{"id":6791,"date":"2026-10-21T07:00:20","date_gmt":"2026-10-21T05:00:20","guid":{"rendered":"https:\/\/balmontconseil.com\/blog\/exit-tax-plus-de-300-000-e-dimpot-sur-1-me-de-plus-value-latente-et-comment-le-neutraliser\/"},"modified":"2026-10-21T07:00:20","modified_gmt":"2026-10-21T05:00:20","slug":"exit-tax-plus-de-300-000-e-dimpot-sur-1-me-de-plus-value-latente-et-comment-le-neutraliser","status":"publish","type":"post","link":"https:\/\/balmontconseil.com\/en\/blog\/exit-tax-plus-de-300-000-e-dimpot-sur-1-me-de-plus-value-latente-et-comment-le-neutraliser\/","title":{"rendered":"Exit tax: over \u20ac300,000 in tax on \u20ac1 million of unrealized capital gains, and how to neutralize it"},"content":{"rendered":"
\n

In summary\u2026<\/h2>\n

Leaving France with a securities portfolio triggers the exit tax. Article 167 bis of the French General Tax Code (CGI) taxes your unrealized capital gains on the day of departure, as if you had sold them. On \u20ac1 million of capital gains, the tax bill exceeds \u20ac300,000. With proper preparation, the departure can be completed without any outlay, and the tax is eliminated after two years if the securities are retained.<\/p>\n<\/div>\n

1. Who is covered by Article 167 bis<\/strong><\/h2>\n

The exit tax applies to taxpayers who transfer their tax residence outside of France after having been a resident there for at least 6 years during the last 10 years. It targets shareholdings whose total value reaches \u20ac800,000, or which represent at least 50% of a company.<\/p>\n

The tax base is the difference between the value of the securities on the date of departure and their cost basis. No sale, no cash receipt: the capital gain is taxed on paper. Its amount is recorded at the outset, then tracked annually on form 2074-ETD.<\/p>\n

2. Automatic stay of execution or stay of execution upon request: the destination decides<\/strong><\/h2>\n

For payments to a member state of the European Union, the European Economic Area, or a state bound to France by an administrative assistance agreement and a tax recovery assistance agreement, the deferral of payment is automatic. The tax is calculated and declared, but not paid.<\/p>\n

When moving to another country, a stay of execution is requested and requires the provision of guarantees. The exit tax then becomes a matter of cash flow before it is a matter of taxation.<\/p>\n

The tax relief begins after two years if the securities are still held. This period is extended to five years when the value of the securities exceeds \u20ac2.57 million. The 2026 Finance Act did not modify this provision.<\/p>\n

3. Concrete example<\/strong><\/h2>\n

Situation.<\/strong> A 52-year-old executive, a lifelong French resident, owns 100 % shares in a company valued at \u20ac1.2 million, for a purchase price of \u20ac200,000. He moves to Lisbon.<\/p>\n

Issue.<\/strong> Upon relocation, Article 167 bis recognizes \u20ac1 million in unrealized capital gains. Without a deferral, over \u20ac300,000 in taxes would be due, without any cash receipts.<\/p>\n

Strategy.<\/strong> Departure to Portugal, an EU member state: automatic deferral. With \u20ac1.2 million in securities, below the \u20ac2.57 million threshold, the tax relief period is 2 years. The securities are retained and form 2074-ETD is filed annually.<\/p>\n

Result.<\/strong> \u20ac0 initially paid out. After 2 years of ownership, over \u20ac300,000 in tax relief.<\/p>\n

4. The three errors that make the tax payable<\/strong><\/h2>\n

Selling the securities during the deferral period: the sale ends the deferral and the tax becomes due, even though the tax relief was within reach.<\/p>\n

Neglecting the 2074-ETD tax return: it must be filed annually for as long as the deferral period is in effect. Failure to do so makes the tax payable unless rectified within 30 days of a formal notice.<\/p>\n

Leaving without having checked the deferment regime of the host country: when guarantees are required, they are established before the transfer of residence, not once settled.<\/p>\n

5. Things to take care of before departure<\/strong><\/h2>\n

Value the securities on the transfer date and document this value. Decide on the allocation of assets in light of the deferral regime. Establish the schedule for sales, gifts, or restructurings in relation to the 2- or 5-year period. These decisions must be made before the departure date: once the residence is transferred, the capital gain is fixed in the tax return.<\/p>\n

Frequently asked questions<\/strong><\/h2>\n

Does the exit tax apply when leaving the European Union?<\/strong><\/h3>\n

Yes, the tax is calculated. But its payment benefits from an automatic deferral, and it is refunded after 2 years, 5 years beyond \u20ac2.57 million of securities, if the securities are kept.<\/p>\n

What is the exit tax threshold?<\/strong><\/h3>\n

\u20ac800,000 in total value of securities, or a stake of at least 50 % in a company, for a taxpayer who has been a French tax resident for at least 6 years out of the last 10 years.<\/p>\n

What happens if I sell my shares after I leave?<\/strong><\/h3>\n

A sale during the deferral period makes the tax payable. The sale schedule is based on the 2 or 5-year period and is decided before departure.<\/p>\n

Are you planning to leave with a securities portfolio? Book a wealth management consultation: we'll calculate the exit tax and set the schedule before your move.<\/strong><\/p>","protected":false},"excerpt":{"rendered":"

En r\u00e9sum\u00e9… Quitter la France avec un portefeuille de titres d\u00e9clenche l'exit tax. L'article 167 bis du CGI impose vos plus-values latentes le jour du d\u00e9part, comme si vous aviez vendu. Sur [\u2026]<\/span><\/p>\n","protected":false},"author":5,"featured_media":6790,"comment_status":"","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[9],"tags":[],"class_list":["post-6791","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-patrimoine"],"acf":[],"jetpack_featured_media_url":"https:\/\/balmontconseil.com\/wp-content\/uploads\/2026\/10\/exit-tax-plus-de-300-000-d-imp-t-sur-1-m-de-plus-value-laten.webp","_links":{"self":[{"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/posts\/6791","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/users\/5"}],"replies":[{"embeddable":true,"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/comments?post=6791"}],"version-history":[{"count":0,"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/posts\/6791\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/media\/6790"}],"wp:attachment":[{"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/media?parent=6791"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/categories?post=6791"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/balmontconseil.com\/en\/wp-json\/wp\/v2\/tags?post=6791"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}