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.
A holding company is not a magic shield
Interposing a holding company can be efficient for governance, reinvestment and transmission, but it does not automatically neutralise French exit tax.
Contribution-deferral regimes
Where shares have been contributed to a holding company, the deferred gain must be identified. A departure from France may bring that deferred gain into the exit tax analysis.
Reinvestment commitments
French contribution-deferral regimes may impose reinvestment conditions after a sale by the holding company. A relocation abroad does not remove these conditions.
Valuation of the holding
The value of the holding company and its underlying assets must be documented. The French tax authorities may challenge the valuation if the file is weak.
Operational planning
Before leaving France, the taxpayer should map the group, past contributions, expected sales, financing and family governance objectives.