No tax treaty between France and Jersey: what this changes

France's administrative list of tax treaties contains no entry for Jersey. Therefore, there is no double taxation treaty between France and Jersey: French domestic law applies, and no article differentiates between the two residences. However, there is an information exchange agreement, which entered into force on October 11, 2010. This agreement organizes the exchange of information. We have not read the text of this agreement and therefore do not consider it to have any bearing on the allocation of tax liability.

Jersey is not included in the French lists: neither a convention nor a list of non-cooperative states.

The BOFiP lists the conventions in force as of January 1, 2026 (version of April 29, 2026). It does not include entries for Jersey, Guernsey, the Isle of Man, or the Channel Islands. The United Kingdom has its own entry. For more recent agreements, the list refers to the "Treaties and Agreements" database of the Ministry of Foreign Affairs.

Two other lists are worth knowing:

• the annex to the draft finance bill for 2027 includes, for Jersey, the mention "Information exchange agreement entered into force on 11/10/2010" (situation as of 1 September 2026); ;
• The French list of non-cooperative states and territories includes 11 states as of the decree of April 15, 2026. Jersey is not on this list. This list is reviewed on the date of departure.

French tax residence: only one criterion is needed

Tax residence is determined according to Article 4 B of the French General Tax Code (CGI), which considers 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 in the year "does not constitute an absolute criterion" (§ 150). The center of economic interests is the location of the principal investments, the headquarters of the business, or the administration of assets (§ 230).

The BOFiP (Official Bulletin of Public Finances) specifies that these internal rules apply "subject to international agreements" (BOI-INT-DG-20-10-10). It describes the tie-breaker based on the permanent residence for individuals covered by an agreement. The outcome of the tie-breaker when there is no agreement is not explained in the excerpts we have read: this page does not resolve the issue.

Two definitions of residence that can overlap

Jersey has its own tax brackets, published by Revenue Jersey. It distinguishes three statuses: resident and ordinarily resident, resident but not ordinarily resident, and non-resident.

Ordinary residents are taxed in Jersey on their worldwide income, "wherever it arises." Non-ordinary residents are taxed on income earned in Jersey and on income transferred there. Transferred funds include foreign income paid into a Jersey bank account, cash brought to the island, and bills paid with foreign income.

On the French side, Article 4B sets out its own criteria. The texts consulted do not specify how to resolve a situation where both administrations consider themselves competent, in the absence of an agreement.

No tax credit is provided for tax paid in Jersey.

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 make the same point regarding income from securities and movable capital: income "not giving rise to a tax credit" is declared for its net amount after tax withheld abroad, or gross if no tax has been withheld.

These two documents apply to French tax. They say nothing about a tax credit granted by Jersey for French tax. We have not read this Jersey rule.

Dividend from a French company paid to a resident of Jersey: numerical example (fictitious profile)

Situation. A consultant, a fictitious profile, moves to Jersey. She holds shares in a French company and receives €10,000 in gross dividends.

Issue. She wonders what difference the absence of a convention makes to the French withholding tax on this dividend.

Strategy. She reads the relevant page on the tax authorities' website, which is addressed to individuals: the withholding tax on dividends of French origin paid to a non-resident individual is 12.80 % as of January 1, 2026, "subject to more favorable provisions under international tax treaties." She notes that no such treaty is listed. She then checks with Jersey to see how this dividend is treated in her local tax return.

Result. The French withholding tax is €1,280 and the net amount received is €8,720. This figure only reflects the French portion. The Jersey tax treatment of the same dividend is not shown here.

What Jersey levies on a non-resident

Revenue Jersey publishes the rules applicable to someone who does not live on the island but receives income there:

• a rate of 20 % on salaries, self-employment income, property income and Jersey pensions, excluding old-age or survivor's social security pensions; ;
• a possible relief. If the non-resident's worldwide income remains below the applicable exemption threshold, the Jersey rate is 0 %; ;
• for non-resident landlords, 20 % of the net rental income, withheld by the managing agent; without an agent, the tenant withholds 20 % when the annual rent reaches £25,000; ;
• exempt income: interest from deposits with a bank registered in Jersey, interest and cash dividends from companies deemed to be resident in Jersey, purchased life annuities, patent royalties.

The tax relief page distinguishes between two cases: the country of residence grants double taxation relief or it does not. The page does not specify which case applies to a French resident, and we cannot deduce it.

Exit tax: Jersey is not included in the automatic deferral list

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 at least 50% of the profits of a company. Form 2074-ETD states "greater than €800,000," while the information sheet states "at least €800,000": reread both before making any calculations. 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 automatic deferral of payment applies to transfers to the European Union or to a state listed in the explanatory notes. Jersey is not included; the United Kingdom is. The explanatory notes also provide for a deferral upon request: this requires a tax representative in France and security interests amounting, for income tax purposes, to 12.8% of the total capital gains and receivables. If the securities are held, a tax refund is granted after two years (total value less than €2.57 million) or five years.

Departure procedures and accounts to declare

Initially, the tax authorities require you to 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. The fine is €1,500 per undeclared account (service-public.fr website, page checked on April 15, 2026). The same page stipulates a fine of €10,000 when the state has not concluded a tax treaty with the state. We do not classify Jersey in this category.

What this page does not cover

This page does not cover the text of the information exchange agreement, Jersey's potential tax credit for French taxes, the determination of dual residency without a tax treaty, social security between France and Jersey, or the conditions for a French citizen to settle in Jersey. For information on local taxes for residents (tax brackets, high-value resident scheme, contributions), please see our sister page on living in Jersey.

What changes depending on your situation

• Your tax residence on the date of departure and your length of residence in France.
• Your Jersey status: ordinary resident or not, and what is transferred to the island.
• The nature of your French income: dividends, rents, capital gains, pensions.
• The value of your securities, your holdings and the applicable deferment.

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