Returning to France from the UK: British departure, French declarations and exit tax

Returning from the UK involves both sides of the Channel. On the British side, you can be considered a non-resident the day after your departure, but two periods of non-residence last longer: temporary non-residence (absence of 5 years or less) and Inheritance Tax (up to 10 tax years). On the French side, meeting only one criterion of Article 4 B is sufficient to establish your residency. If you benefited from a deferral of exit tax upon leaving, returning to France results in a tax refund or rebate.

Leaving the UK: P85, departure day, shared year

HMRC advises you to notify them if you are leaving the UK to live abroad permanently. Form P85 tells HMRC that you have left or will be leaving the country and allows you to reclaim tax paid on UK employment. It is not used if you are filing a Self-Assessment return for the year you leave. HMRC states: "You may be non-resident the day after you leave the UK." A non-resident may owe UK tax on their UK income.

The UK tax year runs from April 6th to April 5th, and the Statutory Residence Test determines your residency. If you spend 183 days or more in the UK during the year, you are considered a resident. You are considered a non-resident if you spend fewer than 16 days in the country (resident in one of the three previous years), or fewer than 46 days (non-resident in the three previous years), or if you work full-time abroad. In the latter case, three additional conditions apply: fewer than 91 days in the UK, fewer than 31 days of work exceeding 3 hours in the UK, and no significant break in work abroad. For the year of departure, HM Revenue and Customs (HMRC) outlines shared-year scenarios: Case 1 (starting full-time work abroad), Case 2 (that person's partner), and Case 3 (ending residency in the UK). The page I consulted does not specify the effects of the shared year on your foreign income and earnings. See the [link/section/section]. Statutory Residence Test.

The two British tails

Temporary non-residence. A person is considered "temporarily non-resident" if they have been a full resident of the UK for four or more years within the seven years preceding the year of their departure, and if their period of non-residence lasts five years or less. Certain income and gains received during this absence may then be taxable upon their return to the UK. The HS278 guidance document provides an example: departure on March 25, 2019, return on February 2, 2024, gain of £35,000 realized on September 15, 2019, taxed in 2023-24. According to HS278, gains on assets acquired after departure are not normally treated as realized upon resuming UK residency, except as otherwise provided in the document.

The Inheritance Tax. You are considered a "long-term UK resident" after 10 or more years of tax residency within the previous 20 years. This status can be maintained for up to 10 tax years after leaving the UK, and assets located outside the UK may be subject to tax. The waiting period is shorter if you haven't resided in the UK for all of the previous 20 years: 3 years after leaving the UK for 10 to 13 years of residency, 4 years for 14 years, and 5 years for 15 years. The page I consulted does not specify a period beyond 15 years. See the FIG regime and the Inheritance Tax.

The day France becomes your home again

Administrative doctrine (BOI-IR-CHAMP-10) identifies three criteria: primary residence or place of residence, professional activity, and center of economic interests. It is sufficient for one of these criteria to be met, and a residence of more than six months per year is not an absolute requirement.

If both France and the United Kingdom consider you a resident, Article 4 of the convention of June 19, 2008, will determine your status. A person is not considered a resident if they are subject to taxation in one state solely on the basis of income from sources located in that state. Next comes your permanent home; if you have one in both states, the state with which your personal and economic ties are closest (center of vital interests); then your habitual residence, nationality, and the agreement of the authorities.

Statements about returning to France

• Update your address in your Public Finances account.
• If you had no French-source income before your return, you don't need to file form 2042-NR: you declare all your income from the date of your return until December 31st. Form 2043 is used to determine your withholding tax rate.
• With income from French sources before returning, the 2042-NR covers this income and the 2042 covers the period of residence in France.
• Contact 3916 or 3916-bis for your accounts, assurance-vie policies, and digital asset accounts abroad. The tax authorities are announcing a €1,500 fine per undeclared account. See accounts and contracts abroad.

We were unable to read the French treatment of savings accounts and British pension schemes: have it reviewed before departure.

British income after return: the 2008 convention

For France, Article 24 § 3 a) provides that income taxable in the United Kingdom is taken into account for the calculation of French tax when it is not exempt, that British tax is not deductible, and that the resident of France is entitled to a tax credit against French tax, under the conditions and limits provided for by the convention.

Paragraph 6 of Article 14 further reserves the right of each State to levy, according to its legislation, a tax on gains derived from the alienation of "any property" by persons whom the text defines as their residence in that State, with regard to the six preceding tax years and the tax year of the transfer. The exact wording of the residence requirements is found in the text of the convention. We do not derive a rule for your case from it: the year of your departure and the dates of your transfers are found in the full text. See the France-United Kingdom convention.

The French impatriate regime

The government website, updated on April 8, 2026, applies to individuals who were tax residents outside of France for the five calendar years preceding their appointment. The scheme runs until December 31 of the eighth calendar year following. Individuals who came "of their own volition" are excluded. The website addresses two situations: employees recruited by a company established in France and related to the company that employed them abroad, or employees directly recruited from abroad to work for a company in France. The French wealth tax (IFI) is limited to assets located in France until December 31 of the fifth year following the establishment of tax residence. See the IFI for expatriates.

The exit tax upon return

Re-establishing your tax residence in France ("returning to France") triggers a tax relief or refund of the exit tax when you still hold the relevant securities or receivables. Form 2074-ETD also provides for a tax relief after two years if the total value of the securities was less than €2.57 million on the date of the transfer, and after five years thereafter. For a contribution-sale transaction, the transfer of tax residence outside of France terminated the deferral under Article 150-0 B ter.

Return with a deferred exit tax of €188,400: a numerical example (fictitious profile)

Situation. A fictional entrepreneur transferred his tax residence to the United Kingdom on March 1, 2026. His securities were worth €2,200,000, representing an unrealized capital gain of €600,000. Assumptions: the United Kingdom was listed in case #1 of the tax information notice on the date of the transfer, and he benefits from tax deferral; income tax at 12.8% (%) without opting for the progressive tax scale. He returns to France on September 15, 2027, less than two years after the transfer.

Issue. He wants to know what his return changes for the deferred tax, and what he needs to declare.

Strategy. He checks that he still holds his securities, files the 2042 of his return year with the 3916 for his British accounts, and has his 2074-ETS3 follow-up checked.

Result. The deferred tax amounted to €188,400: €76,800 in income tax (12.8 times the % rate) and €111,600 in social security contributions (18.6 times the % rate, based on departures in 2026), representing 31.4 times the % rate of the capital gain. His securities were worth less than €2,570,000: the tax relief period is two years. Since returning to France is a tax relief event, the deferred tax is waived if he still holds his securities. A prior sale of the securities triggers the tax liability; the information notice provides for a partial refund if the actual capital gain is less than the deferred gain or in the event of a capital loss.

What changes depending on your situation

• The number of years spent in the UK determines your British queues.
• The date of your return and any transfers you may be undertaking.
• The nature of your UK income: dividends, pensions, gains.
• A possible deferral of exit tax and the holding of your securities.
• Your accounts and contracts held abroad.

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