French exit tax

Lawful French exit tax planning

Lawful planning before leaving France: gifts, holding companies, timing, valuation and anti-abuse review.

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.

Planning is not concealment

The objective is not to hide a departure or assets. The objective is to qualify the situation correctly, use the legal options available and avoid creating artificial arrangements that may be challenged.

Timing of the move

The date of transfer of tax residence must be chosen with the sale timetable, family move, employment situation and company transaction calendar in mind.

Gifts and estate planning

A gift before departure can sometimes be relevant, but it must be legally effective, valued properly and consistent with family and patrimonial objectives.

Holding company structures

A holding company may help organise reinvestment and governance. It does not automatically remove exit tax. Contribution-deferral rules and reinvestment conditions must be reviewed.

Anti-abuse review

Any planning should be tested against abuse-of-law principles, economic rationale and documentation. The file must be defensible if reviewed several years later.

This page provides general information only. French tax residence, exit tax, impatriation and cross-border reporting must always be analysed on the basis of the taxpayer’s facts, documents and applicable treaties.
+33 1 87 44 29 51Book a consultation