Returning to France from the Netherlands: deregistration, Dutch precautionary notice and French declaration

Returning from the Netherlands requires preparation on both sides. In the Netherlands, you notify your local municipality of your departure and file your tax return for the year of your departure; the Dutch tax authorities may also issue a precautionary tax assessment notice regarding a pension, a housing contract, or a shareholding in a company. In France, you file your tax return for the year of your return, declare any foreign bank accounts, and any deferred exit tax liability may apply.

On the Dutch side: the municipality and the M declaration

The Dutch government website states that you must notify your local municipality of your departure if you stay abroad for more than eight months within a 12-month period. This obligation also applies if you retain a residence in the Netherlands. Your registration will change from resident to non-resident. The website also indicates that when a change of address abroad is reported to the Dutch Identity Administration (RvIG), they update the register and forward the change to organizations such as the Tax Administration (Belastingdienst) or your pension fund. The website does not specify a deadline for notification before departure.

For the year of departure, the Netherlands Tax Administration (Belastingdienst) offers the M form to individuals who only lived in the Netherlands for part of the year. It can be filed online or on paper; the paper form arrives within two weeks of ordering. Business owners also complete the annual M report. The page does not specify a deadline: check the website before leaving.

The Dutch precautionary notice: what still needs to be paid later

During an emigration, the Belastingdienst (tax authority) can issue a protective assessment. The page describes this for the items below.

The notice period is generally 10 years, except for substantial shareholdings. For transfers to a country within the European Union or the EEA, the deferral of payment is automatic and interest-free. You must report the sale of shares, the distribution of dividends, or the cessation of the company, which may trigger the notice period in whole or in part.

The page does not provide any figures in euros. It also does not address the impact of returning to France: the Dutch Tax Administration (Belastingdienst) does not specify what happens to the tax assessment when you return to France. The Belastingdienst indicates that the highest tax rate applies to the income to be protected. Have this matter reviewed by a Dutch professional.

On the French side: tax residence, tax return and accounts

French tax residence is determined based on three criteria outlined in the BOFiP (Official Bulletin of Public Finances): principal residence or home, principal professional activity, and center of economic interests. Only one of these criteria is required. If both countries consider you a resident, the convention of March 16, 1973, will determine the outcome in Article 4, paragraph 3, starting with the permanent home.

According to the administration, the tax return for the year of return depends on your income before arrival:

Form 2043 allows you to update your withholding tax rate or set up advance payments if you did not have any French-source income. For your accounts, assurance-vie policies, and digital asset accounts opened, held, used, or closed abroad, attach form 3916 or 3916-bis. The penalty is €1,500 per undeclared account. The page specifies a penalty of €10,000 for an account located in a country without a tax treaty; it does not include the Netherlands. Check this before filing.

Exit tax on hold: what the return changes

If you left with a deferred exit tax liability, the instructions for form 2074-ETD include "re-establishing your tax residence in France" among the events that qualify for tax relief or a refund, for receivables and capital gains still held (the instructions I read concern transfers in 2025). The instructions do not detail the case of unrealized capital gains: have the scope confirmed with the tax authorities. The standard tax relief periods are 2 years (securities under €2,570,000) or 5 years.

What the convention keeps for you

Pensions and similar remuneration are taxable only in the recipient's country of residence, with the exception of public service (Article 18, referring to Article 19, paragraph 1): once you are domiciled in France, you are considered to be in that country. Income from real estate located in the Netherlands remains taxable in the Netherlands (Article 6). For France, Article 24B generally exempts income taxable in the Netherlands, while still taking it into account when calculating the tax rate, except for income for which it grants a tax credit, such as dividends and interest. Our page on the tax treaty provides further details on these articles.

The formalities of the return

The French government website service-public.gouv.fr outlines three steps: a tax clearance certificate (quitus fiscal) may be requested by the authorities of your country of origin; any money transfer of at least €10,000 must be declared online to customs; and registration with France Travail requires a French address. Regarding healthcare, the information sheet distinguishes between two scenarios: if you remain affiliated with your local health insurance fund and are not yet employed, it states that your coverage will continue after three months; otherwise, you must apply for coverage after your arrival.

Expatriates: a scheme for those not domiciled in France

The regime under Article 155 B of the French General Tax Code (CGI) applies to individuals who were tax residents outside France for the five calendar years preceding the year they took up their duties, and who transfer their tax residence to France upon assuming those duties. It runs until December 31st of the eighth calendar year following the start of their duties. It includes an exemption from the expatriation bonus or a flat-rate option of 30% of the total compensation, an exemption of 50% of certain foreign-source income, and a limitation of the French wealth tax (IFI) to assets located in France until December 31st of the fifth year. At the taxpayer's option, the total benefit is capped at 50% of total remuneration, or the exemption cannot exceed 20% of taxable remuneration net of the expatriation bonus.

Return on April 1st, 2027 with €600,000 in capital gains on hold: a numerical example (fictitious profile)

Situation. A fictitious executive left France in 2026 with a deferred exit tax on €600,000 of unrealized capital gains. He returns on April 1, 2027, and still holds his shares, worth €2,100,000. He received French rental income before his return.

Issue. He wants to assess what is at stake and know how to break down the 2027 declaration.

Strategy. He applies to the €600,000 the income tax rate of 12.8% (flat rate from the information sheet read, which concerns transfers in 2025) and the social security contribution rate of 18.6% (information sheet, departures made in 2026). He divides the year 2027 by the date of his return.

Result. Income tax: €76,800. Social security contributions: €111,600. Total: €188,400, representing 31.4% of the capital gain. The instructions classify the return as an event of tax relief or refund: this total is the amount concerned, as long as the securities are held. For tax purposes, the period from January 1st to March 31st represents 90 days, to be reported on form 2042-NR for French rental income; the period from April 1st to December 31st represents 275 days, to be reported on form 2042. The profile and amounts are fictitious.

What changes depending on your situation

• The nature of what you left behind in the Netherlands: pension, housing contract, shareholding in a company.
• The date of your arrival and the French-source income received before that date.
• An exit tax that is on hold, and the fact that you still hold the securities upon your arrival.
• The list of your accounts and contracts opened in the Netherlands.
• Your affiliation to the French social security system during your stay.

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