France · Tax regime
Exit tax on unrealised gains (Article 167 bis CGI)
Open
Last verified July 2026
In force. Scope and thresholds unchanged for 2026, but the effective rate rose with the 2026 increase in social levies. Proposals to tighten the regime featured in the PLF 2026 debate.
The exit tax is why France must be modelled as a decade-long commitment rather than a five-year stop. Deferral is automatic for EU/EEA moves and the charge extinguishes after 2 or 5 years of continued holding — but a founder who moves to France and later wants Dubai or Singapore faces a real cash tax on gains they never realised.
Qualifying routes
€800k
Securities portfolio above EUR 800,000
Deemed disposal on transfer of tax residence out of France
—
Shareholding of at least 50% of a company's profits
Applies regardless of value
The facts
- Qualifying figure
- €800k
- Total landed cost
- roughly 30–31.4% of unrealised gains, subject to deferral; a EUR 10m latent gain implies a EUR 3m+ notional charge
- Physical presence
- applies to those who were French tax resident for at least 6 of the 10 years preceding departure
- Family
- assessed on the departing taxpayer's own holdings
- Permanent residency
- not applicable
- Citizenship
- not applicable
- Language test
- not applicable
- Dual citizenship
- Permitted
What can go wrong
- The 6-of-10-years residence condition means a short French stay can be structured outside the charge — but this must be planned at entry.
- Automatic payment deferral applies for moves to the EU/EEA and to states with an assistance and recovery convention. Moves to the UAE, Monaco or most of Asia may require a guarantee and actual payment.
- The charge is extinguished after 2 years of continued holding for portfolios under roughly EUR 2.57m, or 5 years at or above that value — the threshold determines whether your exit plan is a 2-year or a 5-year hold.
- The 2026 social levy increase pushed the effective rate to a reported 31.4%; treat this figure as directionally right but confirm the current combined rate before modelling a large gain.
- PLF 2026 debate included proposals to lengthen the holding period and tighten scope. Policy risk is live.