In summary…
A leader leaving France needs a firm that starts with a calendar, not through a product: to meet the four criteria for tax residency, to calculate the exit tax on one's securities, to file the deferral request on time if necessary (no later than 90 days before the transfer), then handle contracts, retirement and compensation. The firm coordinates, with the lawyer and the accountant, what each person must submit and by what date.
Balmont Conseil is a firm not independent In regulatory terms: he receives commissions on the contracts signed, and can also bill for a customized service by the hour. We make this clear from the very first contact.
The administration doesn't look at your address: it looks at where your home is, where you work, and where your investments are. A manager has more things to relocate than an employee, and some of these decisions are made before the departure date.
1. Tax residence: four criteria, only one of which is enough to keep you in France
According to service-public.gouv.fr (information verified on January 1, 2026), your tax residence is in France if mon one of these four criteria is met.
| Criteria | What service-public.gouv.fr says | The trap for a leader |
|---|---|---|
| Home | Your family's (spouse and children's) usual residence is in France | Leaving alone and leaving the family in Lyon |
| Principal stay | France is your main place of residence, meaning at least 183 days per year | Returning often for the company |
| Main activity | Your main activity is carried out in France: the one that takes up the most time or generates the bulk of your income. | Remain a full-time executive of the French company |
| Economic interests | Your main investments are in France, or you manage your assets there. | Company, real estate and accounts all remain in France |
Specifically. Leaving France is not simply a matter of changing your address. You must no longer be tied to France by any of the four criteria, and you must be able to prove it. See Leaving French tax residence: key formalities and managing his French company from abroad.
2. Your company's shares and exit tax
The exit tax concerns the executive who was a tax resident in France. at least six of the ten years preceding departure, and which holds securities whose value reaches €800,000 or that represent at least 50 % of social benefits of a company. It covers unrealized capital gains, i.e., those not yet realized, receivables for additional payments, and deferred capital gains. Source: impots.gouv.fr, page modified on March 10, 2026.
| What's happening | What the administration says |
|---|---|
| Tax payment | A payment deferral applies automatically in some cases, and upon request in others. |
| Request for a stay of execution | For departures since November 22, 2019, the application must be submitted no later than 90 days before the transfer |
| Statement | Form 2074-ETD, filed with the income tax return for the year following departure |
| Follow-up during the suspended sentence | A follow-up form (2074-ETS) is required each year, or a simplified version (2074-ETSL) when the deferment is total and no events have occurred during the year. |
| Relief | After 2 years if the securities in question are worth less than €2,570,000; after 5 years above. It does not apply in the event of a sale, repurchase or cancellation of the securities, or liquidation of the company in the interim. |
Specifically. The question to ask is, "How much, and by what date?" A reputable firm will provide you with an exit tax estimate before you choose the country, not after. The cost depends on the value of your securities: see Cost of exit tax: 3 numerical examples and Exit tax 2026: the executive's guide.
For the technician. Taxation of unrealized capital gains upon transfer of tax residence outside France and deferral of payment: BOFiP, BOI-RPPM-PVBMI-50-10-30. Determination of tax residence: BOFiP, BOI-IR-CHAMP-10.
3. Contracts, retirement, remuneration: what changes after leaving
| Subject | What can be established at the source | Things to prepare before departure |
|---|---|---|
| Assurance-vie | For a resident, redemptions on premiums paid since September 27, 2017 are taxed at 12.8% before 8 years and 7.5% after 8 years (premiums less than €150,000), with an annual allowance of €4,600 (€9,200 for a couple), excluding social security contributions. | A list of each contract, its opening date, and the insurer's written response regarding its requirements for a client living abroad. |
| Retirement | A pension is considered to be of French origin if the paying organization is established in France; its tax treatment depends on its nature and the applicable tax treaty (form 2041-E). | The plans and funds that will pay you, and the applicable agreement |
| Remuneration | Wages from work performed in France remain subject to withholding tax for non-residents when they originate from French sources and are taxable in France according to the applicable tax treaties. | Where the work will be performed, and what the convention says about that income |
| IFI | A non-resident is only taxed on their assets located in France. | An inventory of assets remaining in France, with their value as of January 1st |
| Income tax | A non-resident is generally taxed only on their French-source income, with minimum rates of 20% up to €29,579 and 30% above that. | List of your French income after departure: rent, pensions |
This table does not show what happens to each contract in your future country: this must be verified contract by contract, in accordance with the applicable tax treaty. Service-public.gouv.fr also reminds you to check your obligations with the tax authorities of your country of residence. See Pre-departure checklist: 12 organizations to notify.
