No tax treaty between France and the Bahamas: what this changes

France's administrative list of tax treaties contains no entry for the Bahamas. Therefore, no treaty article exists to differentiate between the two states or to cap withholding tax: French domestic law applies. A person domiciled in France is taxed on their worldwide income. A person who moves to the Bahamas remains taxable in France on their French-sourced income. This page presents what we have been able to confirm from both the French and Bahamian perspectives, and explains what it does not cover.

What the official list says, and what it doesn't say

The BOI-ANNX-000306 doctrine, in its version of April 29, 2026, lists the tax treaties concluded by France. It contains no entry for the Bahamas. The page specifies that it covers treaties in force on January 1, 2026, and refers, for other agreements, to the Ministry's "Treaties and Agreements" database.

The absence is therefore valid as of that date. It should be rechecked before any decision to leave or invest.

French tax residence is determined without a tie-breaker clause.

Article 4 B of the French General Tax Code (CGI) establishes three categories of criteria: personal, professional, and economic. Only one of these criteria needs to be met for tax residence to be in France (BOI-IR-CHAMP-10, § 70 and § 310).

Three clarifications from the BOFiP:

• a stay of more than six months in the year is considered as the main stay, but "does not constitute an absolute criterion" (§ 130 and § 150); ;
• in the case of multiple activities, the main activity counts (§ 220); ;
• the centre of economic interests is a criterion in its own right (§ 230).

The BOFiP (French Official Tax Bulletin) indicates that these internal rules apply only subject to tax treaties (BOI-INT-DG-20-10-10, § 20). Since no treaty is listed for the Bahamas, there is no article to differentiate between a French tax domicile and a Bahamian residence.

Two consequences are outlined in the doctrine. Income earned abroad by a person domiciled in France is taxable "even if it has not been transferred to France" (§ 70). Persons domiciled outside France are taxable only on their French-source income (§ 90).

A tax paid in the Bahamas: something we were unable to establish

We looked to see if the BOFiP (Official Bulletin of Public Finances) provides for a tax credit or deduction of foreign tax when no tax treaty exists. The pages we consulted on eliminating double taxation do not answer this question, except for the CSG (General Social Contribution) and CRDS (Contribution to the Repayment of the Social Debt). This page therefore does not resolve the issue. It depends on the income in question and must be addressed on a case-by-case basis.

Agreement on the exchange of information, but no list of non-cooperative states

The Bahamas are not on the French list of non-cooperative states and territories. This list includes 11 states as of the decree of April 15, 2026, according to the annex to the draft budget law for 2027. It is verified on the date of departure.

The same annex, entitled "List of States or Territories Having Concluded an Administrative Assistance Agreement with France in Force on September 1, 2026," contains a line for the Bahamas: "Information Exchange Agreement Entered into Force on September 13, 2010." This is an information exchange agreement. We have not read the text of this agreement and we do not attribute any effect to it on the allocation of the tax.

Exit tax: the automatic deferral is based on assistance agreements, not on the tax treaty.

The exit tax may apply to a person who has been a tax resident in France for at least six of the last ten years and who holds securities with a total value of €800,000 or a shareholding of at least 50% in the profits of a company. Form 2074-ETD and the tax authorities' information sheet do not formulate this threshold in the same way ("greater than" and "at least"): it is read in both texts before any calculation.

The rates are 12.8 % for income tax and, for social security contributions, 17.2 % for transfers in 2025 and 18.6 % for departures in 2026.

The deferral of payment is either automatic or granted upon request. According to the information sheet (case no. 1), it is automatic for a transfer to a Member State of the European Union or to a State that has concluded with France an administrative assistance agreement for combating tax fraud and evasion, as well as a mutual assistance agreement for tax recovery, and which is not non-cooperative within the meaning of Article 238-0 A of the French General Tax Code (CGI). The information sheet publishes a list of 70 States for transfers occurring from January 1, 2025: the Bahamas are not included. Furthermore, the appendix to the draft Finance Bill for 2027 contains a line item for the Bahamas under administrative assistance (information exchange agreement), whereas case no. 1 also requires a mutual assistance agreement for tax recovery. This page draws no conclusions from this comparison: the deferral applicable to your departure should be verified. In other cases, a declaration must be filed within 90 days before the transfer. This period is stated differently in the information leaflet and the fact sheet. If the securities are held, the tax is reduced after two years when their total value is less than €2.57 million, and after five years if it exceeds that amount.

