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.
Post-Brexit analysis
A move to the United Kingdom requires a specific review because the EU law background, recovery assistance and UK domestic reforms affect the practical risk analysis.
France-UK treaty
The treaty is relevant for residence and allocation of taxing rights. It does not replace the French exit tax computation when article 167 bis applies.
Payment deferral
The deferral position for a UK relocation must be checked at the time of the transfer of tax residence. The answer should not be assumed from older EU-era reflexes.
UK tax changes
The UK tax treatment of foreign income and gains has changed. A French departure strategy should be aligned with the UK arrival strategy.
Founder planning
Founders should review cap table, valuation, liquidity event, holding structures and French forms before moving to the UK.
A post-Brexit file requires two current-law checks
The United Kingdom's departure from the European Union did not make every France-to-UK move identical to a move to any other third country. Payment deferral must be tested under the current wording of Article 167 bis and the applicable cooperation and recovery framework. Separately, UK residence and taxation must be analysed under UK law. Neither conclusion should be assumed from an older pre-Brexit memo.
For French residence, record when the French home ceased to be available, where the family lives, where professional duties are performed and where the main economic interests are managed. For UK residence, apply the Statutory Residence Test to the relevant tax year with day-count and connection evidence. If both States can initially claim residence, review the France-UK treaty criteria. A UK visa or company appointment is not a treaty tie-breaker by itself.
Coordinate the share and transaction calendar
- identify shares, earn-out rights and pre-existing deferred gains before departure;
- fix a supportable transfer-date value, especially for an unquoted founder-controlled company;
- map a planned fundraising, sale, option exercise, dividend or reorganisation against the move;
- determine the French filing and any follow-up obligations;
- analyse the UK treatment of later foreign income and gains under the regime applicable in the arrival year.
The UK replaced the former remittance-basis framework with new rules from April 2025. Their conditions and transitional provisions are time-sensitive. A person should not assume that historic “non-dom” advice remains effective, or that a favourable UK result neutralises the French exit tax. The French charge, payment deferral and later UK taxation can operate on different bases and at different times; foreign-tax-credit or treaty relief must be examined for the actual event.
Documents to keep
Retain travel records, leases, utility and council-tax evidence, employment calendars, board minutes, valuation papers, French forms and proof of any event affecting the shares. Where management continues across the Channel, document the location and substance of strategic decisions. This protects both the residence analysis and any later review of the valuation or deferral.
Use the BOFiP exit-tax deferral guidance and the administration's official France-UK treaty guidance as starting points. The post-Brexit deferral position and the UK arrival regime should be confirmed at the planned transfer date; this page gives no assurance that a particular move qualifies.
First-year reconciliation
After the first UK tax year, compare the planned day count and work pattern with what actually occurred. Reconcile UK filings, foreign income and gains, French-source receipts and any share transaction with the French departure analysis. If split-year treatment or a new-arrival regime was expected, confirm that the factual conditions were met rather than carrying the assumption into later advice. Board minutes and travel records should also be reviewed where the individual remains a director of a French company. This reconciliation identifies residence or credit issues while evidence is still available.