No tax treaty between France and Cape Verde: what this means for you

The official list of French tax treaties, published in the BOFiP (Official Bulletin of Public Finances), does not include Cape Verde. However, the two countries are linked by a social security agreement, in force since April 1, 1983: this is not a tax treaty. Cape Verde is also listed in the exit tax guidelines, which grant an automatic deferral of payment, subject to filing forms 2074-ETD and then 2074-ETS. This page explains these points, what France does with your Cape Verdean income, and specifies what it does not cover.

One line in the annex to the 2027 Finance Bill, none in the BOFiP list

The cross in the annex is not legible in the text we were able to consult: we do not consider it to have any effect and we have not read any tax agreement text. Cape Verde is not among the 11 states on the French list of non-cooperative states and territories included in this annex (decree of 15/04/2026). This list is valid as of your departure date.

A social security agreement, not a tax agreement

The Cleiss, a public body, publishes the "General Convention of January 15, 1980," supplemented by two administrative arrangements of 1986 and 1987, which have been in force since April 1, 1983. It covers sickness and maternity, disability, old age and death benefits for insured individuals, work-related accidents and occupational diseases, and family allowances. Unemployment insurance is not included. Salaried employment falls under the legislation of the state where it is performed, with exceptions, including posted workers.

It organizes social protection and is not a tax treaty. For taxation, the internal rules of each state apply.

The Cleiss publishes Cape Verdean contributions "as of January 1, 2024":

The self-employed are not covered against unemployment and are not entitled to family benefits. The National Social Security Institute (INPS) collects contributions. These rates are from 2024: review the information sheet before making any budget.

Exit tax: Cape Verde on the list of 70 states with automatic deferment

Form 2074-ETD places you under the exit tax regime if two conditions are met: tax residency in France for at least six of the ten years preceding the transfer, and ownership of either a shareholding of at least 50% in the profits of a company, or securities with a total value exceeding €800,000. The tax authority's information sheet states "at least €800,000" where the instructions state "greater than". If you are close to the threshold, request a review of your file.

Income tax is 12.8%. Social security contributions are 17.2% for a transfer in 2025 and 18.6% for a departure in 2026.

Payment is automatically suspended for transfers to one EU member state and to 70 other states listed in the information leaflet for transfers from January 1, 2025. Cape Verde is one of them. This suspension does not exempt you from the formalities: according to the tax authorities' information sheet, it requires filing form 2074-ETD at the time of departure, and then filing form 2074-ETS each year. The information leaflet links this list to states bound to France by an administrative assistance agreement and a tax collection assistance agreement, excluding non-cooperative states. The list is subject to change: consult the information leaflet for your year of departure.

If you keep your securities, the tax is reduced after 2 years when their total value is less than 2.57 million euros, and after 5 years when it exceeds that amount.

Securities worth 2.4 million euros before a departure for Cape Verde: a numerical example (fictitious profile)

Situation. A fictitious executive has been domiciled in France for over six years. His shares are worth €2,400,000, including €1,500,000 in unrealized capital gains. He is planning to leave for Cape Verde in 2026.

Issue. He wants to know what the exit tax represents and whether it is payable upon departure.

Strategy. He checks that Cape Verde is included in the automatic deferment list of the notice, files the 2074-ETD at departure, then keeps his titles and files the 2074-ETS every year.

Result. Income tax at 12.8% (%): €192,000.00. Social security contributions at 18.6% (%): €279,000.00. Calculated total: €471,000.00, the payment of which is deferred. The overall value of €2,400,000 is less than €2.57 million: the tax relief would be granted after 2 years of holding. At €2,700,000, the period would be 5 years. The amounts are hypothetical and do not constitute a guarantee of results.

What France does with your Cape Verdean income

It all depends on your tax residence. If you are a resident of France, you must declare your foreign income there, even if it hasn't been transferred to France. The 2026 income tax guide specifies that, in the absence of a tax treaty, income is taxable in France, without eliminating the possibility of double taxation in France.

Regarding income from securities, form 2047 specifies that income from a source in a country without a tax treaty does not qualify for any tax credit. You must declare this income net of any foreign tax withheld, or gross if no tax has been withheld.

If you are domiciled outside France, you are only taxable in France on your French-source income, subject to tax treaties, none of which are listed here. Income received in 2025 is subject to a minimum tax rate of 20% up to €29,579, and then 30% thereafter, unless you opt for the average rate if it is more advantageous for you.

French domicile and Cape Verdean residence: no one to arbitrate

French tax residency is based on three categories of criteria: personal, professional, and economic, only one of which is required. A stay of more than six months per year is considered primary residence, but is not an absolute requirement.

When a tax treaty exists, the BOFiP (French Official Tax Bulletin) specifies that its definition of resident takes precedence over domestic tax domicile. No tax treaty is listed here. Cape Verdean tax residency criteria are not included on any page reviewed. Have your situation reviewed before choosing a departure date.

Entering Cape Verde: what France Diplomacy says

According to the French Ministry of Foreign Affairs, French citizens are exempt from visa requirements for stays of up to 30 days. A tourist visa is required for stays of 31 to 90 days and can be obtained from a Cape Verdean consulate or upon arrival. All non-Cape Verdean travelers without a residence permit must pre-register on the government platform at least five days before arrival and pay an airport security fee of 3,400 escudos (30.83 euros). This page was last updated on May 28, 2013, and is confirmed as of July 24, 2024: please check entry requirements before traveling.

Tax formalities to complete upon departure

Three steps are outlined on the government website: report your new address, declare income received between January 1st and your departure date on form 2042 (including foreign-source income on form 2047), and then complete form 2042-NR, which is reserved for French-source income taxable in France. The non-resident tax office then handles the wealth tax (IFI).

Accounts opened, held, used, or closed abroad must be declared annually using form 3916 or 3916-bis, including assurance-vie policies and digital asset accounts. A forgotten account incurs a €1,500 penalty. The tax authorities cite a figure of €10,000 for an account located in a country without a tax treaty; the texts consulted do not specify whether Cape Verde is included. Verify this point before filing.

What this page does not cover

It does not cover Cape Verdean income tax, withholding taxes, VAT, capital gains and inheritances, or Cape Verdean tax residency. No official Cape Verdean website consulted provides information on these matters or their rates. These points should be verified with a professional based in Cape Verde.

What changes depending on your situation

• Your address: a French criterion met, and the date of your departure.
• The value of your securities, if you own a company: exit tax, deferral, tax relief.
• Your status on site: employee, seconded or self-employed, and the fund to which you belong.
• Your foreign accounts and their declaration.
• Cape Verdean law, which this page does not deal with.

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