France is famously generous with paperwork and famously attached to its taxpayers. Leaving isn’t a form you file at the town hall – there’s no deregistration system – it’s a set of facts the tax office checks against article 4 B of the tax code. Miss one of three tests and you’re still French for tax, whatever your new address says.
This guide covers how French tax residency ends, how the exit tax works, what stays taxable after the move and a practical 12-month plan. It’s general information as of September 2026, not tax advice.
Who this guide is for#
Anyone living in France and moving abroad for good: employees, freelancers, founders with an SAS, retirees and expats moving on. It matters most if you hold a sizeable share portfolio, own a French company or keep French property. Leaving Germany instead? Read leaving Germany: similar ambitions, different traps.
How French tax residency ends#
Under article 4 B of the Code général des impôts (CGI) you have your tax domicile in France if you meet at least one of these tests:
- Foyer or lieu de séjour principal. Your household (usually where your spouse or partner and children live) is in France, or – if that’s unclear – France is where you spend most of your time.
- Professional activity. You work in France, employed or self-employed, unless that work is only incidental.
- Centre of economic interests. Your main investments, the seat of your business or most of your income are in France.
Nationality plays no role, and there’s no fixed day count in French law. The “séjour principal” test is relative: more time in France than in any other single country is enough. The law also presumes that executives of companies headquartered in France with more than €250 million in turnover carry on their main professional activity in France, unless they prove otherwise.
The family trap#
The foyer test is where most exits wobble. If your partner and children stay in Lyon while you set up in Lisbon, your household is still in France – and so is your tax domicile under French law. A treaty may still rescue you (see below), but that’s an argument, not a given.
No deregistration, just evidence#
France has no population register like Germany or Italy. There’s nothing to “sign out” of. Instead you build a paper trail: end the lease or sell, change your address with the tax office, move your family and your working life, register abroad and collect proof. French residents abroad can also register with their consulate (Registre des Français établis hors de France) – useful for consular services, but not a tax test either.
Two residencies: the treaty tie-breaker#
If France and your new country both claim you, the double tax treaty decides: permanent home, centre of vital interests, habitual abode, nationality. Since February 2025, article 4 B says it outright: someone who counts as non-resident under a treaty is not domiciled in France for tax. France has treaties with most popular destinations, including Portugal, Cyprus, Malta, Switzerland and the UAE. How residency tests work elsewhere: tax residency explained.
One destination is special: French nationals who move to Monaco generally remain taxable in France as if they lived there, under the 1963 France–Monaco tax convention. The Riviera is lovely; it’s just not an exit.
Exit tax: the art. 167 bis farewell bill#
France taxes latent gains on company shares when you move your tax domicile abroad. As of September 2026, the rules of article 167 bis CGI are:
| Question | Rule |
|---|---|
| Who | Taxpayers domiciled in France for at least six of the ten years before leaving |
| Which holdings | Shares and company rights where you (with your household) hold at least 50% of a company’s profits, or where the total value of all such holdings exceeds €800,000 |
| What’s taxed | Unrealized gains on the day you transfer your tax domicile, plus earn-out receivables and gains previously placed in deferral (report d’imposition) |
| Rate | 12.8% flat income tax plus social levies (18.6% on most capital income in 2026 under the 2026 social security financing law) |
| Automatic deferral | Moving to an EU state, or to a state with administrative assistance and recovery treaties comparable to EU standards that isn’t on France’s non-cooperative list |
| Deferral on request | Anywhere else: appoint a tax representative and post a guarantee of 12.8% of the gains before leaving |
| Cancellation | If you still hold the shares after two years – or five years if they were worth more than €2.57 million on departure – the tax on latent gains is cancelled |
The €800,000 threshold counts the total of your relevant holdings, not each one. A diversified €900,000 share portfolio is in scope even if no single position is big.
The 2026 finance law, adopted in February 2026, left art. 167 bis unchanged. A parliamentary amendment to bring back a 15-year holding period didn’t make it into the final text.
Paperwork: the 2074-ETD#
You declare the exit tax on form 2074-ETD with the return for the year you leave. While the deferral runs, you report annually on the follow-up form and tell the tax office about sales, gifts or other events. Sell within the window and the deferred tax becomes due, with a credit for tax paid abroad on the same gain.
Company owners#
Your SAS doesn’t leave with you. If you keep running it from abroad, check where it’s effectively managed, and don’t expect a French-seated company to become foreign just because its founder did. See place of management. The exit tax is a personal tax on your shares; the company itself is taxed separately.
