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Exit tax
Exit tax: the capital gain on your securities is calculated on the day you leave.
If you leave France with a large portfolio or a stake in a company, you are taxed on the gain you have not yet realised. The tax can be deferred, then cancelled, provided you follow a timetable that starts before departure.
The timetable
Before, during and after departure.
| When | What is done | The point not to miss |
|---|---|---|
| Before departure | Valuation of the securities, calculation of the unrealised gain | To a country without automatic deferral: the request at least 90 days before |
| The following year | Form 2074-ETD with the income tax return | Deferral is automatic within the EU and for countries that assist France in recovering tax |
| Each year of deferral | Annual securities monitoring return | A sale of the securities makes the corresponding tax payable |
| After 2 or 5 years | Relief of the tax on the unrealised gain | Returning to France before this date also cancels the tax |
The relief only applies to the departure tax: a gain realised later may be taxed in your country of residence, under the tax treaty.
Depending on the destination
Automatic deferral, or on request.
No guarantees, just a return: within the European Union, and for countries that exchange tax information and assist France in recovering tax, such as the United Kingdom, Japan or Mexico (2074-ETD 2026 notes).
The UAE, Switzerland, Singapore, Thailand: deferral must be requested at least 90 days before departure, with a tax representative in France and guarantees covering the tax.
The tax is payable : a 12.8% flat-rate levy plus social charges on the entire unrealised gain, without your having sold anything.
What can be decided beforehand
Three decisions that change the amount.
The 6 out of 10 years rule is counted precisely: leaving before your sixth year of domicile in France escapes the exit tax entirely.
The structureShares contributed to a holding company before departure change the tax base and the follow-up. The contribution-and-sale (apport-cession) keeps its deferral if the proceeds are reinvested.See the page →The destinationThe same portfolio requires neither guarantees nor a representative for a move to Lisbon ; it does for Dubai. Our country guides set this out destination by destination.See the page →
Frequently asked questions
What clients ask us.
Which securities are included in the calculation?
Shares and company holdings, rights to profits and securities, listed or not, held directly or by the household, as well as gains placed under tax deferral. The €800,000 threshold is assessed on their total value (Article 167 bis of the French Tax Code).
Are assurance-vie and PEA accounts affected?
No for assurance-vie, which is not a portfolio of directly held securities. Since 2012, a PEA can be kept on departure, except to a non-cooperative State or territory, and a non-resident's gains on it fall outside French tax.
What happens if I return to France?
Deferred tax is relieved if you return before the end of the 2- or 5-year period while still holding the securities. If you come back after 5 years abroad to take up a post, you can also benefit from the impatriate regime for 8 years.
