Exit tax: six years out of ten, tax relief at 2 or 5 years and return to France

The exit tax only applies to taxpayers who were tax residents of France for at least six of the ten years preceding their departure. If you retain your securities, the tax is reduced or refunded after a period of 2 years (total value less than €2.57 million) or 5 years (value above that), according to the instructions for form 2074-ETD. Re-establishing your tax residence in France may also result in a reduction or refund. Conversely, a sale, redemption, or liquidation during the interim period precludes the reduction. This page does not cover social security contributions: their rate depends on the year of departure; please refer to the instructions for form 2074-ETD for that year.

Six out of ten years: how the condition is counted

The instructions for form 2074-ETD stipulate that the taxpayer must have been a tax resident in France "for at least six years during the ten years preceding" the transfer. The information sheet on impots.gouv.fr (updated on 10/03/2026) reiterates the same condition, stating "at least six years during the ten years preceding the transfer".

This page does not address three counting points: the treatment of the transfer year, the treatment of a partial year, and the counting method (date-to-date or calendar year). We do not infer these. If you are close to the limit, have them confirmed before departure, not after.

The length of residency is a prerequisite. It is combined with a participation or value threshold, detailed in Exit tax: which securities and rights are affected?.

The tax relief: 2 years or 5 years depending on the value of the securities

According to the information sheet on impots.gouv.fr, the 2 or 5 year periods apply to transfers from 1 January 2019. The notice 2074-ETD (transfers occurring in 2025) sets them according to the overall value of the securities and rights on the date of the transfer.

The condition set out in the notice is that you must have retained the securities in your assets at the end of the period. If you exchanged or contributed your securities after leaving the country under the conditions of Article 150-0 B or 150-0 B ter of the French General Tax Code (CGI), the notice requires you to retain the securities received in exchange.

The tax relief applies to the taxation of unrealized capital gains, including income tax and social security contributions, according to the information sheet. This page does not address the date on which the period begins, nor the case of a value exactly equal to €2.57 million. Before planning a sale, confirm these two points with the tax authorities.

The time limits have changed. The information sheet states that "this period is reduced from 15 years to 5 or 2 years, depending on the case" for transfers starting on or after January 1, 2019. For transfers occurring between 2014 and 2018, it indicates a period of 15 years. For transfers from March 3, 2011, to December 31, 2013, it indicates 8 years for income tax; social security contributions for this period are, according to the sheet, subject to a separate rule (Finance Law for 2024), which this page does not detail. If your departure was some time ago, reread the information sheet before applying the current time limits.

This is what prevents the tax relief.

The guide lists the events that trigger tax liability: the transfer of securities (sale, contribution, exchange), the repurchase by the company of its own securities, the cancellation of securities, the redemption of bonds and similar securities, and, under certain conditions, a gift. The guide also includes death among the events that trigger tax liability for certain deferred capital gains: the companion page on gifts and death details these cases. The information sheet mentions the transfer, repurchase/cancellation of securities, and the liquidation of the company occurring in the interim.

Other events, on the contrary, give rise to tax relief or refunds according to the instructions: the taxpayer's death, a gift (subject to residency and tax-related conditions, it must be demonstrated that the gift was not made primarily to evade tax), or the actual taxation of capital gains on disposal in France. These cases are detailed in Exit tax: donation or death during the deferral period. We will not elaborate on them here.

Tax relief or refund: the difference

The term depends on your situation. The notice refers to a tax reduction for taxpayers who benefit from a payment deferral, and a refund for those who do not. In both cases, the condition stipulated in the notice is that you must still hold the securities when the deadline expires.

The process involves filing the 2074-ETS3 follow-up declaration the year following the event, along with supporting documents and a copy of the tax assessment notice issued for the transfer. The instructions provide an exception in the case of a subsequent transfer of tax residence. The exact form depends on the year of the transfer: see Exit tax: forms 2074-ETD, ETS and ETSL.

The return to France

Re-establishing your tax residence in France ("returning to France") is listed in the tax notice among the events that qualify for tax relief or a refund. The written condition is that you must still hold the relevant securities or receivables on the date of your return. Tax relief applies to taxpayers who had a deferral of tax, while a refund applies to those who did not.

Two points of clarification regarding what the sources say:

• the notice does not specify a holding period for this event, unlike the 2 or 5 year period; ;
• Neither the exit tax information sheet on impots.gouv.fr nor the page on procedures for returning to France (published on 25/06/2026) details the tax relief or refund upon return. Only the information leaflet provides details on this point.

This page does not address the treatment of capital losses or specific situations upon return: these are examined in the information leaflet for the relevant year. For tax residency and departure procedures, see Leaving France: exit tax, tax residence and procedures.

Tax relief or refund: numerical example (fictitious profile)

Situation. A female executive, domiciled in France since March 15, 2017, transferred her domicile outside of France on June 30, 2025. She holds shares worth €2,400,000, acquired for €500,000. A second hypothetical case, that of a partner, involves shares worth €2,900,000, acquired for €700,000.

Issue. She needs to know if she is subject to the exit tax, what timeframe applies to her securities, and what a return would change. The calculation includes income tax at the flat rate of 12.8% (%) indicated in the information leaflet for 2025 transfers; social security contributions are not included.

Strategy. She is testing three points: the length of her residency, the value of her securities in relation to 2.57 million euros, and the date on which she might want to sell.

Result. Example calculation assumption, from date to date and for illustrative purposes only (the official method is subject to confirmation): from March 15, 2017 to June 30, 2025, the ten-year period began on June 30, 2015 and includes eight full years, i.e., more than six. The unrealized capital gain is €1,900,000; the income tax at the flat rate amounts to €243,200. As the securities are worth less than €2.57 million, the period is two years. If they are still held at the end of this period, or on the date of return to France, this €243,200 is either tax-free or refunded. A sale before the end of this period makes the tax payable. For the partner in the second case, the unrealized capital gain is €2,200,000, the tax is €281,600 and the period is 5 years, because his securities exceed €2.57 million.

Tax relief and refunds: what changes depending on your situation

• The overall value of your securities on the date of transfer determines the 2 or 5 year period.
• The start date of your file determines which version of the rules applies: before or after January 1, 2019.
• An exchange, a donation, a contribution or a transfer after your departure changes the analysis of the securities to be retained.
• A previous tax deferral, such as a contribution-sale, follows its own rules: see Exit tax and tax deferral (150-0 B ter).

These points are examined case by case, on the notice for the year of departure.