Exit tax and deferral of taxation on the contribution of securities (150-0 B ter)

If you have contributed securities to a company you control and you leave France, the deferral of taxation ends. The BOFiP (French Official Tax Bulletin) states that transferring your tax residence outside of France is an event that terminates the deferral. Form 2074-ETD adds that the deferred capital gains then become immediately taxable. It also stipulates that the deferral of payment of the exit tax may apply to these capital gains.

This page follows the BOFiP (August 2026 versions) and notice 2074-ETD relating to 2025 transfers.

What this page does not cover

• The conditions for the postponement 150-0 B ter (company control, cash payment) and reinvestment: see the pages on the contribution of securities.
• Entry thresholds for the exit tax and the calculation of tax on unrealized capital gains.
• The text of article 167 bis of the CGI. The page only includes what the BOFiP and the instructions say about it.
• The rate in figures. The sources refer to the rate for the year of the contribution; the page does not calculate it for your case.

Key points to remember

Two devices, one event

The deferral of the contribution is governed by Article 150-0 B ter. The exit tax falls under Article 167 bis. The two texts intersect on the date of departure.

The BOFiP (French Official Tax Bulletin) includes departure among the events that terminate the deferral of taxation, along with the sale or repurchase of received securities: "transfer of tax residence outside of France (French General Tax Code, art. 150-0 B ter, I-4°)" (§ 10). In § 300, it specifies that, with regard to articles 150-0 B ter and 167 bis of the French General Tax Code, the transfer is "an event that terminates the deferral of taxation." The BOFiP does not detail the mechanism of article 167 bis in this document.

The official tax return guidelines (BOI) do not cover changes of address or form 2074-ETD. For exit tax, the instructions refer to BOFiP reference BOI-RPPM-PVBMI-50.

What happens on the departure date

The notice is clear: "Transferring your tax residence outside of France terminates the deferral of taxation and therefore makes immediately taxable any capital gains held under tax deferral that you have on the date of the transfer." Article 150-0 B ter is among the deferrals cited in the notice, along with other deferral mechanisms.

The scope is limited to carryovers "whose carryover has not expired on the date of the transfer".

The end of the deferral is a departure event, just like the sale or repurchase of the securities received.

The rate: that of the year of the contribution

Upon expiry of the deferral period, the capital gain is taxed "at the tax rate that would have applied had it been taxed in the year it was realized" (BOI § 360), i.e., the year of the contribution. The BOFiP also states that the deferral "has the effect of postponing the actual taxation" of the capital gain (§ 310).

The notice reiterates the idea: regardless of the method of taxation for income tax, 12.8 % or progressive scale, capital gains in deferral 150-0 B ter "remain, upon expiry of the deferral, taxed at a historical tax rate".

This page does not calculate the tax in a real case: the rate depends on the year of the contribution and your file.

Does the payment deferral apply to deferred capital gains?

The information notice answers in the affirmative: "Article 167 bis of the French General Tax Code (CGI) provides for a deferral of payment, applicable automatically or upon express request." The deferral can cover "capital gains that have been deferred and have become taxable as a result of this transfer" and can be requested separately for all of these capital gains.

Three key points taken from the impots.gouv.fr website (modified on 10/03/2026):

• The deferment is either automatic or granted on request via form 2074-ETD; ;
• For a transfer since November 22, 2019, the application must be submitted no later than 90 days before the transfer; ;
• The annual follow-up is then done using the 2074-ETS, or the simplified 2074-ETSL.

Failure to file the follow-up notice terminates the deferral and makes the tax immediately payable, unless rectified within thirty days of a formal notice (see notice, § VI). The events that interrupt the deferral are detailed on the page concerning gifts, death, and transfers.

Declarations: Box 8UT and tracking status

Each year, you declare the total amount of deferred capital gains on line 8UT of form 2042 (BOI-RPPM-PVBMI-30-10-60-40, § 40). Upon transfer, the instructions instruct you to "reduce the amount shown in box 8UT of your form 2042" and to reset the tracking statement on form 2074-I to "reduce all your deferred capital gains to zero.".

The capital gain has not disappeared: the instructions provide a section dedicated to deferred capital gains in the 2074-ETD declaration.

The deadlines for the 2026 budget law

Law No. 2026-103 of February 19, 2026, amended Article 150-0 B ter. According to the BOFiP update of August 10, 2026, the reinvestment threshold increases from 60 % to 70 %, and the reinvestment period is extended from two to three years. These provisions apply to disposals "carried out on or after February 21, 2026.".

The BOFiP (French Official Tax Bulletin) states that the sale, repurchase, redemption, or cancellation of contributed securities terminates the deferral period after three years from the date of the contribution, unless at least 70% of the proceeds are reinvested. The BOFiP applies this three-year period only to these events (§ 10, I-2°). A change of residence is a separate event (§ 10, I-4°), for which § 300 does not specify a time limit.

Gift, death, donee who leaves

• Gift and death. The information notice includes, in its list of tax relief or refunds, provisions for gifts and inheritances concerning "capital gains realized from November 14, 2012, onwards, upon a contribution of securities to a company controlled by the contributor and placed under deferral," as defined in Article 150-0 B ter. The conditions for this tax relief or refund are detailed in the notice (Section IV.B).
• The departing donee. For the donee of securities received as remuneration for a contribution, the BOFiP writes that "the transfer of tax residence outside of France is treated as a transfer for consideration" (BOI-RPPM-PVBMI-30-10-60-30, § 220).
• A contribution made abroad. Contributions made under Article 150-0 B ter while you are tax resident abroad are not considered transfers for the purposes of monitoring the deferral. The deferral ends upon the same events that terminate the postponement.

Exit tax and carry-forward 150-0 B ter: numerical example (fictitious profile)

Situation. Marc transferred his company's shares to his holding company on March 12, 2024. The deferred capital gain is estimated at €800,000. He plans to leave France on January 30, 2027.

Issue. What happens to the postponement to the departure date, and until when can the payment deferral be requested?

Strategy. Apply the instructions (§ IC): the transfer terminates the deferral. Follow box 8UT. Calculate the deadline for the deferral request.

Result. The €800,000 of deferred capital gains become taxable on the date of the transfer, at the 2024 tax rate, which is not specified here. Box 8UT changes from €800,000 to €0 if this is the only deferral. The three-year period since the contribution is not relevant to this calculation: it concerns the sale of the contributed securities, not the transfer of residence (BOFiP § 10 and § 300). If a deferral is requested, the deadline is November 1, 2026, i.e., 90 days before departure, using the formula "no later than 90 days before the transfer" (impots.gouv.fr information sheet; instructions § V). The instructions also use, in § III.B, the formula "within ninety days preceding the transfer": this should be confirmed with the tax authorities before setting the date. The figures are fictitious and do not reflect your situation.

Exit tax and carry-forward 150-0 B ter: what changes depending on your case

• The year of the contribution, which sets the rate.
• The destination state, which determines whether the suspension is automatic or upon request.
• The date of the transfer compared to February 21, 2026 for the disposals.
• Annual monitoring submitted on time.

The rule depends on your situation. No results are guaranteed.