Leaving France for the United Kingdom after the end of the non-domiciled status: what changes for a French person

«"The non-domiciled status is over, so London is no longer worth it." We hear this from Lyon-based executives preparing to sell their company. The status has indeed been abolished, but its replacement allows for a four-year window, and the real constraint is no longer what one might think.

1. What replaces non-dom: four years, then common law

A scheme reserved for newcomers

The old system allowed non-residents to choose to be taxed only on what they repatriated. It was repealed on April 6, 2025. The new foreign income and gains regime (FIG, for foreign income and gains) grants a 100% exemption on foreign-source income and capital gains during the first four years of British tax residence, provided that they have not been a British tax resident for the previous ten years. A French citizen who has never lived in the UK qualifies.

The four years are consecutive and cannot be carried over. The scheme is claimed in the UK annual tax return, source by source: your foreign dividends, for example, and not your interest. See also the FIG regime and the Inheritance Tax.

What the plan doesn't cover, and what it costs

Wages for work performed abroad are excluded. They fall under the category of... system of days worked abroad (Overseas Workday Relief), extended to four years and capped at the lower of £300,000 or 30 % of total employment income.

The exemption comes at a price: by claiming it, you lose income tax and capital gains tax allowances, as well as certain reductions related to marriage or disability. Exempt income is still counted towards the income considered for other benefits, such as subsidized childcare. For those with modest assets, foregoing the claim may be simpler.

For the technician. FIG regime: reserved for "qualifying residents" as defined by the statutory residence test, in their first four years of residence after at least ten years of non-residence; application by declaration Self Assessment ; Foreign employment income excluded (HMRC guidance "Check if you can claim the 4-year foreign income and gains regime"). UK residence: the residency test.

2. The real deadline: ten years and inheritance taxes

Your home address is no longer important; the length of residence is.

Since April 6, 2025, British inheritance tax (Inheritance Tax) depend on the length of residence, plus the place of residence. You become long-term resident If you have been a UK resident for at least ten of the previous twenty tax years, your worldwide assets, including those in France, are subject to taxation. Until this threshold is reached, only your UK assets are subject to taxation. The rate is 40% of the value of assets exceeding £325,000, a threshold raised to £500,000 if the main residence is for your children or grandchildren.

Leaving doesn't set you free immediately.

Exiting the field is not immediate: the duration of exposure after leaving depends on the accumulated years of residence.

After ten consecutive years of non-residence, the status is lost, even upon return. An eight-year stay without prior residence excludes foreign assets; fourteen years of non-residence maintains it for four years after departure.

For the technician. Article 6A of the’Inheritance Tax Act 1984 : long-term resident if resident for at least 10 of the previous 20 tax years; departure after 10 consecutive years of non-residence, or after the number of years in the table (3 to 10); a split tax year (split year) counts as a full year of residence (Inheritance Tax Manual, IHTM47020). The UK Finance Act 2026 reformed relief on business and agricultural property; it does not change the long-term residency rule (ten out of twenty years) in section 6A.

3. What France keeps, what the conventions distribute

The British system eliminates British tax, not French tax at source.

Those who leave poorly planned discover this too late: the FIG exemption works against the British tax authorities, not against the French tax authorities. The Franco-British convention, signed on June 19, 2008, and in force since December 18, 2009, leaves France with several advantages:

• Dividends from French sources — Withholding tax of 12.8% for a non-resident individual (Article 119 bis, 2 of the French General Tax Code, CGI); the convention caps this at 15% of the gross amount (Article 11), a ceiling higher than the domestic tax rate, so the domestic tax rate applies to an individual. No withholding tax is levied on a beneficially owned company subject to corporation tax and holding at least 10% of the capital.
• Real estate located in France — taxable gains in France (Article 14, paragraph 1).
• Other capital gains — taxable in the State of residence of the seller (Article 14, paragraph 5), with a reservation: each State may continue to tax the gains of a person who has been a resident of it during the six preceding tax years (Article 14, paragraph 6).

In the case of dual residence, the convention establishes a hierarchy of factors: permanent home, center of vital interests, habitual residence, and nationality (Article 4). Maintaining a home and family in France is a classic mistake: see the three criteria of article 4 B.

And for inheritance: a 1963 agreement that only covers death

A 1963 convention allocates inheritance tax between the UK and France. It only covers tax due upon death, not gifts (HMRC). It is based on domicile as defined by each state, and the state of domicile grants a credit for tax paid in the other. HMRC specifies that these older conventions apply to the actual domicile, not the presumed domicile: the implications for a French citizen residing in France for more than ten years are a point of analysis, not a given. Other countries: List of inheritance agreements.