Exit tax for a departure to the Bahamas: numerical example (fictitious profile)

Situation. A fictitious executive has been domiciled in France for at least six of the last ten years. He holds securities with a total value of €1,800,000, including €600,000 in unrealized capital gains. He is planning to leave for the Bahamas in 2026.

Issue. He wants to know if the absence of a tax treaty changes the amount of the exit tax. The documents he consulted do not specify a rate specific to the Bahamas; they are the rates outlined in the information notice. The real question concerns the deferral, the conditions of which are determined by the country of destination.

Strategy. Before departure, he checks three points: the country's eligibility for automatic deferment, the application deadline if deferment is optional, and the retention of documents for tax relief.

Result. On an assumed unrealized capital gain of €600,000, income tax at 12.8% (%) amounts to €76,800. Social security contributions at 18.6% (%) amount to €111,600. The total is €188,400 before deferral and tax relief. With the 17.2% (%) rate applicable to transfers in 2025, the total would be €180,000: the year of departure accounts for €8,400 in this example. This amount reflects the significance of the situation. It is not paid immediately if a deferral applies.

Departure steps to take

Initially, the tax authorities require you to report your new address, declare income received from January 1st to your departure date on form 2042, and report foreign-source income on form 2047. Form 2042-NR should only include French-source income taxable in France, from your departure date to December 31st. The French Wealth Tax (IFI) is managed by the SIP-NR (French Tax Administration). The official website also recommends contacting the tax authorities in your country of residence.

Accounts opened in the Bahamas: the annual declaration

Bank accounts, life insurance or capitalization contracts, and digital asset accounts opened, held, used, or closed abroad must be declared annually. Failure to declare is punishable by a fine of €1,500 per undeclared account (service-public.fr website, page verified on April 15, 2026). The same page stipulates a fine of €10,000 for a country without an anti-fraud treaty. Official websites do not formulate this criterion in the same way: we do not classify the Bahamas.

What we read at the Bahamian administration

• VAT. Two rates: a standard rate of 10 % and a zero rate (Department of Inland Revenue, page modified in April 2024). An announcement dated September 12, 2025, effective September 1, is titled "5% VAT Reduction on Selected Medical Supplies"; we do not specify the details, which are not provided on the announcement page.
• Tax authorities. The Department of Inland Revenue combines business license fees, first home exemption, property tax and VAT.
• Property tax. It exists. The invoice is due upon issuance, and exemptions are not automatic: they must be requested. The rates are not listed on the pages read.
• DMTT. The Domestic Minimum Top-up Tax Act 2024 applies to Bahamian entities falling within its reporting scope. Forms DMTT-24 and DMTT-25 were due on March 31 and April 30, 2026, respectively.
• Gift. An exemption applies to the deed of gift of real estate between parent and child, grandparent and grandchild, and between spouses, for all nationalities.

What this page does not cover

It does not address local taxation of income, capital gains, and inheritances, nor withholding taxes, Bahamian tax residency criteria, social security, or residency permits: these points could not be obtained from an official source. They should be verified with a professional based in the Bahamas. It also does not address French tax credits on foreign taxes in the absence of a tax treaty.

What changes depending on your situation

• Your tax residence on the date of departure and the duration of your residence in France.
• The nature and value of your securities, and your ownership stake in the companies you hold.
• The applicable stay of execution at your destination and the time you request it.
• The nature of the income you keep in France and the accounts you open there.

A departure is prepared based on the facts of your case. No outcome is guaranteed in advance.