Returning to France from Mauritius: clearance certificate, year of return, and Mauritian income

As soon as one of the criteria in Article 4 B of the French General Tax Code (CGI) is met in France, you are considered a tax resident there. Your dividends from Mauritian sources are then taxable in France on their gross amount, with a tax credit of 25% provided for by the 1980 tax treaty. Your Mauritian accounts and contracts must be declared annually using form 3916 or 3916-bis, and your real estate in Mauritius is subject to the French Wealth Tax (IFI). According to service-public.gouv.fr, a tax clearance certificate (quitus) must be requested from the tax authorities of your country of residence if required by the local authorities.

Leaving Mauritius: tax residency and clearance

According to the Mauritius Revenue Authority (MRA) website, Mauritian tax residency is determined by domicile in Mauritius, unless the permanent residence is outside Mauritius, by a presence of 183 days or more in the tax year, or 270 days or more in the two preceding tax years. Non-residents are taxed only on their net Mauritian-source income. To be certified as a resident for a tax year, a Tax Residence Certificate must be requested from the Director-General of the MRA.

For France, service-public.gouv.fr advises requesting a "tax clearance certificate" (or "statement of tax status") from the tax authorities of the country you are leaving, if required by local authorities. In Mauritius, the tax authority is the MRA. The information sheet also recommends notifying banks, insurance companies, and local organizations of your departure, and declaring any money transfers of €10,000 or more online to customs.

From what point onward are you considered a French tax resident?

The doctrine (BOI-IR-CHAMP-10) considers personal, professional, and economic criteria, and only one of these needs to be met. Principal residence in France is presumed if you spend more than six months there per year, although this is not an absolute requirement. If you have several jobs, the one that occupies the most time is considered. The center of economic interests is the location of your main investments, your business headquarters, or the administration of your assets.

During the year of return, the convention of 11 December 1980 resolves situations of dual residence (Article 4, paragraph 2). It considers the State of permanent home; if the home exists in both States, the State of closest personal and economic ties (center of vital interests); if this center cannot be determined or if there is no home in either State, the State of habitual residence; then nationality; and finally, the agreement of the competent authorities.

The year of return: address, 2043, 2042-NR and 2042

The steps detailed by the administration on June 25, 2026 are as follows.

• Update your address in your Public Finances space, under "My profile" then "My contact methods".
• If you have no French-source income during your stay, form 2043 allows you to update your withholding tax rate or set up advance payments. It must be sent, along with supporting documents, to the tax office.
• If you had income from French sources before returning, the 2042-NR will include that from the period preceding your arrival.
• Form 2042 includes "your French and foreign taxable income" from arrival to December 31, along with its annexes.

Regarding health insurance, service-public.gouv.fr distinguishes between two scenarios: if you remained registered with the CPAM (French Health Insurance Fund) and are unemployed upon your return, you retain your French rights after a 3-month period; otherwise, you must apply to activate your rights. France Travail requires a French address for registration.

Your Mauritian income as seen from France

According to Article 24, paragraph 2(d), tax credits cannot exceed the amount of French tax due on the income in question; according to paragraph (e), French tax is calculated at the rate applicable to the total taxable income under French law. Foreign capital income must be declared using form 2047, as explained on our page about... foreign capital income.

Accounts, contracts and assets in Mauritius: 3916 and IFI

Each year, you must attach form 3916 or 3916-bis to your tax return if you have held, opened, used, or closed foreign bank accounts or life insurance policies. The penalty is €1,500 per undeclared account. Form 3916-bis is explained in detail on our page about... information to gather.

For the purposes of the French Wealth Tax (IFI), tax residents are taxed on their real estate assets and rights located in France or abroad, whether held directly or indirectly. The threshold is a net taxable estate exceeding €1,300,000 as of January 1st. Real estate held in Mauritius, directly or indirectly, falls within the tax base of the resident under this domestic law, subject to the 1980 Convention. Article 23 of this convention, entitled "Wealth," taxes real estate in the state where it is located (paragraph 1); the application of the convention to the IFI is not established.

Exit tax: the return in form 2074-ETD

The instructions for form 2074-ETD address the re-establishment of tax residence in France ("return to France") as grounds for tax relief or a refund, subject to the conditions it sets forth, including holding the securities on the date of return. Relief after 2 years (total value less than €2.57 million) or 5 years (value greater than €2.57 million) requires retaining the securities: the tax authorities' information sheet excludes relief in the event of sale, redemption-cancellation, or liquidation of the company during the interim period, and the instructions list the sale, redemption, refund, and cancellation options. The revised instructions concern transfers in 2025 and are for guidance purposes only: the instructions for the year of return take precedence. Read the instructions before selling any securities.

Expatriate tax regime: who can benefit

The tax regime under Article 155 B applies to individuals who have not been tax residents of France for the five calendar years preceding their appointment to a French company, and who transfer their tax residence to France on that date. It runs until December 31st of the eighth calendar year following the appointment and ceases upon departure from the host company, with one exception within the same group, as detailed on the tax administration's website. It does not apply to individuals who relocate of their own volition or those already domiciled in France at the time of hiring. It includes an expatriation bonus, a flat-rate option of 30% of the taxable income, a 50% exemption on certain foreign-source income, and, for five years, a reduced wealth tax (IFI) on assets located in France. Returning from Mauritius is not sufficient: the tax administration's website specifies that the regime is contingent upon taking up a position in a French company.

Return with €900,000 in unrealized capital gains: a numerical example (fictitious profile)

Situation. A former executive, a fictitious profile, left France in 2026 for Mauritius with €1,800,000 worth of securities and an unrealized capital gain of €900,000. His exit tax is suspended. He plans to return to Lyon.

Issue. He wants to know the tax deferral and what the notice stipulates in case of return.

Strategy. Before returning home, he rereads the 2074-ETD notice, keeps his securities and prepares his first tax return in France.

Result. Before any allowances or other potential adjustments, the deferred tax amounts to €282,600: €115,200 in income tax (12.8 times %) and €167,400 in social security contributions (18.6 times %), representing 31.4 times % of the unrealized capital gain. The return of the tax is a case of tax relief or refund provided for in the tax notice, subject to the conditions it sets forth. Since the securities are worth less than €2.57 million, the tax relief period is two years, provided they are held.

What changes depending on your situation

• The date on which one of the criteria in Article 4 B of the CGI is met.
• The nature of your Mauritian income: dividends, interest, royalties, pensions.
• Your accounts, contracts and companies in Mauritius, and the value of your real estate as of January 1st.
• Preserving your securities if an exit tax is involved.
• Your situation with regard to health insurance.

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