Leaving France for Monaco: a French citizen generally remains taxed in France

Moving to Monaco does not, in principle, exempt a French citizen from French income tax. According to Article 7-1 of the Franco-Monegasque tax treaty of May 18, 1963, as summarized by the French tax authorities (BOFiP), French citizens who have transferred their domicile or residence to Monaco are subject to French income tax under the same conditions as if they had their domicile or residence in France. Regarding exit tax, the instructions for form 2074-ETD state that this transfer does not constitute a transfer of tax domicile outside of France for those with French nationality. This page only concerns French citizens; the situation of individuals without French nationality is not addressed here.

What the 1963 convention says

The agreement was signed on May 18, 1963, and entered into force on September 1, 1963. The BOFiP (Official Bulletin of Public Finances) presents it as intended to replace the former agreement on neighborhood relations and mutual administrative assistance. It was supplemented by the amendment of June 25, 1969 (effective August 1, 1969) and by the exchange of letters of May 26, 2003 (effective August 1, 2005, Law of March 14, 2005), which extends Article 7 to the wealth tax (ISF). The official list of agreements mentions other instruments: exchanges of letters, the content of which is not presented here, and an agreement of February 25, 2019, concerning gifts and bequests made to public entities and non-profit organizations, which is unrelated to Article 7-1.

Article 7-1 is the relevant text for you. The BOFiP (Official Bulletin of Public Finances) summarizes it as follows: French nationals who have transferred their domicile or residence to Monaco are "subject to income tax in France under the same conditions" as if they had their domicile or residence in France. The text includes a second part: it also applies to individuals who cannot prove five years of habitual residence in Monaco as of October 13, 1962. The PDF of the convention and the BOFiP use the same date and duration. According to the BOFiP (§ 10), these individuals file their income tax returns with the Menton tax office for individuals.

Exceptions exist: the BOFiP (Official Bulletin of Public Finances) lists them (paragraphs 30 to 110), for example, for French citizens residing in Monaco before October 13, 1957, the Sovereign House, or persons married to a Monegasque citizen. These are not detailed here. Article 7-1 only concerns income tax; according to the BOFiP (paragraph 230), the CSG (General Social Contribution) and the CRDS (Contribution to the Repayment of the Social Debt) may apply by virtue of Article 4 B of the French General Tax Code.

This is not a double taxation agreement in the usual sense. The official list of conventions (BOI-ANNX-000306) classifies Monaco among those "whose principal purpose is not to avoid double taxation." Our page on the convention details its provisions.

And what about the exit tax?

The exit tax levies unrealized capital gains on securities at the time of transferring tax residence outside of France. It requires having been a tax resident of France for at least six of the ten years preceding the transfer, and meeting one of these two criteria: holding, directly or indirectly, at least 50% of the profits of a company, or owning securities with a total value of €800,000. The explanatory note states "greater than €800,000," while the public information sheet states "at least €800,000": the exact threshold is not clearly defined here.

For a French citizen moving to Monaco, the instructions for form 2074-ETD are clear: transferring their tax residence to the Principality of Monaco "does not constitute a transfer of tax residence outside of France." Therefore, the event triggering the exit tax, as described in these documents, is not this departure.

Three limitations.

• The quoted sentence appears in the 2025 transfer notice. The one for a departure in 2026 or 2027 should be reread.
• The instructions for form 2074-ETD (transfers in 2025) list Monaco among the countries eligible for automatic deferment of tax payments, and also state that a French citizen who moves to Monaco does not transfer their tax residence outside of France. This page draws no conclusions regarding the deferment of payment.
• Transferring your tax residence outside of France terminates the deferral of taxation on a capital contribution followed by a sale (Article 150-0 B ter of the French General Tax Code). The application of this rule to a move to Monaco is assessed on a case-by-case basis. If you have made a capital contribution followed by a sale, this point should be verified before leaving.

The criteria for tax residence in France

The administration considers three criteria for tax residence (BOI-IR-CHAMP-10, article 4 B of the CGI). Only one is sufficient.

For a French citizen in Monaco, these criteria are not the only text to read: Article 7-1 of the convention also applies. The way in which the two texts interact is explained in the texts themselves.

What remains outside this page

• Exceptions and amendments. This page does not detail the exceptions listed by the BOFiP, nor the content of the amendment, the exchange of letters and other instruments.
• The IFI. The BOFiP (paragraphs 380 to 390) indicates that Article 7-3 subjects French citizens who transferred their tax residence to Monaco on or after January 1, 1989, to the French Wealth Tax (IFI) on all their real estate assets included in the tax base, whether located in France or abroad; for others, only assets located in France are subject to the tax. The text of Article 7 of the convention should be read before applying this rule to your situation.
• The list of non-cooperative states and territories. It is consulted in its updated version on the date of departure; this page draws no conclusions for Monaco.

On the Monaco side: enter and stay

France Diplomatie indicates that, for French citizens, entry to the Principality of Monaco does not require a visa for stays of less than three months. For longer stays, a residence permit is mandatory. The Monegasque government specifies that this permit is required for all persons aged 16 and over; applications should be submitted to the Directorate of Public Security. The types of permits and their validity periods are detailed on our page about life in Monaco.

Another possible option is a certificate of residence for tax purposes. This requires a valid residence permit and one of these three conditions: more than 183 days spent in Monaco, having your main center of activity in Monaco, or having the longest stay of the year in Monaco. It is valid for one year. The Monegasque government website makes no mention of France or tax treaties: this certificate attests to your residence in Monaco; it says nothing about your tax liability in France.

Numerical example (fictitious profile)

Situation. A fictional French businessman from Lyon rents an apartment in Monaco. Over the course of a year, he spends 190 days in Monaco, 120 days in France, and 55 days elsewhere, totaling 365 days.

Issue. He believes that spending most of a year in Monaco will exempt him from French income tax.

Strategy. Before signing the lease, he reads article 7-1 of the 1963 convention and the sentence from notice 2074-ETD, and he takes stock of his titles.

Result. Having spent 190 days in Monaco, he exceeds the 183-day threshold for the Monegasque residence permit by 7 days, and Monaco is his longest place of residence this year: he can fulfill one of the permit's requirements, provided he holds a valid residence permit. This does not change the rule in Article 7-1: even though he has transferred his residence to Monaco, he remains, in principle, subject to income tax in France under the same conditions. Form 2074-ETD also does not consider this transfer to constitute a change of tax residence outside of France.

What changes depending on your situation

• Your nationality: this page only deals with French.
• The date and circumstances of your arrival in Monaco: the convention refers to this, and its provisions are not detailed here.
• A previous contribution-sale: the deferral of taxation must be considered before departure.
• Your securities, your activity and your home: the criteria of article 4 B remain to be examined.
• The text of the agreement and its amendments: it must be read in its entirety before any decision is made.

These points are examined on a case-by-case basis. No result can be announced without this examination.