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 risk after departure
Leaving France administratively is not enough. The French tax authorities may challenge the claimed transfer of residence if the factual centre of life, professional activity or economic interests remains in France.
Article 4 B criteria
French domestic law uses alternative criteria: home or main place of stay, principal professional activity and centre of economic interests. One criterion may be sufficient.
Treaty tie-breaker
Where two States claim residence, the relevant tax treaty may apply successive criteria such as permanent home, centre of vital interests, habitual abode and nationality.
Evidence file
A strong residence file includes housing, family move, school, employment, bank, health, utility, immigration and travel evidence.
Connection with exit tax
A residence challenge may also affect the exit tax date, the deferral analysis and the taxpayer’s reporting position.