Leaving France for Vietnam: applying for an exit tax deferral, visa requirements, and declarations

Vietnam is not included in the list of automatically granted tax deferrals in form 2074-ETD (transfers from 2025). If exit tax applies to you, you must request a deferral before departure, with a tax representative and collateral. Leaving France is not simply a matter of changing your address: meeting just one of the three criteria in Article 4 B of the French General Tax Code (CGI) is sufficient to maintain your French tax residency. This page addresses departure from the French perspective. It does not cover Vietnamese taxation, for which we have been unable to obtain any official documents.

Vietnam is not on the automatic deferment list

The exit tax applies to taxpayers domiciled in France for at least six of the ten years preceding the transfer, who hold either at least 50% of a company's profits or securities with a total value exceeding €800,000 on the transfer date. The explanatory note states "exceeding," while the public information sheet states "at least": we are not taking a definitive stance. Income tax is 12.8% (option for the progressive tax scale via box 2OP). Social security contributions are 17.2% for a 2025 transfer and 18.6% for a 2026 departure. For a later departure, the rates apply.

The automatic suspension of tax liability applies to Member States of the European Union and to States bound to France by an administrative assistance agreement against fraud and a mutual assistance agreement on tax recovery, provided they are not non-cooperative within the meaning of Article 238-0 A of the French General Tax Code (CGI). The explanatory note lists 70 non-EU States. Based on our interpretation, Vietnam is not included, and we draw no further conclusions from this. Please review the explanatory note's list applicable to your departure date.

A stay of execution remains possible upon express request (part III.B of the instructions):

The instructions themselves use two formulations: "within ninety days prior to the transfer" (part III.B) and "no later than 90 days before the transfer" (other parts). The administration's information sheet states "no later than 90 days before this transfer." These formulations should not be interpreted in the same way (filing window or deadline): confirm the deadline before submitting.

Relief. The tax is reduced or refunded after two years if the total value of the securities is less than €2.57 million, and after five years if it exceeds that amount, provided the securities are still held. Returning to France is another event that triggers tax relief, under the same condition.

Statements. Form 2074-ETD, in paper format, must be filed the year following the transfer to the tax office (SIP) of your former residence, along with forms 2042 and 2042 C. In the case of a deferral upon request, this involves a second filing of the same form: the first is made before departure, with the Non-Resident Tax Office (SIP). Annual monitoring is carried out using form 2074-ETS3, or 2074-ETSL if no changes have occurred. If the situation is not rectified within thirty days of a formal notice, the deferral ends and the tax becomes immediately due.

Contribution-sale. Transferring one's tax residence outside of France terminates the deferral of taxation under Article 150-0 B ter. According to the BOFiP (Official Bulletin of Public Finances), the capital gain is taxed at the rate that would have applied to it for the year in which it was realized.

When does one cease to be a tax resident of France?

According to the BOFiP (Official Bulletin of Public Finances), individuals are considered domiciled in France if they have their home or principal residence there, if they primarily carry out their professional activity there, and if they have the center of their economic interests there. One criterion is sufficient. A stay of more than six months is not an absolute criterion. Having a home, activity, or economic interests remaining in France falls under these criteria.

If Vietnam also considers you a resident, the convention of February 10, 1993, establishes the following order of precedence: permanent home, failing that, the center of vital interests, then habitual residence, nationality, and finally, the agreement of the authorities (Article 4, § 2). The convention takes precedence over domestic law. Our page on the France-Vietnam convention provides further details.

Entering and staying in Vietnam

France Diplomatie indicates that, since August 15, 2023, French citizens are exempt from visa requirements for stays not exceeding 45 days, including the days of entry and exit. The passport must remain valid for six months after the end of the stay. For stays exceeding 45 days, a visa is required. The e-visa covers up to 90 days with multiple entries. Tourist visas and e-visas cannot be extended or renewed locally.

The last verification displayed on this page dates from June 15, 2024: please check the rules as of your departure date. The residence permit for permanent settlement is not mentioned in the sources we have consulted.

On the Vietnamese side: what we were unable to read

The websites of the Vietnamese tax authorities and the Ministry of Finance were not accessible to us. Therefore, the criteria for Vietnamese tax residency, tax rates, taxation of savings, and the social security system are not addressed here, and we make no claims regarding them. The tax authorities of your country of residence should be contacted upon arrival: the French tax authority's website reminds you that certain income may need to be declared in both countries.

Statements from the year of departure

Notify your last tax office of your new address in your online tax account. Inform your employer and pension providers; for pensions, the government website refers to form 2041-E. For the year of departure, form 2042 includes your income from January 1st to the departure date, with foreign-source income reported on form 2047. Form 2042-NR only includes your French-source income taxable in France, from departure to December 31st. The Non-Resident Tax Office (SIP-NR) manages your French wealth tax (IFI) from the moment you leave.

What France still imposes

Non-residents are taxed in France only on their French-source income, subject to tax treaties. For 2025 income, the minimum rate is 20% (%) up to €29,579 and 30% (%) above that amount, with an option for the average rate which requires declaring all household income. The Franco-Vietnamese tax treaty states:

• Dividends from a French company. The withholding is capped at 15 % of the gross, or at 5 % for a beneficiary company which directly holds at least 10 % of the capital (Article 10 § 2).
• Private guesthouses. They are taxable only in the beneficiary's state of residence. Public pensions are taxable in the paying state, except in the case of Article 18 § 2.
• Wages. Taxable in the State of residence, except employment carried out in the other State; exception of 183 days in twelve consecutive months under three conditions (Article 14).
• French buildings. Income and gains derived from buildings located in France remain taxable in France (Articles 6 and 12 § 1). The same applies to shares in companies whose assets consist primarily of real estate, under the conditions of Article 12 § 2.
• Other gains. Gains on all other assets are taxable only in the State of residence of the transferor (Article 12 § 5).

The administrative list of conventions does not include any inheritance or gift agreements with Vietnam. This page does not explain how inheritance matters are settled between the two countries.

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

Situation. A fictitious executive, domiciled in France for over ten years, holds securities worth €3,100,000, with an unrealized capital gain of €1,250,000. He transfers his domicile to Vietnam on September 15, 2027.

Issue. It meets the conditions for exit tax. According to our reading of the list in the notice, Vietnam is not included: without a request for deferral, the tax is payable on the date of the transfer.

Strategy. He appoints a tax representative and offers guarantees to the Non-Resident Tax Office (SIP) before departure, respecting the 90-day deadline. He has this deadline confirmed, as the notice itself uses two different wordings.

Result. June 17, 2027, is the date 90 days before September 15, 2027: the wording of section V of the notice ("no later than 90 days before the transfer") makes it the deadline, while that of section III.B ("within ninety days preceding the transfer") reads differently, hence the confirmation of the deadline. At the rate of 12.8% (%) that the notice generally indicates, the collateral on €1,250,000 amounts to €160,000. Its securities exceed €2,570,000: the tax relief period is 5 years, i.e., until September 15, 2032. Form 2074-ETD is filed a second time in 2028, along with Forms 2042 and 2042 C. The calculation does not quantify the tax due, which depends on the rates in effect on the date of the transfer.

What changes depending on your situation

• Your status: executive with titles, seconded employee, retired or inactive.
• The value of your securities, their ownership and any potential contribution-sale.
• Your ties to France: housing, family, work, investments.
• The nature of your pensions: private or public.
• Your intended length of stay and the permit it requires.

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