Valley International / business
Talent Passport founders: a personal wealth checklist for France
A Talent Passport and a French company do not settle the founder’s personal position. Existing shares, future remuneration, residence and a possible exit need to be reviewed before the move or the employment start date.
A French talent residence permit covers defined categories of work or business activity. It does not alone determine tax residence or the treatment of shares you already own. Establish the residence position under article 4 B and the treaty, then examine a proposed sale under both countries’ rules. France does not generally revalue every holding on arrival, so keep the original acquisition records and check any specific treaty provision.
The timing of an intended sale can matter on arrival as well as on a later departure. French exit tax when leaving with a substantial portfolio covers article 167 bis; French tax residence under Article 4 B explains how the residence-transfer date is established. Compare the operations you actually envisage rather than assuming one always carries the larger charge.
The permit and impatriate eligibility
The talent permit and article 155 B have separate conditions. Recruitment from abroad into an eligible role may qualify for the tax regime, while creating a company after moving does not establish eligibility by itself. Have the immigration, employment and tax facts reviewed together. French impatriate tax regime: eligibility and exemptions and A foreign founder’s personal tax and wealth position in France explain the related questions.
A second timing rule runs alongside and does not depend on the impatriate regime at all. A person who becomes a French tax resident without having been French tax resident in the five calendar years before arrival has French wealth tax limited to French real estate until 31 December of the fifth year following the year of arrival, under article 964 of the French tax code.
The shares themselves, before the move
List any intended share sale, existing holding company, employee awards and earlier share contributions. A salary-related award can involve a work-period allocation, while a securities gain or deferred contribution follows other rules. Retain the grant, acquisition and restructuring documents so that each can be classified accurately.
Where the founder keeps directing his existing foreign company from France, a further question arises that belongs to the company rather than to him: a company can be regarded as effectively managed from the place where its decisions are actually taken. French long-stay visitor visa: financial and tax implications develops that point from the individual’s side; for a founder it is a group question, and it is examined with the company’s own advisers.
Ownership of the shares within the family
A matrimonial-property review helps establish which spouse owns the shares and how a sale or death would affect the family. The applicable rules depend on the marriage date, agreements and residence history; the Hague Convention does not govern every marriage after 1992. How moving to France may affect your matrimonial property regime explains the different periods and possible choices.
How we sequence it
We review the shares, family ownership and proposed transactions alongside the immigration and company files. This establishes which questions need an answer before a move or employment start, and which can be handled later. Choosing and forming a French company as a foreign founder covers incorporation; the company need not be left until every personal question is settled.
Three dates that are not the same date
The date the permit is granted, the date you arrive, and the date your tax domicile transfers are three distinct dates that founders routinely treat as one. Only the third governs the tax treatment of a disposal, and it is established on the facts of article 4 B rather than by any administrative document. Write down which date you are relying on before any transaction is timed against it.
References cited
CGI, art. 155 B · CGI, art. 964 · CGI, art. 167 bis · CGI, art. 4 B
Frequently asked questions
Does France revalue my shares when I become resident?
There is no general automatic reset of every holding to its arrival-date value. Check the asset’s acquisition history, any foreign exit-tax treatment and relevant treaty provisions before calculating a French gain. Keep both the original records and any moving-date valuation.
Can a Talent Passport founder claim the impatriate regime?
It depends on how he arrives, not on the permit alone. Article 155 B of the French tax code covers a person called to France by a company established abroad, or recruited directly abroad by a company established in France. A founder who moves to France and then creates his own company is not in that configuration and his position has to be examined. A founder seconded by his existing foreign group, or recruited from abroad by the French entity, may qualify.
How long is my foreign property outside French wealth tax?
A person who becomes a French tax resident without having been French tax resident in the five calendar years before arrival is subject to French wealth tax on French real estate only, until 31 December of the fifth year following the year of arrival, under article 964 of the French tax code, a rule separate from the impatriate regime that does not require it.
Do my stock options or free shares follow me to France?
Employee awards need classification from their plan documents. Employment-related gains can be allocated by reference to the relevant work period and countries; a later securities gain is a separate question. Do not apply one rule to every option, warrant or free-share plan.
Could moving to France change who owns my shares?
The move can be relevant to the law governing matrimonial property in some circumstances. It does not automatically turn previously personal shares into joint property. Review the marriage date, agreements, residence history and acquisition documents with the notaire.
ÉTHIQUE ET PATRIMOINE, a French simplified joint-stock company (SAS), registered office at 41 rue Saint-Ferdinand, 75017 Paris, France, Paris Trade Register no. 803 414 796, VAT no. FR 40 803 414 796, registered with ORIAS under number no. 24001817 (www.orias.fr) — Financial investment adviser (CIF) no. 18002418, member of ANACOFI-CIF, a professional association approved by the Autorité des marchés financiers, and Anacofi-Courtage for its brokerage activity. Presence: Paris, Montpellier, London, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.
Review my position as a founder
Book a callWritten by Stéphane Molère, President of Éthique et Patrimoine — page last reviewed on 2026-09-15 — reference date for the rules: 2026-09-07.