What stays taxable in France#
Once you’re non-resident, France taxes only French-source income. The main items as of September 2026:
- Minimum rates. Non-residents pay tax on the progressive scale, but at least 20% on net taxable income up to €29,579 (2025 income) and 30% above. If your worldwide average rate would be lower, you can ask for that rate by declaring your worldwide income.
- Salaries and pensions. French employers and pension funds withhold a specific retenue à la source under article 182 A: 0% up to €17,275, 12% up to €50,112 and 20% above (2026 annual brackets). The 0% and 12% slices are final; the 20% slice is credited against your tax. Treaties often shift private pensions to your new country.
- Dividends. French companies withhold 12.8% on dividends paid to non-resident individuals (75% if paid into a non-cooperative state). Your treaty may cap it further.
- Property income. Rent from French property stays taxable in France and you file a return.
- Property gains. Gains on French real estate are taxed at 19% (article 244 bis A), plus social levies.
- Social levies on property income. As of 2026, French rental income and property gains carry 17.2% (CSG 9.2%, CRDS 0.5%, solidarity levy 7.5%). If you’re covered by the social security system of another EU/EEA state, Switzerland or the UK, you pay only the 7.5% solidarity levy.
- IFI. The real-estate wealth tax applies to non-residents on French property with a net value above €1.3 million.
Local taxes on French property – taxe foncière and, for second homes, taxe d’habitation – keep coming from the local tax office.
The departure-year return#
You file one return for the year you leave: form 2042 for all income from 1 January to the departure date, plus form 2042-NR for French-source income from the departure date to 31 December. Confirm your new foreign address in it. From the following year, the Service des impôts des particuliers non-résidents (SIPNR) manages your file if you still have French-source income.
Social security and health insurance#
- CPAM and the carte Vitale. Moving abroad for work usually means leaving the French system and joining your new country’s. Tell your CPAM about the move and return the carte Vitale if you’re no longer entitled to it. Posted workers keep French cover (with an A1 form) for up to 24 months.
- Inside the EU/EEA and Switzerland, Regulation 883/2004 decides which country insures you – usually the one where you work. French pensioners moving within the EU get an S1 form from their pension fund and stay entitled to care in France.
- The other CFE. The Caisse des Français de l’étranger offers voluntary French-style cover for people living abroad. (Not to be confused with the cotisation foncière des entreprises, the business property tax – French administrative acronyms enjoy a good double life.)
- Pension. Your French quarters stay on your record. EU/EEA and treaty periods are combined when you retire.
If you’re self-employed, close your business through the one-stop shop (guichet unique). The business CFE is due for the year in which you’re still active on 1 January.
Banks, brokers and accounts#
- French accounts can usually stay open. Update your address and tax residency. Under the Common Reporting Standard (CRS), the bank then reports to your new country. Paying French taxes online needs an account in France or the SEPA area.
- PEA. Moving abroad doesn’t close your PEA, unless you move to a non-cooperative state. Check how your new country taxes it.
- LEP. The Livret d’épargne populaire requires French tax domicile, so it has to go.
- Some banks and brokers restrict non-residents, especially outside the EU. Ask before you move, not after. More: offshore banking.
Your exit, step by step
Run the three 4 B tests on yourself
Home and family, work, economic interests: after the move, none of them should point to France. Where one still does, you need the treaty tie-breaker to work.
Value your shareholdings
Add up every share and company interest. Above €800,000 in total, or 50% of a company’s profits, you’re in the exit tax.
Pick the destination with the deferral in mind
EU or a state with the right assistance treaties means automatic deferral. Elsewhere, budget for a guarantee. Compare destinations with our Jurisdiction Finder.
Move your life, not just your mail
End the lease or sell, move family and work, register abroad and get a local tax number.
File the departure-year return
Form 2042 up to departure, 2042-NR after it, 2074-ETD for the exit tax. Then keep the follow-ups coming while the deferral runs.
Traps we see all the time
Family stays behind.
Your foyer is still in France. French law says resident; only the treaty can say otherwise.
The €800,000 sum.
The threshold adds up all your holdings. Ten modest positions can add up to one big exit tax.
Selling in month 23.
The deferred tax becomes due. Wait out two years (or five) if you can.
Monaco.
French nationals generally stay taxable in France under the 1963 convention.
A French board seat.
Running the company from Paris keeps your professional activity – and maybe the company’s management – in France.
Forgetting SIPNR.
French rent, dividends and IFI don’t stop because you left. File every year.
