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TAX GUIDE · MOVING ABROAD

Moving from France Tax Guide 2026: Impôt de Sortie Exit Tax, Assurance-Vie & Revenu Fiscal

Daniel · CountryTaxCalc Updated April 2026
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KEY INSIGHT
France has one of Europe's broadest exit taxes — the impôt de sortie applies when you transfer your fiscal domicile outside France and you hold securities (shares, bonds, OPCVM/UCITS funds) with unrealised gains above €800,602 (2025 threshold, indexed) or where the assets have a total value above €1,300,000 (indexed). EU/EEA departures: automatic deferral until actual sale. Non-EU departures (USA, UK post-Brexit, Switzerland): tax is due within 90 days unless you obtain a surety. Assurance-vie policies follow distinct rules that do not trigger the exit tax but lose their French tax advantages on departure. CSG/CRDS social levies continue to apply to French-source income indefinitely.
At a glance

Key Facts

Impôt de Sortie: France's Exit Tax Explained
The impôt de sortie (exit tax) is governed by Article 167 bis of the Code Général des Impôts (CGI). It applies to individuals who: (1) have been French tax residents for at least 6 of the 10 years preceding departure, AND (2) hold assets exceeding either threshold: (a) securities with unrealised gains >€800,602 (2025, indexed annually), OR (b) securities with a total FMV >€1,300,000. The assets in scope: shares in French and foreign companies, OPCVM (mutual funds/UCITS), ETFs, bonds, social parts in société. NOT in scope: assurance-vie (separate rules), real estate (taxed separately as non-resident), professional assets of sole traders. Calculation: deemed realisation of all in-scope assets at FMV on departure date. The gain is taxed at 30% flat (prélèvement forfaitaire unique — PFU, also called flat tax): 12.8% income tax + 17.2% social levies (prélèvements sociaux). Total: 30% on all unrealised gains above the threshold. EU/EEA departure: automatic sursis de paiement (payment deferral) until actual sale — no immediate payment required. File Form 2074-ETD to declare and elect deferral. Non-EU departure (USA, UK post-Brexit, UAE, Canada): immediate payment due within 90 days of departure UNLESS you provide a caution (surety/guarantee) to the French tax administration. Practical: for large portfolios, engage a French comptable (accountant) to structure the garantie before departure.
Assurance-Vie on Departure from France
Assurance-vie is France's dominant savings vehicle — approximately €2 trillion in assets. It enjoys highly favourable French tax treatment: gains are only taxed on withdrawal, and after 8 years, withdrawals benefit from a €4,600/€9,200 annual allowance plus reduced rates. When you become non-resident: the assurance-vie contract is NOT included in the impôt de sortie calculation (it is specifically excluded from Article 167 bis scope). Your contract remains open and invested — you do not need to close it on departure. However, the French tax advantages do NOT continue once you are non-resident: withdrawals as a non-resident are subject to 35% French withholding (contracts <4 years old), 15% (4–8 years old), or 7.5% (8+ years old) — regardless of the normal French resident tax advantages. Under most DTAs, France's right to withhold at source is limited to the treaty-specified rate. Under the France-USA DTA: US residents receiving assurance-vie income may be subject to 15% withholding at source, with the US taxing the rest. Practical: review all assurance-vie contracts before departure. If you are close to the 8-year mark, waiting until after 8 years to withdraw (while still resident) maximises the French resident tax advantages. After departure, the contract can be maintained or liquidated — the choice depends on your destination country's treatment.
CSG/CRDS and Social Levies on French-Source Income
France's social levies — Contribution Sociale Généralisée (CSG) and Contribution au Remboursement de la Dette Sociale (CRDS) — total 17.2% and apply to investment income. For non-residents: CSG/CRDS continues to apply to: (1) French real estate income (rental income, property gains from French real estate); (2) dividends and interest from French sources for non-EEA residents. EU/EEA non-residents: a 2019 EU Court of Justice ruling (Gouvernement de la Communauté française) limits France's ability to apply CSG/CRDS to EU/EEA residents who are covered by another EU social security system. Non-EEA non-residents (USA, UK post-Brexit, UAE): full 17.2% CSG/CRDS on French rental income and property gains applies in addition to the income tax rate. For French property sales as a non-resident: the gain is taxed at 19% income tax plus 17.2% CSG/CRDS = 36.2% total (subject to the applicable DTA). This makes French property gains for non-residents among the highest-taxed in Europe.
French Pension (Retraite) Abroad
France operates a multi-pillar pension system: (1) Régime général (Assurance retraite/CNAV) — the state basic pension; (2) Complémentaire pension (AGIRC-ARRCO) for private sector employees; (3) Specific schemes for civil servants, liberal professions (CIPAV, CARPIMKO, etc.). All French pension entitlements are preserved on departure. Pension payment abroad: CNAV, AGIRC-ARRCO, and other Caisses de retraite pay internationally. You must provide a certificate of life (certificat d'existence) annually to continue receiving payment — this can be done at a French consulate or notarised by a local official. Pension age: France's pension reform (2023) raised the legal retirement age to 64 (for those born after 1968). Withholding: French pensions paid to non-residents are subject to French income tax withholding (barème retenue à la source — 0%, 12%, or 20% depending on annual pension amount). Under most DTAs, the country of residence has primary taxing rights on pensions — France's withholding is then a credit. Under France-USA DTA: US residents claim French pension withholding as a Foreign Tax Credit. Totalization: France has totalization agreements with many countries allowing combination of French and foreign pension contribution years.
Déclaration de Départ and Final French Tax Return
When leaving France permanently: notify your Centre des Finances Publiques (tax office) of your departure. Your final French income tax return (déclaration de revenus) covers January 1 to your departure date. File Form 2042 (main return) plus any applicable supplementary forms (2042 C for capital gains, 2044 for rental income, 2074-ETD for exit tax declaration). Filing deadline: the standard filing deadline applies — online filing due in May/June following the departure year. Ongoing as non-resident: after departure, you file a French non-resident return (Form 2042-NR or 2042 with non-resident tick box) if you have French-source income. Non-residents without French-source income do not need to file. Numéro fiscal: your French tax number (numéro fiscal) remains valid as a non-resident and is required for property transactions, notarial acts, and non-resident returns. Keep a record of it.
Introduction

