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.
Dubai changes the risk profile
Dubai is attractive for entrepreneurs and investors, but leaving France for the UAE does not by itself eliminate French exit tax. The French departure analysis remains anchored in article 167 bis, the asset perimeter and the taxpayer’s prior French residence.
France-UAE tax treaty
The France-UAE treaty is relevant for residence and allocation of taxing rights, but it does not replace the domestic exit tax analysis. Both layers must be reviewed together.
Payment deferral and guarantees
For transfers outside the EU/EEA, the deferral position must be reviewed carefully. The availability of automatic deferral or guarantees depends on the legal framework and administrative conditions applicable at the time of departure.
Substance in the UAE
A Dubai relocation must be real: home, family, work, bank accounts, visa, Emirates ID, lease, economic activity and day-count evidence matter. The aim is not cosmetic residence but a defensible tax residence file.
Founder planning
For founders moving to Dubai, the file should be prepared before the move: cap table, valuation, holding company, sale timetable, expected liquidity event and French forms.
A France-to-Dubai move has two separate tax workstreams
The French workstream determines the effective end of French tax residence, the Article 167 bis position, any payment-deferral application and continuing French-source obligations. The UAE workstream addresses immigration, UAE tax residence, tax-residence certificates and any UAE business or Corporate Tax position. A UAE visa, Emirates ID or company is not by itself proof that French residence has ended, and a French exit-tax filing does not establish UAE treaty residence.
The France-UAE treaty becomes relevant where its residence and income provisions apply to the documented facts. Before relying on it, identify the permanent homes, family location, habitual life, business management and economic interests in both States. For an entrepreneur who continues to run a French company, board practice, decision-making location and the role actually performed after departure deserve specific evidence.
Payment deferral and pre-departure timing
Under the French framework described in the corresponding French analysis, a transfer to the UAE generally requires the optional payment-deferral route rather than treating the deferral as automatic. That conclusion, the required security and the French tax-representative position must be verified under the law and administrative guidance in force at the actual transfer date. The application can have a pre-departure timetable, so the file should not wait until the following annual tax-return season.
Documents for the combined file
- a French residence memorandum and a dated record of the physical move;
- UAE immigration, accommodation and tax-residence evidence for the same period;
- the ownership chart, acquisition cost and valuation of in-scope shares;
- details of planned sales, distributions, option exercises or reorganisations;
- the 2074-ETD computation, representative mandate and proposed guarantee where required;
- a treaty matrix for French-source income and any later disposal;
- separate engagement and data records identifying whether the Paris SELAS or the legally distinct Dubai entity is acting on each workstream.
Common analytical errors
The absence of a general UAE personal income tax should not be stated as the disappearance of French tax. French exit tax is assessed under French law, and France may retain taxing rights over French-source income. UAE Corporate Tax can also be relevant to a natural person conducting a business or to a company, while private investment income may be treated differently. Each receipt and activity needs classification; slogans such as “zero tax” are not a legal analysis.
Start with the BOFiP payment-deferral guidance, the administration's France-UAE treaty guidance and the current Article 167 bis CGI. For the treaty context, see the firm's France-UAE treaty analysis. The applicable contracting entity, fees and responsibilities must be stated in the engagement letter; this page does not merge the Paris SELAS with GEOTAX.