Exit tax: annual obligations during the grace period

With a deferral of payment, the exit tax does not stop at the departure: the instructions for form 2074-ETS3 state that "the annual filing of the follow-up declaration is mandatory" for transfers from 2014 to 2018. For a transfer since 2019, everything depends on what you have declared: with unrealized capital gains only, ETS3 is only due if an event occurs; with receivables or deferred capital gains, it is due every year, with form 2074-ETSL being able to replace it in the absence of any event.

What this page does not cover

• The initial filing of the 2074-ETD, The choice of deferment and the conditions of the exit tax: see Exit tax: forms 2074-ETD, ETS and ETSL explained and Leaving France: exit tax, tax residence and departure procedures.
• The mixed case (latent capital gains and receivables or deferred capital gains) on the 2074-ETSL. The instructions for form 2074-ETS3 specify annual filing in this case; the instructions for form 2074-ETSL are worded differently. This page does not resolve the issue.
• The exact deadline for filing. The notices refer to the tax calendar on impots.gouv.fr.
• Transfers from 2011 to 2013 (ETS1, ETS2), beyond a referral, and sanctions other than the enforceability of the deferred tax.

What statement, according to what you initially said?

The notices distinguish the following cases for a transfer since 2019.

For a transfer between January 1, 2014 and December 31, 2018, the notice states: "The annual filing of the monitoring declaration is mandatory."«

ETS3 or ETSL: the criterion

Form 2074-ETSL is the simplified form. Its instructions state the condition: "you have not experienced any event that would terminate the payment deferral or result in a tax reduction." As soon as an event occurs during the year, the instructions state that "you cannot file a 2074-ETSL return" and that you must file ETS1, 2, or 3.

The events mentioned in the information sheet and explanatory notes include the sale or repurchase of securities, receipt of additional payment, return to France, gift, death, and the expiry of the tax relief period. Moving to another country is addressed in a separate section and with separate information (see below).

An example from form 2026: the 2-year retention period for a transfer in 2023 involving securities with a total value of less than €2.57 million "expired in 2025"; the form therefore indicates that form 2074-ETS3 must be filed. The same applies to the 5-year retention period for a transfer in 2020 with a total value equal to or greater than this threshold. The tax relief or refund is granted subject to the conditions outlined in the instructions and with the required supporting documents.

Where, when, and with what to deposit

• Or. To the DINR non-resident SIP, 10 rue du Centre, TSA 10010, 93465 Noisy-le-Grand Cedex.
• When. «"within the same legal time limit as for forms 2042 and 2042C." The exact date is shown in the tax calendar.
• Pieces. Forms 2042 and 2042 C accompany the transfer; for transfers since 2019, the ETS3 instructions specify that this is the case "whether or not you have French-source income." With ETS3, you must include the payment if there is an amount due. In the event of a payment or tax credit, the instructions require you to include copies of the income tax and social security contribution assessments issued for the year of the transfer. They also indicate that a copy of the 2074-ETD form filed at the time of the transfer is required.
• Case 8TN. The total amount of deferred tax is entered in box 8TN of form 2042C. On form 2074-ETSL, line 203, "Total tax remaining under deferral," is the sum of lines 201 and 202 and is entered on line 8TN.
• Vintage. Form 2026 of 2074-ETS3 (No. 15525*11) is the 2025 follow-up; it relates to 2042 C "2025 income".

What the 2074-ETS3 contains

The first page contains boxes that guide the completion of the form: a transfer effective from January 1, 2018, with the option for the tax bracket; an event ending the deferral period in 2025; a move to another country in 2025; and securities received following an exchange or contribution. The form requests the address on the filing date and, in the case of a move, the previous address.

Failure to file and change of circumstances

Formal notice. If the tax is not rectified "within 30 days of notification of a formal notice", the tax placed under deferral becomes immediately due, according to the ETS3 and ETSL notices.

Moving or new transfer. The ETS3 guidelines state: "You must, within two months of this move, inform the non-resident tax office (SIP) in writing." The tax administration's guidance sheet states the same rule for a subsequent change of tax residence. The consequences for the tax deferral depend on the country of arrival: read the guidelines. See also Foreign address: inform the tax authorities of your departure.

Annual monitoring of exit tax: numerical example (fictitious profile)

Situation. Karim, a fictitious person, transferred his tax residence outside of France in 2023. He only declared a claim for additional payment, which was fully deferred. No events occurred. Lines 201 and 202 of his tax return show €51,200 and €68,800 respectively: these amounts are hypothetical for the purposes of this example. He moves to another country on September 20, 2026.

Issue. How many follow-up declarations does he have to file, what total to report in 8TN, and until when should he inform the non-resident SIP of his move?

Strategy. Apply the case "receivables only, transfer since 2019": a 2074-ETS3 each year following that of the transfer, the 2074-ETSL can replace it in the absence of an event.

Result. The monitoring years are 2024 and 2025, meaning two monitoring declarations at this stage. On the 2025 monitoring declaration, line 203 is the sum of lines 201 and 202, i.e., €120,000 (€51,200 + €68,800), to be entered on line 8TN of form 2042 C. This total is for this declaration only, not a cumulative total for both years. The two-month period to inform the Non-Resident Tax Office (SIP) of the move on September 20, 2026, runs until November 20, 2026. This profile is hypothetical and does not guarantee any outcome.

Annual monitoring of exit tax: what changes depending on your situation

• The nature of your initially declared amounts : unrealized capital gains, receivables, deferred capital gains, or a mixture.
• The year of your transfer : 2014-2018, since 2019, or before.
• The occurrence of an event during the year, which controls ETS3 rather than ETSL.
• Your country of arrival in case of a new transfer, which determines the fate of the suspended sentence.
• A transfer between France and Monaco without French nationality, for which the ETS3 notice provides for a copy of the deposit with another service (SIP of Nice East-West-Menton).

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