Leaving France for Belgium: exit tax, tax residency and registration with the municipality

To settle in Belgium, three issues must be addressed in order: the exit tax on your securities, tax residency (the 1964 convention addresses this in Article 1, not Article 4), and then registration with the Belgian municipality. The official notice notably provides for an automatic deferral of payment for a transfer to a non-cooperative EU member state; France Diplomatie presents Belgium as an EU member. This classification is verified on the date of your departure.

Exit tax: are you affected?

Two conditions must be met. You must have been a tax resident in France for at least six of the ten years preceding the transfer. You must also hold at least 50% of the profits of a company, or securities with a total value of €800,000. The tax authorities do not use the same formula for the €800,000 threshold: if your securities are close to this amount, have your case reviewed.

Income tax is 12.8 %, the rate in form 2074-ETD, established for transfers in 2025. Social security contributions are 17.2 % for a transfer in 2025 and 18.6 % for a departure in 2026, according to the same form.

Suspension, tax relief and declaration

According to the administration's information sheet, the tax relief applies unless the shares are sold, redeemed and cancelled, or the company is liquidated in the interim. The list of non-cooperative states is based on the decree of February 12, 2010, most recently amended by the decree of April 15, 2026: this page does not reproduce the list.

Residence: French tax domicile, then the Franco-Belgian tax treaty

According to the BOFiP (Official Bulletin of Public Finances), France considers three criteria: the primary residence or place of residence, the main professional activity, and the center of economic interests. Only one is required. Spending less than six months in France does not guarantee protection.

If Belgium also considers you a resident, the convention of 10 March 1964 decides in its article 1 § 2, in this order:

1. the permanent home; ;
2. if you have one in each State, the State with which your personal and economic ties are closest, that is to say, the center of your vital interests; ;
3. failing that, the State where you habitually reside; ;
4. then the State of which you are a national, and finally the agreement of the competent authorities.

The French Embassy in Belgium indicates that this bilateral agreement remains in force. Our page on the France-Belgium agreement provides further details.

The year of departure

Declaration is mandatory. According to the administration:

• form 2042 covers your income from January 1st to the date of departure; ;
• form 2042-NR only includes your French-source income taxable in France after departure; ;
• Once the declaration has been processed, the non-resident individual tax service will monitor your case if any French-source income remains; ;
• The IFI then follows the same service; local taxes remain managed by the service of the place where the property is located; ;
• To pay online, you need an account domiciled in France or in the SEPA zone.

What France continues to impose

As a non-resident, you remain taxable on your French-source income, subject to the tax treaty. The minimum rate is 20% of income up to €29,579 in 2025, then 30%; the option for the average rate remains available. The French wealth tax (IFI) applies to real estate assets located in France exceeding €1.3 million. Capital gains on securities are generally not taxed in France for non-residents, except for holdings exceeding 25% of income at some point during the previous five years: the tax is then 12.8%, and 75% for residents of non-cooperative jurisdictions.

On the Belgian side: registration with the municipality

For stays exceeding three months, EU citizens must apply for their registration certificate within three months of arrival; the municipality initially issues an "Annex 19." A late application may result in an administrative fine of €200. Economically inactive citizens must have resources at least equal to Belgian social security benefits. From the age of 15, individuals must be able to prove their right of residence at any time in a public place, under penalty of a fine ranging from €26 to €500. A valid identity card or passport is sufficient for entry.

Your securities upon arrival: the Belgian tax on financial capital gains

Belgium has adopted a tax on capital gains from financial assets. The parliamentary file for the Chamber indicates a vote in plenary session on April 2, 2026, and publication in the Belgian Official Gazette on April 21, 2026. The text adopted in committee, which the plenary session adopted verbatim according to the official document, stipulates that the acquisition of a financial asset transferred to Belgium is deemed to have been made at its value on the first day of liability for personal income tax. For an insurance contract, the starting point is the inventory reserve upon arrival. Our page on tax matters in Belgium details this tax. It falls under Belgian law: have it reviewed by a Belgian professional.

Starting with 60 % from a company: numerical example (fictitious profile)

Situation. A fictitious executive, tax resident in France for over ten years, owns 60 % shares of his company. His shares are worth €3,100,000, representing an unrealized capital gain of €1,850,000. He relocates to Belgium at the end of 2026.

Issue. He meets both conditions of the exit tax and wants to know the tax involved and the time limit for relief.

Strategy. He applies 12.8 % (rate from notice 2074-ETD, established for transfers in 2025) and 18.6 % (social security contributions for a departure in 2026) to the unrealized capital gain, then compares the value of his securities to €2,570,000.

Result. Income tax: €236,800. Social security contributions: €344,100. Total: €580,900, representing 31.4% of the capital gain. His securities exceed €2,570,000: the tax relief period is 5 years. With €2,400,000 worth of securities, it would be 2 years. The automatic deferral depends on the state's classification at the time of departure. The profile and amounts are fictitious.

What changes depending on your situation

• The value and nature of your securities, which determine the tax relief period.
• The classification of the destination state at the date of departure.
• Your ties in France (home, work, economic interests) after leaving.
• The act of keeping real estate in France.
• Your financial assets to be transferred to Belgium.

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