Worked example: a founder moves to Portugal#
Illustrative numbers only. Claire has been resident in France for twelve years and owns 60% of her SAS. The shares are worth €2 million and cost her €100,000. She moves to Lisbon on 1 June 2026, with her family, and keeps the shares.
| Claire moves to Portugal | Claire moves to a state without the required assistance treaties | |
|---|---|---|
| Latent gain | €1,900,000 | €1,900,000 |
| Income tax at 12.8% | €243,200 | €243,200 |
| Social levies at 18.6% | €353,400 | €353,400 |
| Exit tax assessed | €596,600 | €596,600 |
| Deferral | Automatic | Only on request, with a tax representative and a guarantee |
| If she keeps the shares until June 2028 | Tax cancelled (value under €2.57 million) | Tax cancelled too – but the guarantee was tied up until then |
The bill looks scary on paper and can end at zero. It only bites if Claire sells within two years – or keeps her family in Lyon, in which case France may not accept that she left at all. (High-income surcharges are left out for simplicity.) Want to compare the ongoing tax side in the new country? Try our tax calculator.
Leaving France: from 12 months to day zero
Tick them off – your progress is saved in this browser only.
List shareholdings with cost and value, French property, pensions and future income. Check whether the €800,000 or 50% test applies.
Compare tax, residency rules and life in the country guides. Check the treaty with France and whether the deferral is automatic.
Decide who runs your French company after the move, and from where. Look at company formation if you want a new structure abroad.
Plan the family’s move and the school year. Decide whether to sell, let long-term or give notice on your home.
Apply for your residence permit, secure a long-term lease and open a local bank account.
Arrange local or international health cover, look at the Caisse des Français de l’étranger and ask for an S1 if you’re a pensioner moving within the EU.
Tell banks and brokers about the move, close the LEP, check what happens to your PEA and life insurance.
Report your new address in your online tax account, tell the CPAM, close or transfer your business, and register with the consulate if you like.
Register with your new tax authority and request a certificate of tax residence for banks and treaty relief.
File 2042, 2042-NR and, if relevant, 2074-ETD. From then on, SIPNR is your tax office for French income.
FAQ#
Does leaving France end my tax residency automatically?
No. France has no deregistration. You stop being resident when none of the three article 4 B tests points to France – or when a treaty makes you resident elsewhere.
My family stays in France for a year. Am I still resident?
Under French law, probably yes: your foyer is in France. Whether the treaty tie-breaker gives residency to your new country depends on your home, your centre of vital interests and where you actually live.
Does the exit tax apply to my ETF portfolio?
It applies to shares and company rights once your holdings exceed €800,000 in total or you hold 50% of a company’s profits. Check with an adviser how your specific funds are classified before you rely on either answer.
Can I avoid paying the exit tax entirely?
Legally, often yes. With automatic deferral (EU or qualifying treaty states), keep the shares for two years, or five above €2.57 million, and the latent-gain tax is cancelled. Deferred gains from earlier reorganisations follow their own rules.
Do I still pay French tax on my rented apartment in Paris?
Yes. French rent and French property gains stay taxable in France, with minimum rates for non-residents and social levies – 7.5% only if you’re insured in another EU/EEA state, Switzerland or the UK.
The fine print#
Everything here is general information, not tax or legal advice. France gives you three ways to stay resident and one bill for leaving; getting both right at once is where a second pair of eyes pays off. Want your exit plan checked before you go? Book a strategy session.
Sources#
- Article 4 B CGI – tax domicile (Légifrance)
- Article 167 bis CGI – exit tax (Légifrance)
- Article 182 A CGI – withholding on salaries and pensions of non-residents (Légifrance)
- BOFiP – 2026 withholding brackets for non-residents (BOI-BAREME-000043)
- BOFiP – withholding on dividends paid to non-residents
- BOFiP – tax on property gains of non-residents (art. 244 bis A)
- BOFiP – France–Monaco tax convention
- impots.gouv.fr – how tax is calculated for non-residents
- impots.gouv.fr – understanding non-resident withholding
- impots.gouv.fr – declaring income in the year of departure
- impots.gouv.fr – formalities when moving abroad
- impots.gouv.fr – form 2042-NR
- impots.gouv.fr – form 2074-ETD (exit tax)
- impots.gouv.fr – social levies for non-residents
- impots.gouv.fr – non-residents with French property (incl. IFI)
- impots.gouv.fr – keeping a PEA after moving abroad
- Service-Public – social levies on investment income (2026 rates)
- Service-Public – health insurance for French citizens living abroad
- Service-Public – popular savings account (LEP)
- Regulation (EC) No 883/2004 – coordination of social security systems