France's departure tax regime is one of the most comprehensive in Europe — it captures not just private company shareholders (like Germany's Wegzugsteuer) but also portfolio investors with large unrealised gains in securities accounts. The impôt de sortie (exit tax), significantly broadened by reforms in 2011 and updated in subsequent Finance Laws, affects both departing French citizens and long-term residents with substantial investment portfolios. Beyond the exit tax, France's notorious administrative complexity means departing residents must navigate the déclaration de départ process, assurance-vie rules, CSG/CRDS on French-source income, and Caisse de retraite pension management — all while coordinating with the fiscal calendar of the destination country.

Section 01

Moving from France to the USA: Cross-Border Specifics

France-to-USA migration is common among professionals in finance, technology, academia, and the arts — particularly Paris to New York or San Francisco. Key planning points:

Exit tax and US first-year residency: The French impôt de sortie is calculated on the day before departure from France. If you become a US resident later (e.g., you depart France in March and arrive in the USA in May), the exit tax gain is NOT US-taxable — you were not a US resident when the deemed disposal occurred. Ensure your tax advisor understands this timing. If you depart France and immediately become US-resident (same day), you need careful analysis of which country's rules apply first.

Assurance-vie US reporting: French assurance-vie contracts must be reported to the IRS. The correct treatment is complex — it may be a foreign grantor trust or a foreign insurance policy. Consult a US tax attorney before deciding whether to liquidate the assurance-vie before US residency begins.

France-USA DTA complexity: The France-USA double taxation agreement is among the most complex DTAs in the world. It has a saving clause, multiple protocol amendments, and specific rules for pensions (Article 18), dividends (Article 10), and business income. US residents receiving French dividends face a 5% or 15% French withholding depending on ownership level, claimable as FTC on the US return.

French social security: Moving to the USA on an L-1 or H-1B visa: check the France-USA totalization agreement. French social security contributions may continue to be required for a transitional period; the totalization agreement prevents double contribution. Contact CLEISS (the French liaison office for social security) for guidance.

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FAQ

Frequently Asked Questions

My investment portfolio is worth €1.5M — do I owe the French exit tax when leaving for the USA?

