French exit tax

French exit tax and relocation to the United Kingdom

French exit tax and the UK: post-Brexit relocation, France-UK treaty, payment deferral and founder planning.

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.

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.
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