 4 years, 65 % between 4 and 8 years, 85 % beyond 8 years.

The tax allowance only applies to income tax. Social security contributions of 18.6% (%) are still calculated on the entire capital gain.

The option is comprehensive: it applies to all investment income and capital gains of the household in the year of departure. It is checked in box 2OP of form 2042.

Example with case 1 below, securities acquired in 2008 and held for more than 8 years: with the option, the base subject to the tax scale decreases from €3,195,000 to €1,118,250. Social security contributions remain due on €3,195,000, i.e., €594,270.

Three numerical examples

We have identified 3 cases of quantified Exit tax simulations to put things into perspective.

Case 1 — Founding director of an industrial SME (Lyon)

Here we observe the potential financial impact of a Exit Tax in the context of an expatriation, taking the example of securities acquired in 2008 for €5,000 and whose market value is estimated at €3,200,000 on the day of departure in 2026.

1. High unrealized capital gain: The difference between the purchase price (€5,000) and the market value (€3,200,000) generates a very significant unrealized capital gain. €3,195,000. It is on this capital gain that the Exit Tax is calculated.
2. Theoretical Exit Tax: At a rate of 31.4% (income tax and social security contributions), the Exit Tax would amount to €1,003,230. This sum is, in principle, deferred payment at the time of expatriation.
3. Potential effective cost of €0: The key point is the last line of the table. For shares initially valued at over €2.57 million, the deferred tax is cancelled if the executive still holds them 5 years after leaving office: he is then fully tax-exempt. If they are sold beforehand, the tax becomes due; if the sale price is lower than the initial value, the tax is reduced accordingly. Without sales for 5 years, the final tax cost is €0.

The importance of the payment deferral in the Exit Tax mechanism is therefore clear. Although the theoretical tax is substantial (€1,003,230), the mechanism avoids immediate payment and, provided the securities are retained, allows for the total cancellation of the tax debt.

Case 2 — Tech executive selling his first company (Paris)

In this case, we see the theoretical calculation of the "Exit Tax" for the expatriation of a taxpayer holding holding company shares.

Taking into account the elements listed here, and based on a rate of 31.4 % (income tax and social security contributions), the theoretical Exit Tax amounts to €3,705,200 (€11,800,000 x 31.4 %).

This amount of €3,705,200 becomes due if the securities are sold within five years of departure, their total value exceeding €2.57 million. The deferral is automatic if the taxpayer relocates to the European Union, or to a country with which France has an administrative assistance agreement and a tax collection assistance agreement, and is not classified as non-cooperative. Elsewhere, the deferral must be requested, with certain guarantees. If the holding company was formed through a contribution of securities (Article 150-0 B ter of the French General Tax Code), the capital gain deferred at the time of this contribution is also taxed initially, at the rate applicable in the year of the contribution, and is not eliminated after five years.

Case 3 — Investor with a diversified portfolio (unlisted and listed securities)

Never consider the theoretical amount of the Exit Tax as the actual cost. The crucial advice is to systematize a detailed and customized modeling of the impact of the Exit Tax.

• The Exit Tax is not a tax "paid in advance".« This is, in principle, a payment deferral : automatic to the European Union and States linked to France by assistance agreements, on request and with guarantees elsewhere.
• The actual cost may be zero The main challenge is to comply with the conditions of tax relief (total cancellation), These rules assume that the securities must still be held for 2 years after departure, or 5 years if their total value exceeded €2.57 million. Here, the portfolio is worth €1.5 million: the holding period is 2 years.

This case highlights the potential gap between:

1. The Immediate Psychological/Theoretical Burden: The theoretical exit tax of €361,100. This amount, although high, should not be a deterrent if managed correctly.
2. The Actual/Final Cost: The amount that will actually be due (which needs to be modeled, but which could be €0).

In short, Tax planning is a key issue It is imperative to conduct a thorough analysis of the consequences of the future residence and the timeframes to ensure that the cost of this deferred taxation will be appropriate. canceled.

Three decisions that change the real cost

Lever 1 — Contribution-sale to holding company before departure.

