Leaving France for Mexico: two residency tests, then the exit tax and its payment deferral

Moving to Mexico is not enough to change your French tax residence: meeting only one criterion of Article 4 B is sufficient to remain there. Mexico, for its part, applies its own test, primarily based on residency. If you are liable for the exit tax, the 2074-ETD notice for 2025 transfers lists Mexico in its list of countries for automatic deferral of payment. This page does not cover the Mexican tax rates, the detailed conditions for residency, or inheritance matters.

Two administrations, two residency tests

In France. Article 4 B of the French General Tax Code (CGI) establishes three categories of criteria: personal, professional, and economic. Meeting any one of these criteria is sufficient to be considered a resident of France. A stay of more than six months in the year is not an absolute requirement. If you operate in several countries, the French tax authorities (BOFiP) consider the activity to which you dedicate the most time as your principal activity; if this criterion cannot be applied, the activity that generates the largest share of your worldwide income will be considered.

In Mexico. The Mexican Tax Code (Article 9) considers a person to be a resident if they have established their primary residence ("casa habitación") in Mexico. If they also have a residence in another country, they remain a resident when their center of vital interests is in Mexico. This center is deemed to be located there, in particular, when more than 50% of their income for the calendar year originates in Mexico, or when they have the principal center of their professional activities there. The code also provides a presumption of residence for Mexican citizens, which allows for evidence to the contrary: dual nationals should carefully consider this.

When the two meet. The France-Mexico Convention distinguishes between a person resident in both countries based on: permanent home, center of vital interests, habitual residence, nationality, and finally, amicable agreement between the authorities. This convention takes precedence over domestic tax domicile. It is described on our page about the convention.

The 180 days without a visa, then the resident permit

France Diplomatie indicates that no short-stay visa is required to enter Mexico. Tourist stays are limited to 180 days, without paid or volunteer work. A visa is required to work or study. The page is undated (accessed 18/10/2026): please review it before departure.

The Migration Law (Article 52) distinguishes between visitors without paid work permits, limited to 180 consecutive days; temporary residents, for up to four years, with the possibility of a work permit upon receiving a job offer; and permanent residents, for an indefinite period. The National Migration Institute (INM) specifies two deadlines: holders of a temporary resident visa must exchange it for their permanent residence permit within 30 calendar days of arrival; residents must notify the INM of any change of address, place of work, or marital status within 90 calendar days. The same page outlines the transition from temporary to permanent status, particularly for retirees or pensioners who receive their income from abroad. The income and savings requirements are not detailed here, as the source was not consulted.

Your last year as a French resident

The government website's page on leaving the country (updated June 25, 2026) requires you to notify your local tax office of your new address. For the year of departure, form 2042 includes your income up to the departure date; foreign-source income is reported on form 2047. Form 2042-NR should only include your French-source income taxable in France during the period of non-residence. The French wealth tax (IFI) then follows the rules for income tax and is managed by the non-resident tax office. The page also advises contacting the tax authorities in your country of residence: in Mexico, the registration procedure and schedule have not been reviewed.

Exit tax: Mexico included in the 2025 transfer notice 2074-ETD

The exit tax applies to anyone who has been a tax resident in France for at least six of the ten years preceding the transfer, and who holds either at least 50% of the profits of a company or securities with a total value of €800,000: the 2074-ETD form states "greater than €800,000," while the general public information sheet states "at least €800,000." The discrepancy in wording is resolved on your tax return.

The rate is 12.8 % for income tax, plus social security contributions of 17.2 % for transfers in 2025 and 18.6 % for departures in 2026. If the securities are kept, the tax is refunded after 2 years (total value less than 2.57 million euros) or 5 years (value above).

For payment, the tax authorities distinguish between automatic deferment and deferment granted upon request. In its "Case No. 1" section, the 2074-ETD notice lists, in addition to the Member States of the European Union, a list of countries for transfers from January 1, 2025. Mexico is included on this list. Automatic deferment requires that the country has concluded an administrative assistance agreement and a recovery assistance agreement with France, and that it is not non-cooperative within the meaning of Article 238-0 A of the French General Tax Code (CGI). Mexico is not among the 11 countries on the list of non-cooperative countries (decree of April 15, 2026). This list and the information in the notice should be reviewed as of your departure date.

What remains taxable in France after departure

A non-resident is taxed in France only on their French-source income, subject to tax treaties. The text of the treaty specifies the allocation of tax.

The internal withholding tax on dividends paid to non-residents is 12.80% as of January 1, 2026, subject to tax treaties. For other French-source income, the minimum non-resident tax rate is 20% up to €29,579 and 30% above that amount (income received in 2025). An option to use the average rate is available if it is more advantageous, provided that both French and foreign household income is declared.

Income from French sources after departure: a numerical example (fictitious profile)

Situation. Marc, a fictional executive, moves to Mexico. He keeps a rented apartment in France; his net taxable rental income reaches €36,000 per year. Assumptions: income received in 2025 (the year targeted by the €29,579 threshold), single person.

Issue. He wants to estimate the French tax on these rents once he is a non-resident.

Strategy. It applies the minimum rate for non-residents: 20 % up to €29,579, 30 % above that.

Result. The first tax bracket amounts to €29,579 × 20% of the % tax bracket, which is €5,915.80. The second bracket covers €6,421 × 30% of the % tax bracket, which is €1,926.30. The tax calculated at the minimum rate alone amounts to €7,842.10, or 21.78% of the income. With €25,000 in rental income, the tax would be €5,000. This calculation does not take into account social security contributions, the option for the average tax rate, or Mexican tax. The amount of €36,000 is an assumption.

Leaving France for Mexico: what changes depending on your situation

• Your links with France: home, main activity, center of economic interests.
• Your nationality, if it is also Mexican.
• The level and nature of your securities, for exit tax and the choice of deferment.
• The nature of your income remaining in France: rents, dividends, pensions, gains.
• Your immigration status in Mexico and its date.

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