Valley International / leaving france
Exit tax when leaving France with a large portfolio
Exit tax does not punish leaving France. It taxes gains you have not yet realised, and only if your file crosses a threshold most people never check.
Article 167 bis of the French tax code taxes unrealised gains on securities and company rights at the moment you transfer your tax residence outside France, but only where three conditions are met together: you have been a French tax resident for at least six of the ten years preceding departure; you hold a securities portfolio worth at least €800,000, or a participation of at least a percentage set by law in a single company; and you actually transfer your tax domicile abroad. Meeting the first two without the third changes nothing, and most people who ask about exit tax turn out not to be affected, usually because the threshold is measured across the whole portfolio and they measured only what they intended to sell.
The threshold catches more than people expect
The portfolio value is assessed across every account and every participation together, not only the lines you plan to dispose of. A newcomer who arrived with substantial holdings, added a French employer's shares over several years, and never totalled the figure is the profile most likely to be surprised. The test is done on the whole file, well ahead of fixing a departure date.
Deferral is available, and it depends on where you go
The tax is computed on departure but payment of it can be deferred. Moving within the European Union, or to a state that has concluded with France an administrative assistance agreement against fraud and evasion together with a mutual assistance agreement for tax recovery, generally gives an automatic deferral. Moving elsewhere can still obtain deferral, but subject to conditions including guarantees given to the tax authority. This is one of the few genuine decisions a departing taxpayer makes; scheduling it ahead of the move avoids reacting to a demand later.
What a later sale does to the deferred tax
The deferred tax is not owed forever by default. Various events extinguish it, chiefly the passage of a holding period without a disposal, so that many departures ultimately generate no payment at all. Selling the securities while the deferral runs is different: the sale generally settles the deferred tax on that portion, calculated by reference to the gain established at departure, and the timing of a later disposal, in which country and after how long, can materially change the result. A sale planned without checking the deferred position is the most common way this goes wrong.
What has to be filed
Exit tax generates its own annual declaration for as long as the deferred tax remains outstanding, tracking the securities concerned and any event affecting the deferral, entirely separate from your ordinary annual return in whichever country you now file. Missing that continuing declaration is a common and avoidable failure among people who assume that leaving closes the French file.
Before fixing a departure date
Total your securities portfolio and participations across every account, not only what you plan to sell. Check whether either threshold is crossed. If it is, establish which deferral regime applies to your destination. Decide, in writing, what you will and will not sell in the following years, since a sale changes the outcome. And calendar the continuing exit tax declaration alongside your new country's own filing.
Frequently asked questions
Does exit tax apply to everyone who leaves France?
No, and most people who ask are not affected. It applies only where three conditions are met together: French tax residence for at least six of the preceding ten years, a securities portfolio above the statutory threshold or a substantial participation in a single company, and an actual transfer of tax domicile abroad. The threshold is measured across your whole portfolio, not only the assets you intend to sell, which is where people most often underestimate their position.
Do I have to pay exit tax immediately when I leave?
Not necessarily. Payment can be deferred, generally automatically when moving within the European Union or to a state with the right administrative assistance agreements with France, and on conditions including guarantees when moving elsewhere. Deferred tax is not owed forever by default: several events extinguish it, including simply holding the securities for long enough without selling, so many departures ultimately generate no payment. Selling during the deferral period is what typically settles the tax.
If I sell my shares two years after leaving, does exit tax apply?
It can, if the sale occurs while the deferred tax is still running, in which case the sale generally settles the deferred amount for that portion, calculated on the gain established at your departure rather than on the gain since. This is why a disposal should never be decided without first checking the exit tax position from the departure year. The timing and the country of the later sale both affect the outcome.
What do I still have to file after leaving with exit tax deferred?
A continuing exit tax declaration, for as long as any deferred tax remains outstanding, tracking the securities concerned and any event that affects the deferral. This is separate from your ordinary tax return wherever you now live, and it is the obligation people most often forget, because leaving feels like closing the French file when in fact one specific filing continues. Missing it does not remove the tax; it adds a compliance problem to an existing one.
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, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.
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Book a callWritten by Stéphane Molère, Président d'Éthique et Patrimoine — page last reviewed on 2026-08-30 — rules quoted are those in force at that date.