4. Typical Calendar
| Phase | What is done | With whom |
|---|---|---|
| As soon as the departure is decided | Inventory of securities, contracts, pensions, real estate, and accounts; calculation of exit tax; selection of the country based on the figures | Consulting firm, tax lawyer, chartered accountant |
| No later than 90 days before the transfer | Filing of the application for a payment deferral, if necessary, along with the required guarantees. | Lawyer, chartered accountant |
| Month of departure | New address provided to your previous tax office; banks, savings banks and insurers notified; proof of residence abroad gathered | You, with the list from the firm |
| Year of departure, the following spring | Income tax return for the period spent in France; form 2074-ETD filed with it | Chartered accountant or lawyer |
| Every year afterwards | Monitoring form during the deferment period; review of contracts, retirement and remaining real estate in France | Consulting firm, remote if needed |
Official guidelines: the 90-day deadline, the address provided to your last tax office, and the return the following spring. The other steps are a working method, not a legal rule.
5. Common pitfalls
- Leaving the family in France : the household criterion is enough to keep you there.
- Continue to lead the French company full-time without having analyzed the criterion of the main activity.
- Discover the exit tax after departure : when a stay of execution is requested, it is before the transfer.
- Sell the securities during the tax relief period : the tax relief no longer applies.
- Do not keep the evidence of his residence abroad.
6. How to choose your firm
- He calculates the exit tax before to discuss investments, and gives you the result in writing.
- He gives his number ORIAS, their status (independent or not independent) and their remuneration before any advice is given.
- He works with lawyers and accountants, and says who does what, and by what date.
- He ensures a follow-up after departure, from a distance.
For tracking from abroad, see Advisor in Lyon: remote support for an expatriate.
At Balmont Conseil: what you pay
Balmont Conseil is a simplified joint-stock company (SASU) established in January 2013. We have been supporting business leaders, professionals, and families for almost 14 years. We are financial investment advisors, members of ANACOFI-CIF, and insurance brokers, registered with ORIAS under number 13003497. We work with 23 partner companies and asset management firms, have no capital ties with any bank or insurer, and collaborate with a network of international notaries, lawyers, and accountants.
| Step | What you pay |
|---|---|
| Initial meeting, in Lyon or via videoconference | Free |
| Contract X-ray : your statements, their charges calculated in euros | Free |
| Balance sheet | Fixed price announced |
| Customized mission | €500 including VAT per hour |
| Contracts signed through us | Commissions paid by the supplier |
| Annual follow-up, possible remotely | Free |
Our position
A successful departure is planned on paper, long before the plane. A good firm doesn't promise to reduce your taxes; it tells you, before you sign a lease abroad, what the exit tax will cost, what criteria still apply to your situation in France, and who files what. If the figures make you postpone your departure, the advice has been done. Ask anyone, including us.
Frequently asked questions
Is it necessary to resign from the management of one's company to become a non-resident?
Not necessarily, but your main activity is one of the four criteria. If it remains in France, it connects you to France: have your case reviewed by your lawyer before leaving.
Does the exit tax apply to all executives?
No. You must have been a tax resident in France for at least six of the ten years preceding departure, and hold securities worth at least €800,000 or representing at least 50% of the profits of a company.
How long does the exit tax follow-up take?
As long as the deferment is in effect, you must file a follow-up form every year until the tax relief is granted: 2 years if the securities are worth less than €2,570,000, 5 years above.
Are you preparing to leave?
The first exchange is free, in Lyon or via videoconference: bring the list of your securities and contracts, and the date you are considering.
Book an appointment
The initial consultation is to establish your exact situation and determine if there is anything that can be done—sometimes there is nothing, and we will say so as well. Thirty minutes, with no obligation.
Book an exchange with Balmont Conseil
Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 24/10/2026.
Official sources consulted
- Service-Public.fr — How to determine your tax residence? (fact sheet F62, verified on January 1, 2026)
- impots.gouv.fr — Do I have to pay an «Exit Tax»? (published on May 5, 2017, modified on March 10, 2026)
- impots.gouv.fr — I am moving abroad: what steps do I need to take? (updated March 10, 2026)
- Service-Public.fr — Income tax for a French citizen who goes to live or work abroad (fact sheet F31442, verified on April 15, 2026)
- Service-Public.fr — Simplified exit tax tracking declaration, form 2074-ETSL (verified on July 29, 2025)
- impots.gouv.fr — Non-resident: declare wages, salaries and pensions (updated February 22, 2024)
- Service-Public.fr — IFI: persons and assets concerned (fact sheet F563, verified on March 6, 2026)
- economie.gouv.fr — What are the tax implications of assurance-vie? (page dated September 17, 2026)
- AMF — «What you need to know about financial investment advisors?» (October 19, 2018)
