Leaving France for Switzerland: deferral of exit tax, cross-border worker or resident, procedures

Switzerland is not included in the list of countries eligible for automatic tax deferral in form 2074-ETD (transfers from 2025). If exit tax applies to you, the deferral must be requested before departure, with a tax representative and collateral. Changing your address is not sufficient to leave your French tax domicile: only one of the three criteria in Article 4 B of the French General Tax Code (CGI) is required to maintain your tax residence there. Employees who return to France daily are covered by a special agreement from 1983.

The exit tax: why Switzerland treats itself differently

You are affected if you were domiciled in France for six of the ten years preceding the transfer, and if you hold either at least 50% of the profits of a company or a securities portfolio with a total value exceeding €800,000 on the date of the transfer. The tax information sheet states "at least €800,000": the instructions and the information sheet do not agree on the threshold, and we are not making a distinction. Income tax is 12.8%, with an option for the progressive tax scale (box 2OP). Social security contributions are 17.2% for a transfer in 2025 and 18.6% for a departure in 2026; the rate for a later departure is applicable.

The automatic suspension of the notice covers the European Union and states bound to France by an administrative assistance agreement and a recovery assistance agreement. The notice lists these states and territories: 70 non-EU states and territories. Switzerland is not included, and we draw no further conclusions from this.

For such a State, the tax is in principle immediately payable. A deferral remains possible upon express request (part III.B of the explanatory note):

The public information sheet states "no later than 90 days before this transfer," and the instructions themselves use both formulations ("within the ninety days preceding" in Part III.B, "no later than 90 days before" in Part V). We do not differentiate between them: have the deadline confirmed before submitting.

Relief. The tax is waived, or refunded if it has been paid, after a period of 2 years if the total value of the securities is less than 2.57 million euros, and after 5 years if it exceeds this amount, assessed at the date of the transfer, provided that the securities are still held.

Statements. For a deferral upon request, the instructions stipulate two filings of form 2074-ETD. The first is made to the Non-Resident Tax Office (SIP) before the transfer, without forms 2042 and 2042 C. The second is made the year following the transfer, to the tax office (SIP) that had jurisdiction over your residence in France, with forms 2042 and 2042 C; the first page bears the note "Second filing in the case of deferral upon request." Annual monitoring is done using form 2074-ETS3 (or 2074-ETSL in certain cases); if you do not rectify your situation within thirty days of receiving a formal notice, the deferred tax becomes immediately due.

If you have made a contribution-sale, the transfer of residence outside of France terminates the deferral of article 150-0 B ter; the capital gain is taxed at the rate that would have been applied to it in the year of its realization.

Cross-border worker or resident in Switzerland: the key factor that changes everything

The agreement of April 11, 1983, defines a cross-border worker as a person resident in one state, employed in the other, who generally returns daily to their country of residence. Their earnings are taxable only in their country of residence. The cantons concerned are Bern, Solothurn, Basel-Stadt, Basel-Landschaft, Vaud, Valais, Neuchâtel, and Jura.

The "Employees in Switzerland" page of the French administration distinguishes three cases for a resident of France:

• private sector employee from one of these eight cantons, who returns every day: Swiss salary taxable in France, if you spend a maximum of 45 nights per year in Switzerland for full-time work and the daily commute does not exceed 3 hours round trip; ;
• employee taxed at source in Switzerland (for example in Geneva): tax credit in France; ;
• employee not subject to the normal tax scale in Switzerland: taxable in France.

In the second case, the administration's page indicates that these people "are not considered cross-border workers." Our page on the permit G details the border worker's authorization.

On the French side, Article 4 B establishes three criteria (home or principal residence, professional activity, center of economic interests): only one is required, and more than six months of presence is not an absolute criterion (BOI-IR-CHAMP-10). If you actually settle there, the Franco-Swiss convention of September 9, 1966, distinguishes between two residences: permanent home (center of vital interests), failing that, habitual residence, then nationality, then agreement of the authorities (Article 4 § 2). For a definitive transfer of domicile, you cease to be subject to taxation in the first State "as soon as the day on which the transfer of domicile took place expires," and taxation begins in the other State from the same date (Article 4 § 4).

