Leaving France for Canada: exit tax and procedures

Moving to Canada can trigger exit tax if you have been a tax resident of France for at least six of the last ten years and hold either at least 50% of a company's profits or a securities portfolio with a total value of €800,000. Canada is not included in the list of countries eligible for automatic deferral of tax payments in form 2074-ETD (transfers from January 1, 2025). For other countries, the form provides for an optional deferral: this must be requested before departure, with the assistance of a tax representative and by providing "guarantees" to the tax authorities.

This page addresses exit tax from the perspective of leaving for Canada, and the residency requirement on the Canadian side. It does not cover: the current list of non-cooperative states (NCS), which this page was unable to access; Canadian immigration; Canadian taxation; the text of the tax treaty between the two countries; income tax returns for the year of departure; or social security. These topics are not addressed here.

Who is affected?

Form 2074-ETD (transfers occurring in 2025) sets out two cumulative conditions, the second of which can be fulfilled in two ways:

If the value of your portfolio is close to €800,000, the exact wording of this threshold should be checked with the official source before deciding.

To determine if you are still domiciled in France, the BOFiP (version of July 28, 2016) uses three criteria: your home or main residence, your main professional activity, and your center of economic interests. Only one of these criteria needs to be met.

Canada and the automatic reprieve list

Payment deferral is automatic when the transfer is made to a Member State of the European Union, or to another State or territory that has concluded administrative assistance and recovery agreements with France, provided that it is not non-cooperative within the meaning of Article 238-0 A of the French General Tax Code (CGI). The explanatory note lists these States for transfers from January 1, 2025. The United States and the United Kingdom are included. Canada is not: the terms "Canada" and "Canadian" do not appear in the text consulted.

For a transfer to a state or territory other than those listed in the first case in the notice, the notice provides for an optional deferral. Before the transfer, have the applicable tax regime in Canada confirmed by the non-resident tax office.

Regarding non-cooperative tax jurisdictions (ETNCs): the BOFiP (Official Bulletin of Public Finances) indicates that the list established by the decree of February 12, 2010, was last amended by the decree of April 15, 2026. The list itself is not reproduced here. This page therefore does not indicate whether Canada is included.

The optional deferment, step by step

1. Request to be specifically granted a stay of execution. It can be partial: by category (unrealized capital gains, deferred capital gains, receivables for additional prices).
2. Respect the deadline. The notice and information sheet indicate a 90-day period before the transfer (transfers from November 22, 2019 onwards, according to the information sheet). The calculation method must be confirmed with the administration.
3. Appoint a tax representative established in France, authorized to receive communications from the administration.
4. To offer "guarantees"« to the non-resident tax office, on plain paper. Their amount is 12.8 % of the total amount of capital gains and receivables. If the tax under the progressive scale exceeds the guarantees provided, additional payment must be made within one month of receiving the tax notice.
5. Submit the 2074-ETD in two stages. A first filing before the transfer, without the 2042 and 2042 C declarations. A second filing the year following the transfer, with the 2042 and 2042 C, bearing the mention "Second filing" within the framework of the optional deferral.

After departure: tax relief and follow-up

For transfers from 1 January 2019 onwards, the holding period for securities depends on their overall value.

According to the information sheet, a sale, a buyback-cancellation or a liquidation in the meantime prevents the tax relief.

In the event of a deferral, annual monitoring is required: the 2074-ETS3 form, or the 2074-ETSL form if no events have occurred during the year. Any new transfer of tax residence abroad must be reported to the non-resident tax office by letter on plain paper within two months.

The rates

For the exit tax, the information sheet indicates a flat income tax rate of 12.8%. Social security contributions are 17.2% for departures in 2025 and 18.6% for departures in 2026. For a departure in 2027, the information sheet consulted does not indicate a rate: this needs to be verified.

The Canadian perspective

The Canada Revenue Agency (page updated January 20, 2026) defines three significant residential ties as: a home in Canada, a spouse or common-law partner in Canada, and dependents in Canada. Without sufficient significant ties, a stay of 183 days or more in a year makes the visitor a deemed resident. The CRA offers form NR74 to request its opinion when entering Canada. Our page "Canada: Tax Residence and Residential Ties" details these rules.

The official list of tax treaties (BOFiP, version of 29/04/2026) provides for Canada the convention of 2 May 1975 and three amendments, with taxes covered including income tax, wealth tax, inheritance tax, and gift tax. Its text is not reproduced here on this page.

Departure for Canada: numerical example (fictitious profile)

Situation. Hélène, a fictitious executive, has been a tax resident of France for over six years (hypothesis). She holds securities with a total value of €1,150,000, with a taxable unrealized capital gain of €400,000 (hypotheses, no allowances calculated). Her departure for Canada is being considered: the tax rates from the information sheet are used for a departure in 2026 (calculation hypothesis).

Issue. What tax is initially calculated, what "guarantees" are required, and what retention period conditions a possible tax relief?

Strategy. The total value exceeds €800,000: it falls within the scope. As Canada is not included in the list of countries eligible for automatic deferment, the information leaflet refers it to the optional deferment scheme (to be confirmed, see above). The rates are those in the leaflet for a departure in 2026. The total value is less than €2.57 million: the deferment period is 2 years.

Result.

With the same capital gain and a departure in 2025, social security contributions at 17.2% (%) would amount to €68,800, for a total of €120,000: €5,600 less. This scenario is hypothetical. It does not include the option for the tax brackets or any allowances, and it does not prejudge any actual situation. A deferral by option must be requested no later than 90 days before the transfer: the timeline for a 2026 departure needs to be verified.

Departure for Canada: what changes depending on your situation

• Your year of departure : the rate of social security contributions depends on the year of the transfer.
• Your stake and the value of your securities : 50 % of social benefits, or €800,000 of total value.
• The overall value of your securities : it sets the deadline at 2 years or 5 years.
• The regime applicable in Canada : the list in the notice does not mention Canada; the scheme needs to be confirmed with the administration.
• Your status on the Canadian side : residency ties and number of days spent in Canada.
• The timetable : the first filing of the 2074-ETD precedes the transfer.

The rule depends on your situation. No results are guaranteed.