Returning to France from Ireland: Revenue Office exit, French tax return and exit tax

Returning from Ireland requires preparation on both sides. At Revenue, the Irish tax authority, you update your records and check if you are a "habitual resident": this status maintains Irish tax on worldwide income for three tax years after departure, with some exceptions. In France, the year of return is taxed in two periods. The 1968 tax treaty does not distinguish between two residences: the return date must be clear.

Step 1: Exit Ireland via Revenue

According to the Revenue, a person who leaves Ireland may become a non-resident for Irish tax purposes. The Revenue recommends updating your details in myAccount (for employees) or in ROS.

• End of employment. Your employer is generally required to report the end of your employment to the Revenue. Otherwise, you can do it yourself in myAccount, under "View/Cease your Job or Pension Details".
• Working abroad for an Irish employer. A PAYE Exclusion Order exempts the employer from withholding income tax and USC if all your duties are performed abroad and you are a non-resident during the tax year. The employer submits the details in writing to the Revenue Service.
• Refund. If you worked in Ireland for part of the year and then went to live abroad, you can claim a refund: online, or by post with form P50, form 12 (employees) or 11 (self-employed), and a declaration of permanent departure or non-residence in the following tax year.
• Split-year departure. It only applies to employment income. You must be an Irish resident in the year of departure and a non-resident the following year. Employment income earned abroad after the departure date is disregarded for Irish tax purposes. For departures after December 31, 2024, the application is made via your tax return. For earlier departures, it must be made in writing, either through MyEnquiries in myAccount or at the Revenue Office.

Three years of habitual residence after departure

After three consecutive tax years of residence, you become a habitual resident at the beginning of the fourth year. Upon leaving Ireland, you remain a habitual resident for three consecutive tax years. The tax authorities then indicate that Irish tax applies to your worldwide income, except:

• income from a commercial or professional activity carried out entirely outside of Ireland; ;
• income from employment carried out entirely outside Ireland; ;
• Other foreign-source income, such as investment income, is taxable when it is €3,810 or less; above that, the whole amount is taxable.

For a former Irish resident returning to France with investments, this €3,810 threshold is important. Have your situation assessed by an Irish professional before your return date.

What remains taxable in Ireland

The tax authorities state that you pay Irish tax on rental income from Irish property regardless of your residence. Regarding capital gains, the tax authorities state that a non-resident, non-habitual resident, and non-domiciled individual is only taxable on "Irish specified assets": land, buildings, minerals, and assets from a business carried out in Ireland. A former resident must remain a habitual resident for three tax years (see above): have it checked which of these rules applies to you. The Irish capital gains tax rate is currently being revised (Budget 2027): check it as of the date of the sale.

Step 2: France, arrival date and declarations

The date. French tax residence is determined based on three criteria set out in the BOFiP (Official Bulletin of Public Finances): the home or principal place of residence, professional activity, and the center of economic interests. Only one of these criteria is required. The 1968 Franco-Irish tax treaty does not contain a rule for determining tax residence for a person resident in both countries: according to the BOFiP, the provisions concerning the income of a resident do not apply, and double taxation is avoided under Article 21.

The statement. According to the administration, the return year is divided into two periods:

Your first income or asset declaration in France must be filed on paper. Update your address in the Public Finances section. If you have no French-source income during your stay, form 2043 allows you to request a personalized tax rate.

Health: Re-affiliation in France

The French Treasury (DG Trésor) indicates that Ireland joined the European Union in 1973 and is part of the Eurozone. The information sheet on service-public.gouv.fr regarding returning from the European Economic Area, the European Union, or Switzerland states that, if you are employed, re-affiliation with your primary health insurance fund begins from your first hour of work. If you are unemployed and without benefits, you are eligible for universal health coverage after three months in France. This information sheet does not mention Ireland: please confirm with your local health insurance fund whether your situation falls under this sheet.

Irish accounts: form 3916

Once you are a resident of France, you must declare annually any bank accounts, assurance-vie or capitalization contracts, and digital asset accounts opened, held, used, or closed abroad. The penalty is €1,500 per undeclared account. The tax authorities stipulate a penalty of €10,000 per account when the account is located in a country without a tax treaty with France; they do not specify which category applies to Irish accounts. Check this before filing. For assurance-vie contracts, see our page on form 3916-bis.

Exit tax on hold: what the return changes

If you left France 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 a tax reduction or refund, provided you still hold the relevant securities. The 2074-ETS3 follow-up form includes a "Return to France" section (lines 440 to 442): the date of your return to France and, on line 442, the "capital gains subject to deferred taxation prior to the transfer of your tax residence outside France" for which the securities are still in your assets on the date of your return. These must be entered on line 8UT of form 2042 for income tax purposes in 2025. The instructions do not specify the case of unrealized capital gains: have the scope confirmed with the tax authorities. The reference rates are 12.8% for income tax and, for a departure in 2026, 18.6% for social security contributions.

Irish pensions and dividends after the return

Article 14, paragraph 1 of the convention stipulates that pensions are taxable only in the state of which the recipient is resident. The consolidated text does not annotate this paragraph. If you hold shares in Irish companies, the exemption from the Irish withholding tax of 25 % on dividends is not automatic: it must be claimed using form V2A, certified by the tax authority of your country of residence. The Irish Revenue Agency reserves this exemption for individuals who are neither residents nor habitual residents of Ireland; this condition is related to the habitual resident status described above, which should be verified with the Revenue Agency before submitting the form. The exemption is valid until December 31 of the fifth year following its issuance.

Expatriates: a system for those coming from afar

The tax regime under Article 155 B applies to individuals not domiciled in France for the five calendar years preceding their employment with a company. It runs until December 31st of the eighth calendar year following their employment. It does not apply to those who relocate voluntarily. It includes an exemption from the expatriation bonus or a flat-rate allowance of 30% of the taxable income, a 50% exemption on certain investment income and foreign-source gains, and a French wealth tax (IFI) limited to assets located in France until December 31st of the fifth year. The cap is 50% of total remuneration or 20% for the portion related to work performed abroad. It is declared on form 2042 or 2042 C.

Return on July 12, 2028 with €650,000 of capital gains on hold: a numerical example (fictitious profile)

Situation. A former fictitious executive left for Ireland in 2026 with a deferred exit tax on €650,000 of unrealized capital gains. She returned to France on July 12, 2028, and still held her shares. She received rental income from French sources.

Issue. She wants to know how much money is involved and how her return year tax return is broken down.

Strategy. She applies 12.8 % and 18.6 % to the €650,000 (assumption: rate from the notice for a departure in 2026). She divides the year 2028 by the date of her return.

Result. Income tax: €83,200. Social security contributions: €120,900. Total: €204,100. This is the amount obtained with these rates on €650,000; the instructions do not specify whether the refund applies when capital gains are unrealized: this needs to be confirmed. For tax purposes, the period from January 1st to July 11th represents 193 days, to be reported on form 2042-NR for French rental income. The period from July 12th to December 31st represents 173 days, to be reported on form 2042. The profile and amounts are fictitious.

What changes depending on your situation

• The number of years spent in Ireland determines your habitual resident status.
• The nature of your foreign-source income and its amount in relation to €3,810.
• The exact date of your return and your French-source income before that date.
• The existence of a deferred exit tax and the holding of securities upon return.
• A list of your accounts and contracts opened in Ireland.

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