Leaving France for Singapore: exit tax, tax residency and procedures

Moving to Singapore is not enough to escape the French tax system. The tax authorities examine three criteria for tax residency, and only one is required to maintain your status. If you hold securities, exit tax may apply upon departure. Singapore is not included in the list of countries eligible for automatic deferral of tax relief under form 2074-ETD for transfers in 2025: the implications for your case should be verified before departure.

Exit tax: are you affected?

The exit tax taxes unrealized capital gains on your securities at the time you transfer your tax residence outside of France. Two conditions must be met.

A period of residence. You have been tax resident in France for at least six of the ten years preceding the transfer.

A level of detention. You hold, directly or indirectly, at least 50% of the profits of a company. The other test concerns the total value of your shares on the date of the transfer: €800,000. The instructions for form 2074-ETD state "greater than €800,000," while the public information sheet uses "at least €800,000." The exact threshold can be verified in your file. The two tests are alternative. Only one is required.

The rates. Income tax is 12.8% by default, with an option to use the progressive tax scale. Social security contributions are 17.2% for a transfer in 2025 and 18.6% for a departure in 2026.

Payment deferral: Singapore and the list in the notice

Payment deferral is sometimes automatic, sometimes requires a request. According to the instructions for form 2074-ETD (transfers from 2025, Part III.A), automatic deferral applies to transfers to a non-cooperative European Union member state as defined in Article 238-0 A of the French General Tax Code (CGI), or to a non-EU country that has concluded an administrative assistance agreement with France. For the latter, the instructions list 70 countries for transfers made since January 1, 2025. Singapore is not included.

When the transfer does not fall under automatic deferral, the information sheet provides for a deferral upon request. The request is filed with form 2074-ETD. It requires a tax representative in France and collateral. For transfers since November 22, 2019, the information sheet states "no later than 90 days before this transfer." The information sheet states "within ninety days preceding the transfer": the two formulations do not entirely overlap; have the deadline confirmed by the tax authorities.

Two limitations. This list is for transfers in 2025; for departures in 2026, the applicable guidelines should be consulted. Furthermore, Singapore's absence from the list does not, in itself, resolve your situation, which must be reviewed before departure.

The list of non-cooperative states and territories is governed by the decree of February 12, 2010 (article 238-0 A of the CGI), last amended by the decree of April 15, 2026. The classification of a state in this list is verified on the date of departure.

Tax relief: 2 years or 5 years

If you still hold your securities after a certain period, the tax is waived (or refunded if it has already been paid). For transfers since January 1, 2019, this period has been reduced from 15 years to 2 or 5 years.

The tax relief does not apply if, in the meantime, there is, in particular, a sale, a buyback by the company, a cancellation of the securities or a liquidation.

Declare the exit tax

• Without a deferral on request, the 2074-ETD declaration is filed with the same deadlines as the income tax return, i.e. in year N+1 for a departure in year N: a departure in 2026 is declared in 2027. With a deferral on request, it is filed before the departure.
• According to the notice, this declaration only exists in paper format.
• In case of deferment, annual monitoring is mandatory: declaration 2074-ETS3, or simplified version 2074-ETSL when the conditions of the notice are met.

If you have made a contribution-sale

Transferring tax residence outside of France terminates the deferral of taxation under Article 150-0 B ter of the French General Tax Code (CGI). The capital gain is then taxed at the rate that would have applied in the year of the contribution. When the deferral of exit tax applies, form 2074-ETD specifies that it covers "capital gains that have been deferred but become taxable as a result of this transfer." A rate exception exists for certain contributions falling under the "Mergers and Acquisitions Directive.".

Tax residence: the three criteria of Article 4 B of the French General Tax Code

The administrative doctrine (BOI-IR-CHAMP-10), which comments on article 4 B of the CGI, identifies three criteria. It is sufficient for one of them to be met.

Spending less than six months in France does not therefore protect you.

When both France and Singapore consider you a resident, the tax treaty makes the final decision, and its definition of resident takes precedence over domestic tax domicile. For Singapore, Article 4 §2 of the treaty considers, in this order: permanent home, center of vital interests, habitual residence, and then agreement between the competent authorities. Nationality is not included. Details can be found on our page about the Franco-Singaporean tax treaty.

What France continues to impose after departure

Once you become a non-resident, you are only taxed in France on your French-source income, subject to tax treaties. Transfers of securities are generally not taxed, except for substantial shareholdings: more than 25% of the rights to profits of a company subject to corporate income tax and headquartered in France, held directly or indirectly, with the family group, at some point during the last five years. The levy is then 12.8%. It is 75% if the beneficiary is domiciled in a non-cooperative state or territory, regardless of the percentage. Capital gains on real estate are subject to a levy of 19%, to which social security contributions are added: 17.2% for residents of a country outside the European Union, the EEA, and Switzerland, according to impots.gouv.fr.

The year of departure: one or two statements

For the year of departure, online declaration is mandatory.

1. Form 2042 includes your income from January 1st to the date of departure.
2. Form 2042-NR is required if you have French-source income taxable in France that remains after you leave. It will only include your French-source income taxable in France, from your departure date until December 31st.

In subsequent years, non-residents file their returns online (form 2042, sections to be completed). Paper returns are only accepted in exceptional circumstances.

Singapore side: enter and stay

France Diplomatie offers tourist stays of up to 90 days, with a "social visit pass" sent by email upon arrival. The passport must be valid for six months after the planned departure date, a return ticket is required, and the SG Arrival Card must be completed no earlier than three days before arrival. Work passes are discussed on our Employment Pass and ONE Pass pages.

Numerical example (fictitious profile)

Situation. A fictitious Lyon-based business owner, who has been a tax resident in France for over ten years, holds 70,130 shares in his company. He is planning to move to Singapore in 2026. His shares are worth €2,100,000, representing an unrealized capital gain of €1,400,000.

Issue. He meets the exit tax requirements: at least six years of residency out of ten, ownership of at least 50% of the profits, a total value of €2,100,000, exceeding the €800,000 threshold regardless of the applicable limit. He doesn't know what leaving would cost or when to declare it.

Strategy. Before leaving, he calculates the tax, checks the deferral scheme and sets the schedule for his tax returns.

Result. The tax liability amounts to €439,600: €179,200 in income tax (12.8 times the % tax bracket) and €260,400 in social security contributions (18.6 times the % tax bracket), representing 31.4 times the % tax bracket of the unrealized capital gain. Since the value of the securities is less than €2,570,000, the tax relief period is 2 years. With securities valued at €2,900,000, it would be 5 years. Without a deferral upon request, the 2074-ETD tax return must be filed in 2027. With a deferral upon request, it must be filed before departure, within a timeframe to be confirmed.

What changes depending on your situation

• The value of your securities on the date of the transfer determines the tax relief period.
• Whether or not the deferment is automatic depends on your situation and the notice applicable to your year of departure.
• A prior contribution-sale alters the analysis of the departure.
• Your home, your business and your economic interests determine whether France remains your tax residence.

These points are examined on a case-by-case basis.