France · Tax regime
Exit tax on unrealised gains (Article 167 bis CGI)
Open
Last verified July 2026
In force. Scope and thresholds are 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 the reason France needs to be modeled as a decade-long commitment, not a five-year stop. Deferral is automatic for moves within the EU and EEA, and the charge disappears entirely 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 bill on gains they never actually realized.
Qualifying routes
€800k
Securities portfolio above EUR 800,000
Treated as a deemed disposal on transfer of tax residence out of France.
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Shareholding of at least 50% of a company's profits
Applies regardless of value.
The facts
- Minimum
- €800k
- Total landed cost
- Roughly 30–31.4% of unrealised gains, subject to deferral. On a EUR 10m latent gain, that implies a notional charge of EUR 3m or more.
- Route type
- Tax regime, not a visa
- Physical presence
- This applies to anyone who was a French tax resident for at least 6 of the 10 years before leaving.
- Family
- It is 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 rule means a short stay in France can, in theory, be structured to avoid the charge. That structuring has to happen at entry, not later.
- Automatic payment deferral applies to moves within the EU and EEA, and to states that have an assistance and recovery convention with France. Moves to the UAE, Monaco or most of Asia may require a guarantee, and actual payment, up front.
- The charge disappears after 2 years of continued holding for portfolios under roughly EUR 2.57m, or after 5 years above that value. That threshold decides whether your exit plan is built around a 2-year hold or a 5-year one.
- The 2026 social levy increase pushed the effective rate to a reported 31.4%. Treat that figure as directionally right, but confirm the current combined rate before modeling a large gain.
- The PLF 2026 debate included proposals to lengthen the holding period and tighten the rules further. The policy risk here is real and ongoing.