For the technician. Convention of 19 June 2008, as amended by the OECD Multilateral Convention (BEPS, Base Erosion and Profit Shifting), Articles 4, 11, 14 and 24 (tax credit). Withholding tax on dividends: Form 2777-SD. 1963 Convention (SI 1963/1319): Articles II (domicile), IV (location of property), V and VI (credit), VII (claim within five years of death).

4. The timetable for a departure to the United Kingdom

A numerical example: four years of foreign dividends

Situation. A French business owner relocates to England in 2026-2027. He has never been a UK resident. His holding company, located outside the UK, pays him £150,000 in dividends annually. Assumptions: no other income, residence in England (excluding Scotland), 2026-2027 tax brackets, no foreign tax credits, illustrative example calculated using the rules in effect on October 23, 2026.

Issue. Without the scheme, the personal allowance disappears beyond £125,140 of income; the £500 dividend allowance remains. Rate: 10.75 % on the basic bracket (£37,700, i.e. £50,270 less £12,570), 35.75 % up to £125,140, 39.35 % above that.

Strategy. He requests FIG exemption for the first four years and prepares from the first year for the fifth: distribution of reserves during the exempt years, or review of the structure.

Result. UK tax calculated without the scheme: £37,200 at 10.75 %, i.e. £3,999.00; £87,440 at 35.75 %, i.e. £31,259.80; £24,860 at 39.35 %, i.e. £9,782.41; total £45,041.21 per year. Under the scheme: £0 on these dividends. Over four years, the difference is £180,164.84, before French withholding tax. Fifth year: tax appears.

For the technician. Personal allowance of £12,570, reduced by £1 for every £2 of net income above £100,000, zero at £125,140. The Scottish tax scale is different.

On the French side, the’exit tax (Article 167 bis of the French General Tax Code) concerns individuals who have been tax residents in France for at least six of the last ten years and who hold securities worth at least €800,000 or representing at least 50% of a company's profits; the deferral of payment depends on the country of destination, to be verified for the United Kingdom, which is no longer a member state of the European Union: Exit tax and tax domicile, guide to departures to the United Kingdom. The return is just as dated: returning to France from the United Kingdom.

Frequently asked questions

Do the unused years of the four-year scheme carry over if I leave and then return?

No. The scheme is limited to four consecutive years from the start of UK residence; unused years are not carried over, and it is not claimed for years of absence from the UK. A departure followed by a return is calculated on a case-by-case basis before departure.

Will my assets in France be subject to British inheritance tax upon my arrival?

No. As long as you haven't been a resident for ten of the previous twenty years, your assets located outside the UK remain excluded. Those located in the UK are included from day one.

Can a French citizen paid by a British company benefit from the four-year scheme?

For foreign income (dividends, interest, gains), yes. For salary, no: foreign employment income is excluded. Days worked abroad fall under a separate scheme, capped at the lower of £300,000 or 30% of employment income.

Are you planning to move to the UK, or have you already signed a lease in London?

The first interview is used to date your two deadlines and to verify that the French residence is actually terminated.

Are you a notary, chartered accountant, lawyer, or fellow consultant? And one of your clients is leaving for the United Kingdom? We act as a co-contractor on the residence, the agreement and the transfer: the client remains yours.

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 23/10/2026.

Official sources consulted

• GOV.UK — Reforming the taxation of non-UK domiciled individuals
• GOV.UK — Check if you can claim the 4-year foreign income and gains regime
• Legislation.gov.uk — Inheritance Tax Act 1984, section 6A
• HMRC — Inheritance Tax Manual IHTM47020 (long-term UK residence test)
• GOV.UK — Inheritance Tax
• GOV.UK — Income Tax rates and Personal Allowances
• GOV.UK — Tax on dividends
• GOV.UK — UK/France Double Taxation Convention of 2008
• HMRC — Double Taxation Relief Manual DT7258 (France: applicable conventions)
• Legislation.gov.uk — 1963 France/United Kingdom Convention (Estate Duty)
• HMRC — Inheritance Tax Manual IHTM47072 (old treaties and domicile)
• Legislation.gov.uk — Finance Act 2026, Schedule 12 (Reliefs on business and agricultural property)
• Impots.gouv.fr — form 2777-SD (withholding tax on income distributed to non-residents)
• Impots.gouv.fr — I am leaving France: do I have to pay the exit tax?
• Service-public.gouv.fr — tax domicile (article 4 B of the CGI)
• National Assembly — Report on the 2008 Franco-British Convention