This English page mirrors the French reference page for international clients. It is written for decision-makers who need a clear first reading before a tailored French tax analysis.
Reference guide
This page organises the English exit tax cluster. For the main legal analysis, see the core English page on French exit tax.
Key resources
French exit tax calculation in 2026
How French exit tax is calculated: latent capital gains, market value, tax basis, rates, payment deferral and documentation.
French exit tax case studies
Practical French exit tax case studies: founders, holding companies, gifts, Dubai relocation and return to France.
Crypto-assets and French exit tax
French exit tax and crypto-assets: scope, private wallets, companies, tokenised securities and residence transfer issues.
French exit tax filing and follow-up forms
French exit tax forms: 2074-ETD, annual monitoring, payment deferral, supporting documents and deadlines.
French exit tax relief and cancellation
French exit tax relief after departure: holding period, return to France, sale events and claim procedure.
French exit tax and relocation to Dubai
French exit tax and Dubai: UAE relocation, France-UAE tax treaty, payment deferral, residence and founder planning.
Lawful French exit tax planning
Lawful planning before leaving France: gifts, holding companies, timing, valuation and anti-abuse review.
French exit tax FAQ
French exit tax FAQ: scope, thresholds, calculation, forms, deferral, relief, Dubai, Switzerland, UK and audit risk.
French exit tax glossary
Glossary of French exit tax terms: article 167 bis, payment deferral, latent gain, relief, tax residence and guarantees.
Holding companies and French exit tax
French exit tax and holding companies: contribution-deferral, article 150-0 B ter, reinvestment and founder planning.
Key French exit tax case law
French exit tax case law: constitutional framework, EU law, payment deferral, residence and anti-abuse issues.
French exit tax and relocation to Panama
French exit tax and Panama: tax treaty, residence, payment deferral, ETNC review and expatriation planning.
Risk of French tax residence challenge
French tax residence challenge after expatriation: article 4 B CGI, treaty tie-breaker, evidence and audit strategy.
French exit tax and relocation to Switzerland
French exit tax and Switzerland: treaty, payment deferral, private capital gains and cross-border residence.
French exit tax payment deferral
French exit tax payment deferral: automatic deferral, optional deferral, guarantees, monitoring and end of deferral.
French exit tax and relocation to the United Kingdom
French exit tax and the UK: post-Brexit relocation, France-UK treaty, payment deferral and founder planning.
A practical framework before leaving France
French exit tax is assessed when an individual transfers tax residence outside France while holding interests that fall within Article 167 bis of the French Tax Code. It is not a general tax on every asset owned by an expatriate. The analysis starts with the taxpayer's residence history and the nature and value of the relevant shares, securities, earn-out receivables or gains already placed under a tax deferral. Only after that scope review should the adviser quantify the latent gain and consider payment deferral.
The transfer date matters because it fixes the facts to document: ownership, acquisition cost, market value and the country of destination. A residence permit, lease or foreign tax certificate does not by itself settle French tax residence. French domestic criteria must be examined first and, where two States may treat the person as resident, the applicable treaty must then be applied to the documented facts.
Four questions that organise an exit-tax file
- Is the individual within the personal scope? Review the statutory residence-history condition and the alternative ownership or value thresholds in the version of Article 167 bis applicable on the transfer date.
- Which assets are within the statutory base? Distinguish direct securities, rights in companies, earn-out receivables and gains already under deferral from assets governed by another tax regime.
- Is payment immediate, automatically deferred or deferred on application? The answer depends on the destination and the legal-assistance and recovery framework in force at the relevant date. An optional deferral can involve a timely filing, a French tax representative and sufficient security.
- What must be monitored afterwards? A sale, redemption, cancellation, donation, return to France or failure to make a required follow-up filing may affect the deferred charge or the availability of relief.
Evidence to assemble before the move
A reliable working file normally contains the ownership chart, acquisition documents, shareholder agreements, previous deferral statements, valuation materials, the planned transaction calendar and evidence of the effective move. For unquoted companies, a single headline valuation is rarely enough: the assumptions, reference transactions, accounts, debt, cash and any minority or liquidity considerations should be recorded. This evidence is useful both for the initial return and for any later discussion with the French tax authorities.
Read the current text of Article 167 bis on Legifrance, the tax administration's BOFiP overview of the regime and the official Form 2074-ETD page. These sources must be checked again for the year of departure: thresholds, forms and procedural conditions can change.