Leaving France for Mauritius: tax residence, exit tax and residence permit

Moving to Mauritius does not, in itself, sever your tax ties with France: meeting only one of the criteria in Article 4 B of the French General Tax Code (CGI) is sufficient to maintain your tax residency there. If you hold securities, the exit tax may apply. Mauritius is on the list of countries for which the instructions for form 2074-ETD provide for an automatic deferral of payment, subject to the conditions it sets out. For Mauritian tax purposes, residency is determined, in particular, by 183 days of presence during the tax year.

What Maurice asks upon arrival

We were unable to read the Premium Visa income requirements or the specific thresholds for occupancy permits clearly enough to publish them. These must be verified with the Economic Development Board before setting a departure date. We also did not review the Mauritian social security system.

French tax residency is not lost with a plane ticket

The administrative guidelines (BOI-IR-CHAMP-10) consider personal, professional, and economic criteria. Meeting only one of these criteria is sufficient for you to remain domiciled in France. A presence in France of more than six months per year is considered for principal residence, but is not an absolute requirement.

Two points must be checked as a priority before departure:

• You maintain a business activity in France. When you carry out several activities, the administration retains the one that occupies the most effective time; the doctrine also provides for a fallback criterion based on worldwide income (BOI-IR-CHAMP-10, § 220), which this page does not detail.
• Your economic interests remain in France. The center of economic interests is the location of major investments, the headquarters of business, or the administration of property.

If you are running a French company from Mauritius, consider these two points before departure, in addition to the number of days spent there.

Exit tax: Mauritius on the automatic deferment list

The exit tax may apply if you have been a tax resident in France for at least six years during the ten years preceding your departure, and if you hold either at least 50% of the profits of a company or securities with a total value exceeding €800,000 according to the explanatory note ("at least €800,000" according to the public information sheet). Both wordings appear in the tax authorities' sources: verify with the source. According to the explanatory note, income tax is 12.8% and social security contributions are 18.6% for departures in 2026. This explanatory note (relating to transfers in 2025) is only indicative: the tax for the year of departure takes precedence.

The deferral of payment is "either automatic or granted upon request." The automatic deferral mentioned in the notice applies to European Union member states and a list of other states. This list, valid for transfers occurring from January 1, 2025, includes "Mauritius." According to the notice, the automatic deferral also requires an "administrative assistance agreement for combating tax fraud and evasion" with France and that the destination state is not a non-cooperative state as defined in Article 238-0 A of the French General Tax Code (CGI). These two conditions must be met on the date of departure. The annex to the draft Finance Bill for 2027 lists 11 states and territories as non-cooperative states, following the decree of April 15, 2026. Mauritius is not on this list. This list must be verified on the date of your departure, as the decree itself could not be reviewed. Apart from the automatic deferral, the request must be submitted within 90 days before the transfer: the information sheet and the notice formulate this period differently, to be checked with the source.

The tax relief is granted after two years if the total value of the securities is less than €2.57 million, and after five years if the value exceeds €2.57 million, provided the securities are held. The information sheet excludes the tax relief in the event of a sale, redemption and cancellation of the securities, or liquidation of the company during the interim period; the explanatory note lists the sale, redemption, repayment, and cancellation procedures.

The year of departure: two statements

Form 2042 includes your income from January 1st to your departure date, and foreign-source income should be reported on form 2047. Form 2042-NR should only include your French-source income taxable in France. Notify your last tax office of your new address. The tax authorities also recommend contacting your local tax office and clarify that the French wealth tax (IFI) is administered by the non-resident tax office.

Resident of both countries: Article 4 of the 1980 Convention

The convention signed in Port Louis on December 11, 1980, has been in force since September 17, 1982. For a person resident in both States, Article 4, paragraph 2, first considers the State where they have a permanent home; if they have one in both, the State with which their personal and economic ties are closest (center of vital interests). If this center cannot be determined, or if they have no home in either State, the Convention considers the State where they habitually reside; and then, if their habitual residence is in both States or in neither, the State of which they are a national. Failing this, the competent authorities shall decide by mutual agreement.

The Mauritian page refers to an "income year," while Article 15 of the convention refers to a calendar year: each text has its own calculation. The Mauritian administration's page adds that a person wishing to be certified as a resident for an income year must apply for a Tax Residence Certificate. The convention itself is detailed on our page about... France-Mauritius tax treaty.

What remains taxable in France

Once you become a non-resident, you are taxed in France only on your French-source income, subject to tax treaties. For income received in 2025, the minimum rates are 20% of the taxable income up to €29,579 and 30% of the taxable income above that amount, with an option to use the average rate when it is more favorable. The tax authority's page dedicated to dividends paid to a non-resident for tax purposes (individual) indicates a withholding tax of 12.80% as of January 1, 2026, subject to more favorable provisions in tax treaties. Article 10, paragraph 2, of the 1980 tax treaty provides for 5% or 15% of the gross amount, depending on the recipient.

Starting with €3,100,000 in securities: a numerical example (fictitious profile)

Situation. A founding partner from Lyon, a fictitious profile, who has been a tax resident of France for over ten years, owns 70,130 shares of his company. His shares are worth €3,100,000, representing an unrealized capital gain of €1,900,000. He is planning to leave for Mauritius in 2026.

Issue. He wants to know the cost of the exit tax, whether the deferral is automatic, and within what timeframe the tax can be waived.

Strategy. Before the departure date, he calculates the tax, checks the list of non-cooperative states on the scheduled date and reads the conditions of the deferral in notice 2074-ETD.

Result. Before any allowances or other potential adjustments, the calculation yields €596,600: €243,200 in income tax (12.8 times %) and €353,400 in social security contributions (18.6 times %), representing 31.4 times % of the unrealized capital gain. The rates are those in the explanatory note, which is for guidance purposes only. The value of his securities exceeds €2.57 million: the tax relief period is 5 years, provided he retains them.

What changes depending on your situation

• The criterion of tax residence that remains in France: home, activity or economic interests.
• The value and nature of your securities, which determine the exit tax and the relief period.
• The chosen residence permit: Premium Visa, Occupation Permit or Residence Permit.
• The number of days spent in Mauritius during the income year.
• Income and assets that remain in France.

No result is guaranteed in advance: each point must be read in light of the documents in your file.