French exit tax is a sequence, not a single calculation: determine scope, establish the departure-date value, identify the payment-deferral route, file the correct departure-year forms and monitor later events affecting the deferred tax.
Exit-tax decision path
Begin with the taxpayer’s French residence history and the legally relevant transfer date. Then create a household-level inventory of direct and indirect securities, acquisition history, reorganisations, tax basis, earn-out receivables and gains already under a French deferral. Article 167 bis does not treat every category identically, so a conclusion on latent share gains should not automatically be extended to an earn-out or a previously deferred gain.
Next, establish value at the departure date. Listed prices may be observable; private-company shares require a reasoned valuation file that reconciles accounts, debt, cash, shareholder rights, recent transactions and realistic forecasts. Preserve negotiations and contemporaneous documents: a later sale or financing round may be compared with the value reported on departure.
Payment is a separate stage. The destination and the statutory assistance-and-recovery conditions applicable at the time determine the deferral route. After departure, sales, redemptions, contributions, donations, earn-out payments, changes of residence and a return to France can require further analysis or reporting. The file therefore needs an event log and named responsibility for follow-up.
Official starting points: consult the current article 167 bis CGI and select the millésime matching the actual transfer on the official 2074-ETD page. A current web page or article title should never be used as a substitute for the form and notice applicable to the departure year.
Articles in this category
Resources on French exit tax for founders, executives, investors and families leaving France.
Exit Tax 2026: Complete Guide to Article 167 bis
Use this overview to identify scope, valuation, deferral and follow-up questions before opening the specialised pages.
Exit Tax Payment Deferral: Conditions and Procedure
Focus on the destination-specific payment route, procedure, representation and guarantee issues.
Exit Tax Relief After 2 or 5 Years of Continuous Holding
Review the relief timeline separately from the initial scope thresholds and the events ending a deferral.
Business Sale and Expatriation: Tax Optimization
Map a contemplated sale against the departure date, valuation evidence and any existing tax deferral.
Tax Expatriation Checklist: 12 Essential Steps Before Leaving France
Use the checklist to organise facts and documents, not as a substitute for applying article 167 bis to the file.
How to use these resources
Read the pages in procedural order: scope and residence, calculation and valuation, deferral, declaration, then later-event relief or payment. They do not replace a review of the taxpayer’s ownership chain, departure year, destination, official forms and contemplated transactions.
Book a consultation
For a live matter, the first step is usually a video consultation or an office consultation to identify the issue, the deadlines and the supporting documents required.