If the contribution is made at least three years before the sale, the tax deferral of the’Article 150-0 B ter of the French General Tax Code (CGI) is maintained without any reinvestment requirement. However, leaving France terminates this deferral: the deferred capital gain becomes subject to exit tax at the rate applicable in the year of the contribution, and it is not eliminated after 2 or 5 years (Article 167 bis of the French General Tax Code). The contribution-sale facilitates reinvestment; it does not reduce the exit tax calculated initially.

Lever 2 — The gift before transfer.

A gift made before the transfer of residence eliminates the unrealized capital gain on the gifted securities (the value is fixed for the recipient on the date of the gift). Coupled with a division of ownership, It reduces the taxable base for exit tax while organizing the transfer.

Lever 3 — Choosing a destination with an agreement.

Deferral of tax payments is automatic for departures to a European Union member state, or to one of the 70 states and territories linked to France by an administrative assistance agreement and a tax collection assistance agreement (list 2025), including the United States, the United Kingdom, Norway, Monaco, and Japan. For other destinations, including Switzerland, the United Arab Emirates, and Singapore, the deferral must be requested no later than 90 days before departure, with a tax representative in France and guarantees (bank guarantee, pledge) covering the tax (Article 167 bis of the French General Tax Code). Choosing a destination with an agreement and planning the deferral are crucial to avoid having to provide several hundred thousand euros in guarantees.

The Asset Stress Test – Anticipating Instability in 2027

L'’wealth engineering It is not about managing certainties, but about modeling risks. At Balmont Conseil, we apply the methodology of Stress Test — inherited from the Basel III banking frameworks — to your expatriate taxation.

The Disruption Scenario: The Extension of the Relief

The major risk for an expatriate executive is not the initial Exit Tax rate, but the retroactive modification of the tax relief conditions.

Assumption : What happens if a future finance law extends the erasure period, currently 2 or 5 years, and applies it to departures in 2026?

1. Liquidity Risk: A longer timeframe freezes your divestment strategy. If you need to sell your securities just after the current deadline, such a reform would make the tax payable instead of eliminating it.
2. Inaction as a Cost: Without prior structuring (Levers 1 and 2: Contribution-sale or Gift), you are "hostage" to the French holding period while you reside abroad.
3. The Balmont Response: Our model doesn't stop its calculations on the day of departure. It incorporates a regulatory disruption scenario. We systematically recommend capital gains clearance schemes (split gifts) before departure to make your assets indifferent to the duration of the Exit Tax deferral.

Assuming that the 2026 rules will remain unchanged until the end of the deadline is a strategic error. The Stress Test allows you to build a structure where, even if legislation becomes stricter after your departure, your net-net return remains protected by unassailable standard legal mechanisms.

The goal is not to be subject to the political calendar, but to make it neutral for your assets.

Conclusion

The cost of the Exit Tax as shown in the theoretical simulation is almost always the worst-case scenario. The actual cost depends on the country of residence, the holding period of the securities after departure, and any gifts made before departure. The rule of thumb: what's expensive isn't the exit tax itself—it's the lack of proper structuring. The Balmont simulator generates your personalized, itemized estimate.

Official Sources & Legal Basis

• Exit Tax Mechanism: Article 167 bis of the General Tax Code (CGI) — Defines the transfer of tax residence outside of France, the tax base, the deferral of payment and the cases of cancellation.
• Payment Deferral & Relief Delays: BOI-RPPM-PVBMI-50-10-20 — Administrative doctrine on the basis of assessment of unrealized capital gains. The 2 or 5 year erasure periods and the 18.6% rate of social security contributions are detailed in form 2074-ETD 2026.
• Social Security Contributions on Capital Income: Article L136-6 of the Social Security Code — Social security contribution base: 18.6 % for departures in 2026 (notice 2074-ETD).
• Case Law on Retroactivity: Constitutional Council, Decision No. 2012-662 DC of December 29, 2012 — Legal framework for "tax retroactivity" (decision on the finance law for 2013).