A foreign founder’s personal tax and wealth position in France

The company accounts do not answer the founder’s personal questions. Salary, dividends, share ownership, wealth tax and a later sale or departure need to be reviewed as one connected file.

Salary and dividends affect both the company and your personal finances. Remuneration can be deductible under the applicable conditions and brings social contributions and related protection. Dividends follow a different calculation; their social treatment depends in part on the company and the recipient’s status. Compare the company’s total cost with your net income and protection, rather than comparing headline tax rates alone.

In short

A dividend should not be treated as a salary without contributions, and a remuneration exemption should not be assumed to apply to a French-company dividend; the result depends on the company’s tax regime, your status and applicable reliefs.
Article 155 B, the impatriate regime, can apply to qualifying directors as well as employees, but a title such as SAS president does not establish eligibility on its own: recruitment circumstances and previous residence must be checked.
French wealth tax reaches real estate rather than financial assets, under article 964 and following of the French tax code, so shares in an operating company are not in scope as such; the company’s property is looked through only to the extent that it does not use it for its own operating activity.
For the rise in value of shares you still hold, the exit tax of article 167 bis requires French tax residence for at least six of the ten years before departure, and holdings worth more than €800,000 or representing at least 50% of a company’s profits.

The impatriate regime applies to directors too

Article 155 B can apply to qualifying directors as well as employees. A title such as SAS president does not establish eligibility on its own: the recruitment circumstances, previous residence and other conditions need to be checked. The remuneration exemption can affect the salary comparison; separate provisions concern certain foreign-source investment income. French impatriate tax regime: eligibility and exemptions explains those conditions.

How French wealth tax treats the shares

French wealth tax reaches real estate rather than financial assets, under article 964 and following of the French tax code, so shares in an operating company are not in scope as such. Two qualifications matter for a founder. Property held by the company can be looked through, so a trading company that owns property it does not use for its own activity is not automatically outside the charge, whereas premises used for that activity are left out of the calculation.

And an exemption exists for assets genuinely used in a professional activity, whose conditions have to be met rather than assumed. Newly arrived residents also benefit from a separate limitation confining the charge to French real estate for a period following their arrival.

Selling the company, or leaving France

Two events deserve to be anticipated years ahead, because both are governed by holding periods and by residence at a given date. A sale of shares produces a capital gain whose treatment depends on how and when the shares were acquired and on your residence when the sale occurs. A departure from France can bring the exit tax of article 167 bis of the French tax code into the analysis.

For unrealised gains — the rise in value of shares you still hold — it requires French tax residence for at least six of the ten years before departure, and holdings worth more than €800,000 or representing at least 50% of a company’s profits; deferred gains and certain receivables need their own review, and the timing of any later disposal changes the result.

A founder planning both a sale and a departure should decide the order deliberately, because the two sequences produce different results. French exit tax when leaving with a substantial portfolio sets out the mechanism, the deferral rules and what a later sale does to the deferred amount in full.

The choice between remuneration and dividends has social security consequences as well as tax ones, and an arrangement designed solely to minimise contributions can be challenged. The exit tax and the professional assets exemption are technical regimes whose conditions must be verified against the client’s own facts. This page is general information and neither tax advice nor a recommendation. The firm does not practise accountancy or law and works alongside the professionals who do.

References cited

CGI, art. 167 bis · CGI, art. 155 B

Frequently asked questions

Should I pay myself a salary or dividends?

Calculate the company’s cost, your net income and the social protection associated with each option. The result depends on the company’s tax regime, your status and applicable reliefs. A dividend should not be treated as a salary without contributions, and a remuneration exemption should not be assumed to apply to a French-company dividend.

Can a company director claim the impatriate regime?

Certain directors can qualify under article 155 B. Check the eligible role, recruitment from abroad, previous non-residence and remaining conditions. Being an SAS president or a returning French national is not sufficient by itself. If eligible, include the relief in the remuneration calculation.

Are my company shares subject to French wealth tax?

Not as financial assets, since the charge under article 964 and following of the French tax code reaches real estate rather than securities. Two qualifications matter. Property owned by the company can be looked through, so a trading company holding property it does not use for its own activity is not automatically outside the charge, whereas premises used for that activity are left out. And an exemption exists for assets genuinely used in a professional activity, whose conditions must be met rather than assumed. Newly arrived residents also have a separate limitation for a period after arrival.

What happens to my shares if I leave France?

A transfer of tax residence can bring article 167 bis into the analysis. For unrealised gains — the rise in value of shares you still hold — residence history and the value or size of the participation are important conditions. Deferred gains and certain receivables need separate examination. Establish the scope, any payment deferral and the consequences of a later sale using the departure-date rules.

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.

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Written by Stéphane Molère, President of Éthique et Patrimoine — page last reviewed on 2026-09-15 — reference date for the rules: 2026-09-07.