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 initial filing
The French exit tax filing is not a simple annex. Form 2074-ETD identifies the taxpayer, the date of transfer, the relevant assets, the tax basis, the valuation and the payment deferral position.
Payment deferral request
Depending on the destination country, the deferral may be automatic or require a specific request and guarantees. The filing must therefore be consistent with the country of relocation and the expected future sale strategy.
Annual monitoring
A taxpayer benefiting from a payment deferral may have follow-up obligations. These forms preserve the deferral and allow the French tax authorities to monitor sale, gift, redemption or return events.
Supporting documents
The filing file should include valuation evidence, share registers, cap tables, acquisition documents, contribution deeds, gift deeds and tax residence evidence.
Errors to avoid
The most frequent errors are late filing, incomplete valuation, confusion between latent gains and deferred gains, and assuming that a move to a low-tax country automatically removes the French tax exposure.
An operational filing workflow
Form 2074-ETD is the starting return for an exit-tax position, not a substitute for the underlying computation. Before completing it, build a schedule by asset or deferred gain showing ownership, acquisition date, tax basis, transfer-date market value, latent gain and the payment-deferral route considered. The figures should reconcile with supporting documents and with the relevant boxes in the income-tax return for the departure year.
Step 1: confirm the legal scope and destination
Record the residence-transfer date and the statutory version applied. Test the residence-history condition, the ownership or value thresholds and the nature of each asset. Then identify whether payment is immediate, automatically deferred or deferred only on an application. For an optional deferral, the filing date, appointment of a tax representative and security package may have to be completed before the transfer; a normal annual income-tax deadline should not be assumed.
Step 2: create an audit-ready evidence pack
- share registers, acquisition deeds, gift or inheritance documents and shareholder agreements;
- listed-market price records or a reasoned valuation report for unquoted interests;
- details of earn-out rights and gains already under Articles 150-0 B ter or other deferral provisions;
- departure and destination evidence relevant to tax residence;
- the representative mandate, guarantee documents and correspondence with the tax authorities where applicable;
- a signed reconciliation between the calculation schedule, 2074-ETD and the income-tax return.
Step 3: calendar later events
Follow-up duties depend on the departure date, the component of the assessment and later legislative changes. A taxpayer should not assume that every historic transfer uses the newest form or that the absence of a sale removes all monitoring. Sales, redemptions, cancellations, gifts, returns to France, changes in guarantee and the expiry of a relief period should trigger a review. Keep proof of submission and any acknowledgement, not only an unsigned PDF.
Correcting an omission
If an original or follow-up return was late, incomplete or inconsistent, first reconstruct the correct position and preserve the chronology. The appropriate correction depends on the year, whether tax became payable, whether the authorities have opened an enquiry and whether a payment-deferral condition was affected. This page makes no promise that a late filing will be accepted without interest, penalties or loss of deferral.
Use the official 2074-ETD page, the 2074-ETS follow-up page and BOFiP procedural guidance. Download the form and instructions for the relevant year rather than reusing a prior-year template.
Final filing control
Before submission, a second reviewer should check names, tax numbers, transfer date, destination, share quantities, basis, valuation and the deferral route against the evidence pack. Confirm that every annex referenced in the return is included and legible. Keep the exact filed version, transmission receipt and later correspondence in one dated folder. If figures are provisional, state why and how they will be corrected. A technically accurate calculation can still fail operationally if it is attached to the wrong form year, filed at the wrong office or submitted after a special pre-departure deadline.