Article 4 B of the French Tax Code

Leave.
We keep the evidence.

Your tax residence file, built before you leave — while the documents still exist — and kept up to date for as long as it may be requested from you.

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Residence · 2027
9/11

202520262027
HomeEvidenced
Principal stayEvidenced
Professional activityEvidenced
Centre of economic interestsDeclared
Permanent homeEvidenced
Centre of vital interestsEvidenced
Habitual abodeNot applicable
Generate my 2027 file

Tax residence file

Year 2027 · prepared on 12 January 2028
Departure: 14 January 2027 · Portugal

SEALED
SHA-256

01 · HomeEvidenced
02 · Principal stayEvidenced
03 · Professional activityEvidenced
04 · Centre of economic interestsDeclared
06 · Resident status (treaty)Evidenced
07 · Permanent homeEvidenced
09 · Habitual abodeNot applicable

9 evidenced · 1 declared · 1 pending3f9a…c21b

30 days
to respond to a request from the tax authorities. The deadline is not extended.
11
criteria examined, in order: domestic law first, then the tax treaty.
N−5
the depth of the logbook. A logbook that stops at N−2 does not cover the limitation period.
0
document reconstructed after the fact. What is missing is recorded as missing.

What is at stake

€1,068 set against your worldwide income.

If the tax authorities treat you as a French resident, it is not a fine: it is the basis of your taxation that changes, retroactively, for the years concerned.

The file

1 068 €

incl. VAT, once only. Then €39 incl. VAT per month to update it every year and keep it for as long as the tax authorities can request it.

  • OnceBuilt before departure, while the documents still exist.
  • DatedEach document bears the date it was uploaded, not the current date.
  • DocumentedSealed with a SHA-256 hash that any change alters.
set against

Being reclassified as a French tax resident

Your worldwide income

Taxed in France for the reassessed years (Article 4 A of the French Tax Code). Late-payment interest is added; penalties, for their part, require the tax authorities to establish intent.

  • 2.4% a yearlate-payment interest (0.20% per month), due automatically — nearly 10% over four years.
  • 40%penalty if a deliberate breach is established.
  • 80%in the case of fraudulent manoeuvres — the rarest scenario.

No file guarantees an outcome, and we promise none. What a complete file, dated and sealed by its hash, changes is what you are able to produce on the day the question is asked.

On the day of the request

The same question, in two situations.

“Prove that you were not tax-domiciled in France in 2027.” You have thirty days to respond.

Without a prepared file

You go looking for the documents.

×The 2027 lease has ended and the agency cannot find it.
×The bank no longer keeps statements online for more than five years.
×School certificates from that time were never requested.
×You write a declaratory response, with no supporting documents.
×The burden of proof remains on you, and the clock is ticking.

With the file

You respond with a document that is already dated.

✓The eleven criteria are completed, year by year.
✓Each document bears the date on which it was uploaded, in 2027.
✓What was missing is listed as missing: nothing is reconstructed after the fact.
✓The document's hash proves it has not been altered since.
✓The file will be delivered to you within five working days.

An illustrative example

Four years between departure and the question.

The time lag is the rule, not the exception. That is what makes it impossible to build the file when you need it.

January 2027
Departure for Lisbon. The file is compiled within the following month, using the documents from that time.
February 2028
Annual update. Two documents no longer cover the year: they are flagged, then replaced.
February 2029
Annual update. A tax treaty is amended: what affects you is explained to you.
May 2030
Request for clarification regarding the year 2027. The thirty-day period begins.
June 2030
Response sent with the 2027 file, dated 2027 and sealed. No document had to be tracked down.

What you use

Not a questionnaire. An instrument of proof.

One closed answer per criterion, the consequence stated before you answer, and the supporting document required named where you upload it. Nothing is guessed on your behalf.

Criteria · year 2027
Where is your home?
The place where your spouse and minor children reside.
Home in France (a qualifying household member lives there)
Home abroad
No home identified
What this implies: to be supported by a document for each qualifying household member — proof of occupancy in both names, residence visa, school certificate dated at the start of the school year.

Document required · 2027 school certificate Uploaded on 03/09/2027

What you receive
Your proof of address no longer covers 2028

The last document submitted is dated November 2027. To document the year 2028, a document dated 2028 is required. You can submit it from your account.

The France–Portugal tax treaty has been amended

The point that concerns you: the definition of a permanent home. Your file has been reviewed; none of your documents is called into question.

We flag what changes. We recommend no product, and an alert is never followed by a sales follow-up.

The substance

Eleven criteria, in the order in which they are examined.

First, domestic law: a single criterion is enough to make you a French resident. Only then the tax treaty, and only within its material scope.

Domestic law — Article 4 B

A single criterion is enough. None is a day count, none is weighted.

01

HomeWhere the household lives, and the document that proves it for each member.
02

Principal stayExamined if there is no home. A comparison between countries, not a threshold.
03

Professional activityTime per country, documented. A specific presumption for company directors.
04

Centre of economic interestsThe source of income, asset by asset — wealth that yields nothing proves nothing.
05

Government employeeThe specific case of Article 4 B, 2.

