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.
The architecture of the calculation
French exit tax is not a departure tax on the individual as such. It is a mechanism that crystallises certain unrealised capital gains and deferred gains when a taxpayer transfers tax residence outside France. The calculation starts with the assets falling within article 167 bis of the French Tax Code, then determines the taxable basis, the applicable tax treatment and the availability of a payment deferral.
Valuing shares and securities
Listed securities generally require a market reference. Unlisted companies require a documented valuation based on coherent methods: comparable transactions, multiples, net asset value, discounted cash flows or a combined approach. The valuation file is often the decisive point in a later tax audit.
Latent capital gain and deferred gain
The latent gain is the difference between the market value at the date of departure and the tax acquisition price. Deferred gains under French regimes such as contribution-deferral mechanisms must be analysed separately because leaving France can bring them within the exit tax perimeter.
Rates, allowances and practical computation
The amount is not assessed mechanically. The taxpayer must analyse the nature of the gain, the applicable income tax treatment, social surtaxes, historical allowances and the interaction with the payment deferral. A robust computation is not only arithmetic: it is also a legal qualification exercise.
Evidence to keep
The taxpayer should keep the departure date analysis, the shareholding threshold analysis, the valuation report, corporate documents, past acquisition documents and the forms filed with the French tax authorities.