Exit tax: forms 2074-ETD, ETS and ETSL explained

At the time of departure, the exit tax is declared on a single form, the 2074-ETD, which is only available in paper format. In subsequent years, if a payment deferral has been granted, the tax is reported using the 2074-ETS (ETS3 for transfers since 2014) or the simplified version, 2074-ETSL. Filing depends on the deferral: if automatic, the 2074-ETD is filed the year following the transfer; if optional, an initial filing is required no later than 90 days before the transfer.

What this page does not cover

• The detailed conditions of the automatic deferment. The information sheet describes several scenarios. The first concerns an initial transfer to a Member State of the European Union or to another State or territory that has concluded an administrative assistance agreement and a mutual assistance agreement for tax recovery with France, and which is not non-cooperative within the meaning of Article 238-0 A of the French General Tax Code (CGI). This page does not list these States or provide details of the other scenarios. Please refer to the information sheet for the year of your departure.
• Calculating the tax on a real estate case, the carry-forward losses and the detailed frameworks of the 2074-ETD.
• Details of the annual monitoring, treated in Exit tax: annual obligations during the grace period.
• Tax residence and exit tax conditions, treated in Leaving France: exit tax, tax residence and departure procedures. For the threshold of €800,000, the notice writes "greater than €800,000" and the administration's guidance sheet "at least €800,000": to be verified with the source.

The forms, in a table

The ETS3 and ETSL forms include the statement "This declaration is an attachment to your comprehensive income tax return form no. 2042". Form 2074-ETD accompanies "Returns no. 2042 and 2042 C for 2025 income".

The 2074-ETD: what notice 2026 says

Field. The notice applies "only to transfers of tax residence occurring in 2025." It does not include a publication date; the tax authorities' guidance sheet indicates "Published on 20/07/2016, amended on 10/03/2026." For a move in 2026, please refer to the notice for that year.

Terms. Exit tax applies if you have been "tax resident in France for at least six years during the ten years preceding the transfer," and if you hold either "a direct or indirect interest of at least 50% in the profits of a company," or securities whose total value reaches the threshold of €800,000 on the date of the transfer ("greater than" in the information notice, "at least" in the guidance document: to be verified). Securities held in a PEA or PEA-PME are excluded.

Three types of amounts. Unrealized capital gains, determined "by the difference between the value of the securities on the date of transfer" and their acquisition price; receivables arising from earn-out clauses; and deferred capital gains, because "the transfer of tax residence outside France terminates the deferral of taxation." For the latter, the instructions advise "reducing the amount shown in box 8UT" of form 2042. An unrealized capital loss "cannot be offset against unrealized capital gains recognized on other investments.".

Rate. Income tax at a flat rate of 12.8% (%), with the option to use the tax scale by ticking box 2OP on form 2042. Social security contributions: 17.2% (%) for a transfer in 2025; "For departures made in 2026, the overall rate will be 18.6% (%)."«

Keep a copy. The instructions state "keep a copy of your declaration no. 2074-ETD"; the copy is used to complete the follow-up.

Where and when to drop off

Automatic stay of execution, or no request for stay. Filing "the year following that of the transfer", "to the tax office (SIP) which was responsible for your residence in France before the transfer", "within the same time limits and at the same time as your income tax return no. 2042 and your supplementary return no. 2042 C".

Deferred payment as an option. Two filings are required. The first must be filed "no later than 90 days before transferring your tax residence outside of France to the non-resident tax office"; you do not file forms 2042 and 2042 C at this time. The second filing is required the following year, with the notation "Second filing" of the optional deferment, the exact wording of which is provided in the information sheet. The information sheet states the same 90-day rule for transfers since November 22, 2019. The information sheet also uses, in another section, the phrase "within ninety days preceding the transfer": this must be confirmed with the tax authorities before setting the date.

Automatic or optional deferment

Payment deferral is automatic or granted upon request. Automatic deferral applies as soon as certain conditions are met, the first being an initial transfer to a Member State of the European Union or to a State or territory meeting the conditions of the conventions described above. Outside of automatic deferral, the instructions require the appointment of a tax representative established in France and set the amount of security at 12.81% of the total amount of capital gains and receivables. If opting for the progressive tax scale results in a higher tax liability, additional payment is due within one month of receiving the tax assessment notice issued for the exit tax.

After the deposit: follow-up, events, deadlines

With a deferral, the total amount of deferred duties is reported in "box 8TN of form 2042C". Forms 2074-ETS3 and 2074-ETSL are filed with the Non-Resident Tax Office (10 rue du Centre, TSA 10010, 93465 Noisy-le-Grand Cedex).

The transfer of securities, defined as "transfer for consideration (sale, contribution, and exchange)," is one event. Returning to tax residence in France is another. For the tax relief, the guidelines stipulate "the expiration of a 2-year period if the total value of the securities and rights is less than €2.57 million," or 5 years if it exceeds that amount.

Two deadlines to remember: thirty days after a formal notice to regularize, otherwise the deferred tax becomes due, and two months to notify a new transfer of tax residence.

Without a deferral, according to the guidance sheet, the follow-up declaration "should only be submitted in the event of an occurrence resulting in a refund"; notice 2074-ETS3 refers to a refund of all or part of the tax.

Exit tax forms: numerical example (fictitious profile)

Situation. Inès, a fictitious person, plans to transfer her tax residence outside of France on March 15, 2027. She meets the conditions for the exit tax. Her unrealized capital gains amount to €1,500,000, and she holds a claim for additional payment of €200,000. It is assumed that her destination does not qualify for automatic deferral.

Issue. On what date must she file her first application for deferment by option, and what is the amount of the security of 12.8 % of the total of the capital gains and receivables?

Strategy. Apply the rule outlined in the notice: the first filing must be made no later than 90 days before the transfer, to the non-resident tax office (SIP), without forms 2042 and 2042 C; the second filing must be made the following year. The 12.8% % rate for security interests is that specified in the 2025 transfer notice; the notice for the year of departure should be reviewed.

Result. The first filing must be made no later than December 15, 2026, i.e., 90 days before March 15, 2027, using the formula "no later than 90 days before the transfer." The total amount of capital gains and receivables is €1,700,000; 12.8% of this total, the amount of the security interests as per the instructions, gives €217,600. The second filing is due in 2028, along with forms 2042 and 2042 C. This scenario is hypothetical and does not guarantee any specific outcome.

Exit tax forms: what changes depending on your case

• Your destination : she decides on the automatic or optional deferment.
• The nature of your amounts : unrealized capital gains, receivables, deferred capital gains.
• The overall value of your securities : the threshold of 2.57 million euros sets the deadline of 2 or 5 years.
• The year of your departure : rates, forms and instructions are those of the year.
• A previous contribution-sale : the end of the postponement changes the analysis.

The rule depends on your situation; check before deciding. No results are guaranteed.