France and Guernsey: no tax treaty, and a departure to prepare for.

The French administrative list of tax treaties contains no entry for Guernsey. Therefore, we have not found any treaty provisions that limit withholding tax or differentiate between two residences: this page describes French domestic law. An information exchange agreement was signed on March 24, 2009, and has been in effect since October 4, 2010. For departures from France to Guernsey, the first point to consider is exit tax: Guernsey is not on the list of states that offer automatic deferral of payment.

What the lists say, from the French side and from the Guernsey side

The BOFiP lists the agreements in force as of January 1, 2026 (version of April 29, 2026). No line refers to Guernsey, Jersey, the Isle of Man or the Channel Islands.

The intelligence-sharing agreement appears in two official sources:

• the annex to the draft finance bill for 2027: "Information exchange agreement which entered into force on 04/10/2010"; ;
• the Guernsey authorities' page on the information exchange agreements: France, signed on March 24, 2009, effective October 4, 2010.

Guernsey's page on double taxation agreements does not mention France. It lists full agreements (including Luxembourg, Monaco, the United Kingdom, Jersey, and the Isle of Man) and partial agreements (including the Netherlands, Japan, and Ireland). France is not included. The same page specifies that these agreements apply to Guernsey, Alderney, and Herm, but not to Sark or Jethou.

Finally, the French list of non-cooperative states and territories includes 11 states as of the decree of April 15, 2026. Guernsey is not on it. It will be rechecked on the date of departure.

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

Situation. A founding partner, a fictitious profile, has been domiciled in France for over six years. He holds shares with a total value of €1,800,000, including €600,000 in unrealized capital gains. He is planning to leave for Guernsey in 2026.

Issue. He needs to know whether the tax is due from the outset or whether he can defer payment, and what the deferral entails.

Strategy. He reads form 2074-ETD. The automatic deferral applies to transfers to the European Union and to countries on a list. This list includes the United Kingdom. It does not include Guernsey. The form also provides for a deferral granted upon request. This request requires a tax representative established in France and security offered to the non-resident tax office. For income tax, the amount of the security is 12.8% of the total capital gains and receivables.

Result. Calculation assumptions: unrealized capital gain of €600,000; income tax at 12.8% (%), a rate that the 2074-ETD notice states for transfers in 2025 but does not state for a departure in 2026 (we use it here without confirming it for 2026); social security contributions at 18.6% (%), the rate that the notice gives for departures in 2026. On this basis, income tax is €76,800 and social security contributions are €111,600, i.e., €188,400 before deferral and before tax relief. With social security contributions at 17.2% (%), the 2025 transfer rate, the total would be €180,000: the difference due to the social security contribution rate is €8,400. According to the information sheet, the amount of security for income tax purposes is 12.8% of the total capital gains and receivables, i.e., €76,800 in this case: a figure to be confirmed with the relevant department.

The conditions of the exit tax, with two points of divergence

The exit tax may apply to a person who has been a tax resident in France for at least six of the ten years preceding the transfer, and who holds securities with a total value of €800,000 or at least 50% of the profits of a company. The explanatory note states "more than €800,000," while the information sheet states "at least €800,000." The request for deferral must be filed within 90 days before the transfer, as worded differently in the explanatory note and the information sheet. We do not take a definitive stance on either document: reread both texts on the date of your departure.

If the securities are kept, the tax is relieved after two years when their total value is less than 2.57 million euros, and after five years above that.

No tax credit for tax paid outside of France

The practical guide to income tax form 2026 (p. 365) states: "In the absence of a tax treaty, income is taxable in France, without eliminating any potential double taxation in France." The instructions for form 2047 stipulate that, for income from foreign securities and movable capital that does not qualify for a tax credit, a declaration must be made for the net amount of tax withheld abroad, or for the gross amount if no tax has been withheld.

These documents describe the French rule. We have not read the Guernsey rule regarding a credit for French tax.

French tax domicile and internal rules

Article 4 B of the French General Tax Code (CGI) sets out personal, professional, and economic criteria. It is sufficient for one of these criteria to be met (BOI-IR-CHAMP-10, § 310). A stay of more than six months "does not constitute an absolute criterion" (§ 150). The BOFiP (Official Bulletin of Public Finances) states that these rules apply "subject to international agreements." The specifics of how to determine dual residency without an agreement are not addressed in the excerpts provided: this page does not resolve the issue. For the definition of residency in Guernsey (91 days, 182 days), see our sister page on living in Guernsey.

What Guernsey retains from someone who does not live there

The Guernsey administration website describes three situations that are useful for those leaving or maintaining ties with the island:

• Pensions. Guernsey occupational pensions paid to a person residing in a jurisdiction other than the United Kingdom are subject to Guernsey tax at 20 %. Where the new country has no agreement with Guernsey, or the agreement does not address pensions, Guernsey tax is initially withheld at 20 %; allowances are claimed using form 676.
• Rents. A property located in Guernsey is taxed at 20 % of the gross rent, after the standard deduction for works; the agent or the tenant withholds the tax.
• Bank interest. No tax is due on Guernsey bank interest after departure.

On the French side, a non-resident is taxed only on their French-source income, with a minimum rate of 20% (%) up to €29,579 and 30% (%) above that amount for income received in 2025. The tax authority's page on dividends, intended for individuals, indicates a withholding tax of 12.80% (%) as of January 1, 2026, for a French-source dividend paid to a non-resident individual, subject to tax treaties. We have not found any treaty with Guernsey that would extend this "subject to" clause.

Departure procedures and accounts to declare

Initially, you must report your new address, declare income received from January 1st to the departure date on form 2042, and report foreign-source income on form 2047. Form 2042-NR only includes French-source income taxable in France. The French wealth tax (IFI) remains managed by the tax office for non-residents.

Bank accounts, assurance-vie or capitalization contracts, and digital asset accounts opened, held, used, or closed abroad must be declared annually, under penalty of a €1,500 fine per undeclared account (service-public.fr website, page verified on April 15, 2026). The same page stipulates a €10,000 fine when the state has not concluded a tax treaty with the country. We do not classify Guernsey in this category.

What this page does not cover

It does not address the text of the information exchange agreement, Guernsey tax ceilings, social security between France and Guernsey, capital gains and inheritances in Guernsey, or the conditions for a French national to settle there. These points could not be obtained from a usable official source.

What changes depending on your situation

• Your tax residence on the date of departure and its length of time.
• The value of your securities, your shareholding in your companies, and the requested extension.
• The nature of the income you keep in France: dividends, rents, pensions.
• Your status in Guernsey in the year of arrival.

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