“Alexis, I'm moving to Dubai in January. There's no income tax there. What do I still owe France?”
More than people think, and it all starts with one question: have you really left France within the meaning of Article 4 B of the French Tax Code? Home, main activity, centre of your economic interests: just one criterion still met in France is enough to keep you taxable there.
The United Arab Emirates has 33,438 French nationals on the consular register at 31 December 2025, a sharp increase: +12.7% over one year, one of the two largest increases in 2025.
The treaty of 19 July 1989 covers both income tax and inheritance. At Balmont Conseil, we prepare these departures ahead of the date, because that is when exit tax, residence and contracts are settled.
1. Why seek expert wealth management in the Emirates?
Four points, all to be addressed before departure.
- Tax residence has to be proven. An Emirati residence certificate is not enough under Article 4 B: France looks at your home, your activity and your economic interests. A business or investments left in France can keep you tax resident there.
- The exit tax is not automatically suspended. For the Emirates, deferral must be requested, with a tax representative and guarantees put in place before departure.
- Your French income remains taxable in France. Rent from a property located in France is taxed there, with a minimum rate of 20% for a non-resident, plus 17.2% social charges.
- The treaty covers inheritances. Movable property is in principle taxed in the deceased's State of residence; real estate located in France remains taxed in France.
2. The France ↔ United Arab Emirates framework in five verified points
Here is the applicable framework, checked against official sources as at 1st October 2026.
| French nationals on the register | 33,438 at 31 December 2025 (+12.7% over one year), one of the two largest increases in 2025. |
| Income tax treaty | Yes — treaty of 19 July 1989 on taxes on income and on inheritances. |
| Estate tax treaty | Yes, the same treaty of 19 July 1989. Its Article 17 allocates movable property, including securities and deposits, to the deceased's State of residence. Gifts are not covered. |
| Exit tax — deferral of payment | Deferral on request, with a tax representative and guarantees put in place before departure (Article 167 bis of the French Tax Code). Deferral is not automatic for the Emirates. |
| CSG and CRDS on property income and capital gains | 17.2% on French-source property income and real estate capital gains. The Emirates are a third country: the CSG and CRDS exemption does not apply. |
On residence. The Emirates issue a tax residence certificate from 183 days' presence, or 90 days with a residence permit and housing or a job there. France, for its part, applies Article 4 B: its assessment is what counts for your French tax.
On inheritance. Article 17 of the treaty allocates movable property to the deceased's State of residence: an Emirati resident who leaves financial investments in France may, on that basis, escape French inheritance tax on them. Real estate located in France, however, remains taxed in France.
Regarding gifts. The treaty does not cover them. A gift to a child domiciled in France falls under Article 750 ter of the French Tax Code: it is taxed in France.
3. Our services: 360° support for expatriates and investors
Four workstreams, to open before the departure date.
Leaving France for tax purposes, and exit tax
We check each of the criteria of Article 4 B, then we process the exit tax if your securities exceed €800,000 or if you hold at least 50% of the profits of a company: calculation, request for deferral, tax representative, guarantees.
- Review of the criteria for French tax residence.
- Exit tax: deferral request and guarantees before departure.
- What happens to your business and your French-source income.
Your contracts and your real estate in France
Assurance-vie, PER, rental property: we examine what can be kept from the Emirates, what can be redeemed before departure, and how your French rents will be taxed.
Some French insurers refuse payments from the Emirates. A Luxembourg assurance-vie contract is designed to follow its policyholder from one country to another.
A company in Dubai
For financial years starting on or after 1st June 2023, the Emirates apply a 9% federal corporate tax on taxable profit above 375,000 dirhams; a free zone company can remain at 0% on its qualifying income, subject to substance requirements. VAT is 5%.
On the French side, an Emirati company managed in practice from France can be taxed there, and its director can remain domiciled there: where decisions are taken needs documenting as much as your residence.
Inheritance
We establish, asset by asset, which State would tax your estate under Article 17 of the treaty, and we prepare gifts separately, as the treaty does not cover them.
4. Methodology: our way of working
We work in four stages, and at each stage you know where you stand.
- The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
- The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
- The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.
5. What the firm offers you
What concretely sets our work apart.
- Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
- A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
- Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.
Frequently asked questions on the Emirates
If I live in Dubai, am I still taxable in France?
Yes, if one of the criteria in Article 4 B of the French Tax Code still ties you to France: home or principal place of stay, main professional activity, or centre of your economic interests. Otherwise, you are taxable in France only on your French-source income.
Is the exit tax automatically suspended?
No. For the Emirates, deferral must be requested at least 90 days before departure, with a tax representative in France and guarantees (Article 167 bis of the French Tax Code). It only concerns securities portfolios above €800,000 or shareholdings of at least 50%.
Will my French rental income be taxed?
Yes, in France: at the progressive scale with a minimum rate of 20% for a non-resident, plus 17.2% social charges, or 18.6% for furnished lettings from 2025 income. The Emirates, a third country, do not give access to the CSG and CRDS exemption reserved for people covered by European, Swiss and British schemes.
Who taxes my estate if I die in the Emirates?
The treaty of 19 July 1989 allocates movable property — securities and deposits included — to the deceased's State of residence (Article 17), and leaves real estate to the State where it is located. Your investments can therefore escape French inheritance tax; your real estate in France cannot.
Does my company in Dubai pay tax?
Yes, for financial years starting on or after 1st June 2023: 9% on taxable profit above 375,000 dirhams, with a possible 0% rate on a free zone company's qualifying income. If it is managed from France, it can also be taxed there.
Can I continue to make payments into my French assurance-vie policy?
It depends on the insurer: some refuse payments from the Emirates. The contract stays open and keeps its date for French tax purposes, including the €152,500 passed on per beneficiary free of tax (Article 990 I of the French Tax Code). We check each insurer's position before departure.
In summary
The Emirates levy no personal income tax, but leaving France for them takes preparation: residence within the meaning of Article 4 B, exit tax deferred on request with guarantees, French rents still taxed in France.
The 1989 treaty is one of the few that also covers inheritances. Read properly, it protects your investments; it covers neither your real estate in France nor your gifts.
Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.
Let's review your situation
A thirty-minute conversation is enough to check that your departure will stand up to Article 4 B. You can also start with a free contract X-ray.
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