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.
Article 167 bis CGI
The central provision of the French Tax Code governing exit tax on certain unrealised gains and deferred gains when a taxpayer transfers tax residence outside France.
Latent capital gain
The unrealised gain existing at the date of departure, generally computed as market value minus tax acquisition price.
Payment deferral
The mechanism by which assessed exit tax is not immediately collected, subject to statutory conditions and sometimes guarantees.
Relief
The later cancellation or reduction of exit tax when the taxpayer meets the holding-period or other statutory conditions.
Tax residence
The legal qualification determining whether and when the taxpayer has transferred residence outside France. It requires both domestic and treaty analysis when a convention applies.