Returning to France from Israel: what you need to declare, and what Israel can keep for five years

Your return to France has two immediate tax consequences: your worldwide income is included in your French tax return from your arrival date, and your accounts held in Israel must be declared using form 3916. On the Israeli side, the National Insurance Institute indicates that a resident who leaves the country remains registered as a resident for the first five years, unless they request to terminate their residency. The 1995 convention designates the country of residence for private pensions: after your return, this is France. It does not address Israeli exit tax, the rules of which we were unable to review.

Two grids for the same return

On the French side, tax residence is the determining factor. According to the BOFiP (Official Bulletin of Public Finances), individuals are considered to be domiciled in France if they have their home or principal residence there, if they carry out a professional activity there (except on a secondary basis), and if they have the center of their economic interests there. Only one criterion is required; a stay of more than six months is not an absolute requirement.

If Israel also considers you a resident, Article 4 § 2 of the convention differentiates between: permanent home, center of vital interests, habitual residence, nationality, and then approval by the authorities. Our page on the France-Israel convention details this article.

The five-year Israeli annexation

The Israeli National Insurance Institute defines residency by the individual's center of life in Israel, using both objective and subjective tests, and requires a residency permit. Its website states that a resident who moves abroad remains registered as a resident for the first five years, with their rights to benefits and public health insurance preserved. The Institute may reassess residency before this period. After five years, residency may be revoked, with the possibility of appeal; an extension is possible if the individual proves, through a questionnaire and supporting documents, that their stay abroad remains temporary and that their center of life is still in Israel. An individual who has moved their center of life abroad may request the termination of their residency before five years; the Institute reviews the application at the family unit level, and it may be denied if the spouse or children remain in Israel.

This affiliation relates to national insurance, not tax residency, which we were unable to ascertain from the Israeli side. The Israeli Tax Authority's page on the annual report for individuals (2023 report, updated December 9, 2024) lists form 1348 for those declaring themselves non-residents of Israel and form 1324 for foreign income. It does not define tax residency. Closing your tax affairs in Israel is done with a local professional.

The statement of the year following the return

The administration's page on returning from expatriation (published on June 25, 2026) distinguishes two cases.

Upon arrival, update your address in your online tax account. Regarding your withholding tax rate, the government website indicates form 2043, along with supporting documents, to be filed with the tax office of your new residence if you had no French-source income during your time abroad. The authorities of your country of origin may request a tax statement, which can be obtained from the tax administration of your country of residence. Any money transfer of €10,000 or more must be declared online to customs.

Your Israeli accounts: form 3916

Bank accounts, life insurance or capitalization contracts, and digital asset accounts opened, used, or closed abroad during the year must be declared using form 3916 or 3916-bis, attached to the income tax return. Failure to declare is punishable by a fine of €1,500 per undeclared account. The tax authorities' website increases this fine to €10,000 if the country does not have a tax treaty with France, and provides for the taxation of presumed income with a surcharge of 40%. The pages consulted do not specify which of the two fines applies to Israeli accounts: this point should be verified before filing any declaration.

The exit tax upon return

If you left France with an exit tax liability, the instructions for form 2074-ETD include "re-establishing your tax residence in France" among the events that trigger a tax reduction or refund on receivables and capital gains, provided you still hold the securities on the date of your return. The deadline for declaring your return is not specified in the documents reviewed. Israel is not included in the list of automatic deferrals in the 2025 transfer guidelines; our page on leaving for Israel details the deferral process upon request.

Expatriate status: five calendar years outside of 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 their appointment to a position in France. It runs until December 31st of the eighth calendar year following their appointment. The tax authority's website (updated April 8, 2026) mentions the exemption of the expatriation bonus, the option to deduct 30% of salary, the 50% exemption on certain income from movable capital, intellectual property, and foreign-source gains, and a French wealth tax (IFI) limited to assets located in France until December 31st of the fifth year following their arrival. Individuals who moved to France of their own volition are excluded. The information sheet also stipulates a condition related to the employer: a French employer (a company linked to a foreign entity within the group) or direct recruitment from abroad. Therefore, the five calendar years alone are not sufficient.

After returning: income and pensions of Israeli origin

The convention allocates the right to tax; its application to your case needs to be examined.

• Pensions. Article 18 restricts private pensions to the State of residence, subject to the provisions for public pensions (Article 19 § 2). Article 24 § 5 provides for a reduction in contributions to a pension scheme established in the other State, limited to six years and subject to the agreement of the competent authority.
• Dividends from an Israeli company. The ceiling under Article 10 § 2 is 15 % of gross tax in other cases, 5 % for a company holding at least 10 % of capital for 365 days, and 10 % in a specific Israeli case. France grants a tax credit equal to the Israeli tax paid, without exceeding the corresponding French tax (Article 23 § 1 a).
• Sale of a stake in an Israeli company. For capital of 10 % or more (25 % for a family company), the state of the company, in this case Israel, may tax the gain up to a limit of 18 % (Article 13 § 2). Whether Israeli law actually levies this tax is not established by the text.

Health insurance upon return

The CLEISS (French Centre for International Social Security Studies) indicates that the France-Israel social security agreement does not provide for coordination regarding health insurance or disability insurance; unemployment benefits are not covered. For those returning from a country outside the European Union, the European Economic Area, Switzerland, and the United Kingdom, the information sheet on service-public.gouv.fr states that you ceased to be covered by French social security during your time abroad, unless you took out voluntary insurance. If you start work immediately, coverage is acquired from the first hour worked (form S1106 at the CPAM - French Health Insurance Fund). Otherwise, three consecutive months of residency in France are required before applying for universal health coverage. Our page on health insurance upon return details the process.

Return to March 2028: numerical example (fictitious profile)

Situation. Camille, a fictional executive, left France in 2019 for Israel, where she is registered as a resident with the national insurance system. She returns on March 1, 2028, to take up a position in Lyon. She holds two bank accounts in Israel.

Issue. She wants to know if the five-year calendar condition is met, how long the expatriate regime lasts, how long the five-year Israeli affiliation lasts, and what it would cost, at the basic rate, to forget form 3916.

Strategy. She lists the five calendar years preceding 2028 (2023 to 2027), verifies that she has not had any tax residence in France during these years, adds eight calendar years to 2028 and five years to her departure from Israel.

Result. The years 2023 to 2027 are considered years without tax residency in France: the five-year residency requirement is met. The scheme runs until December 31, 2036. With tax residency in France in 2025, the requirement would not be met. The first five years of Israeli residency would extend until March 1, 2033, unless the Institute reviews the application or requests termination of residency; beyond that date, residency may be refused or extended with supporting documentation. Without form 3916, the basic penalty would be 2 x €1,500 = €3,000. The tax authority's website specifies a different amount for countries without an anti-tax fraud treaty; the website does not specify which one applies to Israel. The expatriate tax regime involves other conditions, including those related to the employer, which are not examined here. This profile is hypothetical and does not reflect any real-life situation.

Returning from Israel: what changes depending on your situation

• Your arrival date and your tax residence, as defined in Article 4 B and the convention.
• Your French source income before your return, which determines the filing of a 2042-NR.
• A list of your accounts and contracts in Israel.
• The existence of a deferred exit tax and the holding of securities upon return.
• Your status with the Israeli National Insurance and the end date of your residency.
• Your professional situation upon arrival, for the expatriate scheme and health insurance.

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