Taxation based on expenditure: the Swiss lump sum

The 2026 instructions from the Federal Tax Administration allow for taxation on expenses incurred by individuals who are not Swiss citizens, do not engage in gainful employment in Switzerland, and are subject to taxation for the first time, or after an absence of at least ten years. The eligible expense is at least the higher of the following amounts: CHF 435,500 for 2026 and, depending on the circumstances, seven times the annual rent or three times the cost of the pension.

For France, the key point is point 9 of the instructions: a person taxed on a flat-rate basis calculated according to the rental value of their accommodation in Switzerland is not considered a resident of Switzerland within the meaning of the convention and cannot claim its benefits. The anti-abuse clauses of the convention remain reserved.

On the Swiss side: arrival, permit, insurance

• Announcement. For an activity lasting more than three months, the national of the Union or EFTA must register within 14 days of arrival and before starting their activity (State Secretariat for Migration, 06/07/2026).
• Permit. A permit L is required for stays of less than one year, while a permit B is required for stays of one year or more, valid for five years and renewable. If you are not gainfully employed, you must have sufficient financial resources and insurance. For stays exceeding three months, France Diplomatie advises contacting the cantonal migration office. See our page on [the topic is missing from the original text]. driving licence B.
• Health insurance. Anyone domiciled in Switzerland must take out health insurance within three months of establishing residency; insurance policies taken out within this period are retroactive. Employees working in Switzerland and residing in France have a right to choose their insurance provider within three months (Cleiss). See LAMal for new residents.
• Tax. The arrival of a foreign national triggers a new tax liability (Federal Administration Guide 2026). Foreign workers domiciled in Switzerland are subject to withholding tax, with the exception of holders of a C permit and those married to a Swiss citizen or a C permit holder.

Statements from the year of departure

Notify your last tax office of your new address. For the year of departure, you must file: form 2042, which includes your income up to the departure date, and form 2042-NR, which includes only your French-source income taxable in France from your departure until December 31st. The Non-Resident Tax Office becomes your tax administrator if you still have taxable income in France, and the management of the French Wealth Tax (IFI) follows the same rules. Online filing is mandatory if your residence has internet access.

What France still imposes

Non-residents are taxable in France only on their French-source income, subject to tax treaties. Capital gains on securities are generally exempt from French tax, except for gains exceeding 25% of the rights to profits from a company subject to corporate income tax (IS) with its registered office in France, held jointly with the family group within the five years preceding the sale: the levy is 12.8%. According to the tax authorities' website (updated in 2022), the French wealth tax (IFI) for non-residents applies to their real estate assets and rights located in France, as well as to the portion of their company shares corresponding to these assets, exceeding a net taxable real estate portfolio of €1.3 million. For dividends, the withholding tax under the tax treaty is capped at 15% of the gross amount (Article 11).

Departure for Switzerland with €1,800,000 in securities: a numerical example (fictitious profile)

Situation. A fictitious executive, domiciled in France for over ten years, owns 60 shares of his company, valued at €1,800,000. The unrealized capital gain is €900,000. He transfers his domicile to Switzerland on April 1, 2027.

Issue. He meets the conditions for the exit tax. Switzerland is not on the list of countries with automatic deferrals: without a request, the tax is due.

Strategy. He appoints a tax representative and offers guarantees to the Non-Resident Tax Office (SIP) within the 90-day window preceding his departure. The information leaflet and the form are not interpreted the same way: according to one, the window opens on January 1, 2027, while according to the other, that is the deadline. He has the deadline confirmed.

Result. The collateral, at 12.8% of €900,000 (%), amounts to €115,200. His securities are worth less than €2,570,000: the tax relief period is 2 years. Assumptions: transfer on April 1, 2027, securities valued at €1,800,000, capital gain of €900,000. Form 2074-ETD is filed once before the transfer, at the Non-Resident Tax Office (SIP), then a second time in 2028, at the Tax Office of his former residence. The calculation does not include the tax due.

What changes depending on your situation

• Your status: executive with shares, cross-border worker, retired or inactive.
• The value of your securities and a possible contribution-sale.
• Your ties to France: housing, family, work.

No result is guaranteed in advance: each point must be read in light of the documents in your file.