Potentially yes. The impôt de sortie thresholds for 2025: either (a) total securities portfolio FMV > €1,300,000 or (b) unrealised gains in the portfolio > €800,602. If your €1.5M portfolio exceeds the €1,300,000 total value threshold, and you have been French tax resident for at least 6 of the last 10 years, then YES — the exit tax applies. All unrealised gains (FMV minus your original purchase cost) are deemed realised on departure day and taxed at 30% PFU. Because the USA is not in the EU/EEA, there is no automatic deferral — the tax is due within 90 days of departure, unless you arrange a surety (caution). To manage cash flow, you can: (1) request payment by instalments (maximum 5 years); (2) provide a bank guarantee to the French tax authority; or (3) sell some securities before departure to fund the tax payment. Important: losses in your portfolio can offset gains — a net gain calculation is used. This can significantly reduce the exit tax if you have some unrealised losses in the portfolio.

I have a French property — is it subject to the exit tax?

No. French real estate (immobilier) is NOT included in the impôt de sortie calculation. The exit tax applies to securities (financial assets), not physical real estate. However, this does not mean you owe no French tax on your property as a non-resident. When you eventually sell a French property as a non-resident: the gain is taxed at 19% income tax + 17.2% CSG/CRDS (for non-EEA, non-treaty-protected non-residents) = 36.2%. For treaty-protected non-residents (e.g., under France-USA DTA), CSG/CRDS may still apply even if income tax is credited in the US. Additionally, France has a non-resident capital gains tax on real property managed via the notaire at sale — a notaire will apply the tax at source. You also need a représentant fiscal (French fiscal representative) if you are non-resident and selling French real estate — mandatory for non-EEA residents.

When should I file Form 2074-ETD for the exit tax?

Form 2074-ETD (Declaration of Unrealised Capital Gains, Claims, and Instalments on Departure) must be filed along with your final French income tax return for the year of departure. Deadline: same as your final French income tax return — typically online in May/June of the following year, with the balance due in September. For EU/EEA departures: file 2074-ETD to declare the unrealised gains AND to elect the automatic deferral (sursis de paiement) — the tax is logged but not collected immediately. For non-EU departures: file 2074-ETD to declare gains and either pay immediately or request instalment/surety arrangements with the Recette des non-résidents (DINR — Direction des Impôts des Non-Résidents). Missing this form or filing late: the exit tax may be assessed with penalties and interest. The DINR (based in Paris) handles all non-resident French tax matters and is the point of contact for exit tax compliance.

My employer offers stock options (BSPCEs) — are they covered by the exit tax?

BSPCEs (Bons de Souscription de Parts de Créateur d'Entreprise) and stock-options at the departure date: the exit tax under Article 167 bis applies to shares already held at departure. Unexercised options are NOT shares — they are not subject to the exit tax at departure. However, when you exercise BSPCEs or stock options after departure as a non-resident, the gain (the difference between exercise price and FMV at exercise) may be subject to French tax depending on the type of plan and when the options were granted. RSUs (actions gratuites) that have already vested and converted to shares before departure: counted in your exit tax portfolio. RSUs not yet vested: the gain on future vesting is a French-source employment benefit — potentially subject to French withholding even after departure, depending on the French service fraction. Complex area — take advice before departure if you have significant unvested equity.

Do I need to close my French bank account when I leave?

No — you can maintain French bank accounts as a non-resident. Notify your bank of your change of tax residency. French banks (BNP Paribas, Société Générale, Crédit Agricole, La Banque Postale) all serve non-resident customers, though some accounts may be reclassified or restricted. Non-resident account: your bank must apply the non-resident withholding rates on interest income. Under the FATCA framework, if you become a US resident, your French bank must report your accounts to the IRS annually. FBAR: French accounts exceeding $10,000 must be reported via FinCEN 114. Livret A, Livret de Développement Durable (LDD): these state-regulated savings accounts must be closed when you become non-resident (they are only open to French residents). The accrued interest is tax-free in France up to closure. PEA (Plan d'Épargne en Actions): must be closed within 2 months of becoming non-resident, or converted — losses in the PEA cannot be carried forward after closure.
Disclaimer:This guide provides general tax information for educational purposes only. French tax law — including Article 167 bis impôt de sortie thresholds, assurance-vie rules, CSG/CRDS rates, and DTA provisions — changes with annual French Finance Laws (Loi de finances). Nothing in this guide constitutes tax or legal advice. Consult a French expert-comptable or avocat fiscaliste before departing France, particularly if you hold an assurance-vie, real estate, or securities portfolio above the exit tax thresholds.
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