Tax treaty — Article 4

A cascade: you move down a rung only if the one above has not settled the question.

06

Resident status (§1)The preliminary step: are you a resident of the other State within the meaning of the treaty?
07

Permanent homeAssessed by actual use and costs, never by title alone.
08

Centre of vital interestsPersonal and economic ties. Where they diverge, the courts have followed personal ties.
09

Habitual abodeFrequency, duration, regularity. Still no six-month threshold.
10

NationalityThe rung at which a French national loses, if nothing has settled it before.
11

Mutual agreement procedureThe last resort between the two states.

“Fewer than 183 days”This rule does not exist in Article 4 B. The criteria are alternative: only one is sufficient. This is the mistake we see most often.
The criteria are annualEvidence gathered in 2027 proves nothing for 2030. Each year is documented in its own right.
Up to N−5The limitation period reaches well back beyond the year of departure. A logbook that stops at N−2 does not cover what may be requested of you.

The process

Four steps, no appointment required.

Everything is done from your client area. You can stop at any step and pick up later: what you have entered is saved.

01You create your accountFree, in two minutes. It is your space: your documents, your exchanges, in one place.
02You describe your situationThe process uses your personal information: nothing to re-enter. It prepares your engagement letter and the client onboarding document.
03You sign, then you payElectronic signature with the code received by SMS, then payment for the departure file: €1,068 incl. VAT, once only.
04Your Residence module opensThe eleven criteria, document uploads year by year, and your file, which can be generated at any time.

The price

Two lines, announced in advance.

The departure file is paid for once. The subscription keeps it accurate. There is no third line.

Founder price Founder places: {n} / 100 already taken · the price is guaranteed with no increase for as long as your subscription runs

Before departure

1 068 €incl. VAT · once only · of which €890 excl. VAT

Analysed, compiled and delivered with its documentary completeness status.

  • Documented tax residence study
  • Document file compiled item by item
  • French obligations to settle before departure
  • Departure day formalities
  • Insurability of your profile and destination country

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Then, every month

39 €incl. VAT / month · of which €32.50 excl. VAT · twelve-month commitment, i.e. €468.00 incl. VAT over the year

Your file stays up to date and available, without you having to think about it.

  • Storage of your documents for as long as they may be requested
  • Annual update of your file
  • Monitoring of tax treaties and tax doctrine
  • Alert when a document no longer covers the current year
  • A single point of contact, a single consent, export at any time

€59 incl. VAT / month (€49.17 excl. VAT), i.e. €708.00 incl. VAT over the year, from the 101st subscriber. Offered when your file is delivered, never before.

What is included

Everything listed above, at no extra cost.

Your file made available within five working days if the tax authorities request it, provided the necessary information is available and usable.

What is not

Your tax returns: we prepare the documents, we do not file them for you.

Legal advice and taxation in your host country.

Support in the event of a tax audit, charged per service, price stated in advance.

Prices include VAT at 20%. Account creation is free: it opens your client area and the subscription process. The Residence module opens upon payment of the departure file.

The limits of the service

What we do not do.

Saying it here saves you discovering it later. It is also what makes everything else credible.

We do not rule on your statusWe do not state anywhere that you are, or are no longer, a French resident. That determination belongs to the tax authorities and, in the event of disagreement, to the courts. We organise what makes it defensible.
We do not file on your behalfWe prepare the documents and the replies. Your tax returns remain your own.
We promise no outcomeNo file guarantees an outcome. A complete, dated and sealed file changes what you can put forward — that is all we claim.
We sell nothing off the back of an alertAn alert says what changes. It never recommends a product, and it is never followed by a sales follow-up.

Questions

What we are asked before subscribing.

Why do I have to pay before accessing the Residence module?

Because the module is the product, not a demo. The free account opens your client area and the subscription process: there you see the contents of the file, the price and the documents to sign before committing. The module itself opens upon payment of the departure file.

Will you tell me whether I am still a French tax resident?

No, and no serious professional will tell you in advance. We document each criterion of Article 4 B, then, where relevant, those of the applicable tax treaty. What you get is a file that holds up, not an opinion that commits no one.

I'm leaving in three weeks. Is it too late?

No. The file is built with the documents that exist on the date you upload them. What is missing is recorded as missing, with the required supporting document named. This is precisely the period when documents can still be retrieved.

I already left last year. Is it still useful?

Yes, as long as the years concerned are not time-barred. The logbook goes back to N−5: past years are documented with the documents still available, and what is missing is recorded as missing rather than reconstructed.

What if I cancel the subscription?

You can export all of your documents for ninety days after cancellation, with no need to give a reason. Your access to your account is not closed: what you have paid for remains viewable.

Can I withdraw from the contract?

Yes, within fourteen days of signing. If you ask us to start immediately, you expressly waive this period — the box is in the contract, and it is never ticked in advance.

The 2027 documents exist in 2027.

Creating your account costs nothing and commits you to nothing. You see the contents of the file, the price and the documents to sign before deciding.

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