Returning to France from Switzerland: transfer date, occupational pension plans, 3916 and expatriates

The Franco-Swiss agreement shifts your social security coverage as soon as your residence is permanently transferred to France. The year of your return is declared in two stages, and your Swiss accounts and contracts are included with the declaration using form 3916 or 3916-bis. A point specific to Switzerland must be addressed before departure: according to a bulletin from the Federal Social Insurance Office (FSIO), cash payments of the mandatory portion of occupational pension contributions are not permitted when moving to a European Union member state.

The day France becomes your home again

Article 4, paragraph 4 of the Convention of 9 September 1966 provides that, when a person permanently transfers their domicile from one State to another, they cease to be subject to VAT in the first State "as soon as the day on which the transfer of domicile took place expires." VAT liability begins in the other State from the same date.

On the Swiss side, the 2026 guide from the Federal Tax Administration states that tax liability ends when a taxpayer permanently leaves their domicile or residence in Switzerland and provides proof of a new domicile abroad. The tax year of departure must be less than one year. A taxpayer who left in March no longer owes tax in Switzerland "unless they still own property there," such as a building.

On the French side, Article 4 B establishes three criteria: primary residence or place of residence, professional activity, and center of economic interests (BOI-IR-CHAMP-10). Only one of these criteria needs to be met. Staying for more than six months in the year is not an absolute requirement. If both states consider you a resident, the agreement will prioritize, in order: permanent residence (center of vital interests), habitual residence, nationality, and agreement of the authorities (Article 4 § 2).

Occupational insurance: to be settled before leaving

Bulletin No. 164 of the Federal Social Insurance Office (FSIO), section 1140, states that in the event of departure to a European Union or EFTA state, "cash payments are excluded for the mandatory portion of the occupational pension scheme (LPP)." Payment is only possible for the supplementary portion. The excerpt comes from a section concerning Swiss citizens living abroad and is based on Article 25f of the Federal Act on the Free Movement of Persons Abroad (LFLP); it assumes a permanent departure from Switzerland. The cover page of the compilation (updated as of July 1, 2026) specifies that the bulletin is simply an informational tool of the FSIO, and Bulletin No. 164 is undated. The excerpt does not mention any conditions regarding social security contributions in the country of arrival.

We were unable to review the French tax treatment of Swiss pension capital, nor that of pillar 3a, nor that of AVS and LPP pensions beyond Article 20 of the convention. Have these points examined before your departure date from Switzerland: timing is crucial.

Statements from the year of the comeback

The steps detailed by the administration on June 25, 2026 are as follows.

First, report your new address in your online account. Attach form 3916 or 3916-bis for your bank accounts, assurance-vie policies, and digital asset accounts held abroad. Failure to do so will result in a fine of €1,500 per undeclared account. Our page on accounts and contracts abroad details the cases.

What the convention says about your Swiss income

Once you are a resident of France, you remain subject to the rules of the 1966 convention for your income from Swiss sources.

Article 25 A entitles you to a tax credit that can be offset against French tax; Swiss tax is not deductible. You can also reread our page on the France-Switzerland convention and the one about the’Swiss withholding tax.

The expatriate regime: a return may fall under it

According to the government website, updated on April 8, 2026, the scheme applies to individuals "who were tax residents outside of France during the five calendar years preceding the year they took up their duties." It applies until December 31 of the eighth calendar year following their start date. Excluded are individuals "who came to work in France of their own volition" and those already residing in France at the time of recruitment. The website addresses two situations: employees recruited by a company established in France and affiliated with the company that employed them abroad, and employees recruited directly from abroad to work for a company in France.

The scheme exempts the additional remuneration directly linked to the performance of professional activity in France, provided that the employer has expressly linked it to the expatriation. The page indicates that the total exemptions "cannot exceed 50% of the total remuneration." It also exempts 50% of certain investment income and capital gains from foreign sources, subject to treaty conditions. The IFI (French Wealth Tax) is limited to assets located in France until December 31st of the fifth year following the establishment of residence. The text refers to taking up a new position: a return without employment, for example for retirement, is assessed on a case-by-case basis.

The exit tax upon return

If you obtained a deferral or paid the exit tax upon leaving France, re-establishing your tax residence in France ("returning to France") triggers a tax relief or refund, provided you still hold the relevant securities or receivables. The tax relief also expires after two years if the total value of the securities was less than €2.57 million on the date of the transfer, and after five years if it was less than that. The transfer of residence outside France terminated the deferral under Article 150-0 B ter for a contribution-sale transaction; this point can be reviewed in the 2074-ETD notice.

Returning from Switzerland with a bonus of €70,000: a numerical example (fictitious profile)

Situation. A fictitious executive has been living in Switzerland since 2021. A French group is recruiting him directly from Switzerland, with a start date of March 1, 2027. His total compensation is €180,000, including a supplement of €70,000 related to activity in France.

Issue. He wants to know if he falls under the expatriate tax regime and how far the exemption goes.

Strategy. He verifies that he has not been domiciled in France during the five calendar years preceding the start of his duties, i.e. 2022 to 2026, that his recruitment is not a personal initiative, and that the employer has expressly linked the supplement to the expatriation.

Result. If the conditions are met, the scheme runs until December 31, 2035, and the IFI (French wealth tax) is limited to assets located in France until December 31, 2032. Calculation assumption: the supplement is the only exemption at play, so the 50% cap on total remuneration applies. This cap is €90,000. The €70,000 supplement falls below the cap, with a margin of €20,000. With a €110,000 supplement, the exemption would be capped at €90,000.

What changes depending on your situation

• The circumstances of your return: taking up a new position, retirement, family project.
• The composition of your pension plan: mandatory or supplementary part, pillar 3a.
• Your accounts, contracts and securities held in Switzerland, and a possible deferral of exit tax.
• A property held in Switzerland, which maintains local taxation.

No result is guaranteed in advance: each point must be read in light of the documents in your file.

For the general procedure (dates, declarations, form 3916, exit tax on hold): I am returning to France after living abroad..