Key takeaways
- You remain a French tax resident if any one of four domestic criteria is met: your household (foyer) is in France, your principal place of stay is in France, your main professional activity is in France, or France is your centre of economic interests. Leaving France means breaking all four.
- If you were French tax domiciled for 6 of the last 10 years and hold shares worth more than EUR 800,000 (or over 50% of a company), the exit tax taxes unrealised gains at 12.8% income tax plus 18.6% social surtaxes; payment is automatically deferred for moves to the EU or a treaty country and cancelled after 2 years (5 years above EUR 2.57 million).
- After departure, France still taxes French-source income (French rent, French salary, gains on French property) and French real estate above EUR 1.3 million for the real-estate wealth tax (IFI).
Last reviewed: October 2026
French nationals are not taxed on the basis of citizenship: if you genuinely move your life abroad, France taxes you only on French-source income. But France's residence test is broad – one criterion is enough to keep you resident – and the exit tax catches founders and investors. This guide explains how to leave France cleanly in 2026.
Leaving France – key figures (2026)
| Item | Figure / rule |
|---|---|
| Residence criteria (any one suffices) | Household (foyer); principal place of stay; main professional activity; centre of economic interests |
| Exit tax – residence condition | French tax domicile for 6 of the 10 years before departure |
| Exit tax – shareholding threshold | Holding over 50% of a company or shares worth over EUR 800,000 |
| Exit tax – rates | 12.8% income tax + 18.6% social surtaxes (or progressive scale on option) |
| Exit tax – discharge period (departures since 2019) | 2 years; 5 years if shares exceed EUR 2.57 million |
| Real-estate wealth tax (IFI) | Due above EUR 1.3 million net real estate; non-residents taxed on French real estate only |
| Departure year | One return covering income up to departure (resident) and French-source income after |
When are you still a French tax resident?
Under article 4 B of the French Tax Code, you are domiciled in France if at least one of these applies:
- Household (foyer). Your foyer – usually where your spouse/partner and children live – is in France.
- Principal place of stay. Failing a foyer, you spend most of your time in France.
- Professional activity. Your main professional activity is carried out in France (unless it is ancillary). Senior executives of large French companies (turnover above EUR 250 million) are presumed to work mainly in France.
- Centre of economic interests. Your main investments, business seat or the source of most of your income is in France.
There is no 183-day rule in French domestic law: someone who spends 150 days in France but whose family stays in Paris is resident. Where another country also treats you as resident, the treaty tie-breaker (permanent home, centre of vital interests, habitual abode, nationality) decides.
Step-by-step: how to leave France
- Move the household. If your spouse and children stay in France, the foyer criterion usually keeps you resident.
- Move your professional activity. Work for clients or an employer from your new country; avoid running a business mainly from France.
- Reorganise economic interests. If most of your wealth or income remains in France (e.g. a French company paying you dividends), you may still meet the economic-interest test.
- Become resident abroad and obtain a tax residence certificate from your new country.
- Declare your new address in your espace particulier on impots.gouv.fr; from the following year you will be handled by the non-residents' tax office (SIP non-résidents).
- File the departure-year return (the following spring) declaring income up to your departure date and French-source income after it, and attach the exit-tax declaration if you are in scope.
- Keep evidence: new lease, school enrolment, foreign employment or company registration, travel log.
The French exit tax explained
You are in scope if you were French tax domiciled for at least 6 of the 10 years before leaving and, on departure, the shares and rights held directly by your tax household either represent more than 50% of a company's profits or are worth more than EUR 800,000 in total.
- What is taxed: the unrealised gain on those shares (and certain deferred gains from earlier exchanges).
- Rate: flat 12.8% income tax plus 18.6% social surtaxes, or the progressive scale on option.
- Deferral: automatic and without guarantee when you move to an EU member state or to a country with a tax treaty with France covering assistance (non-cooperative countries excluded). Otherwise, deferral requires an application and guarantees.
- Cancellation: for departures since 2019, the tax is discharged if you still hold the shares 2 years after leaving (or 5 years if they are worth more than EUR 2.57 million), or if you return to France.
Example: A founder domiciled in France since 2015 holds 60% of a SaaS SAS valued at EUR 3 million (acquisition cost EUR 10,000). She moves to Spain in 2026. The exit tax is computed on the EUR 2.99 million gain but automatically deferred; if she has not sold within 5 years (holding above EUR 2.57 million), it is cancelled.
What stays taxable in France after you leave?
- French-source salaries (work physically performed in France) – withholding at source applies.
- Rental income and gains on French property – taxed in France, with social charges for non-EU residents.
- Dividends from French companies – withholding tax, reduced by treaty.
- French real estate for IFI – non-residents pay IFI on French real estate if net value exceeds EUR 1.3 million.
- Minimum rate for non-residents: French-source income is taxed at a minimum rate (20% up to the indexed threshold of about EUR 29,000, 30% above) unless you show that your worldwide average rate would be lower.
Points for location-independent professionals
- Freelancers (micro-entrepreneurs): close or transfer your activity; continuing to invoice French clients from abroad is possible, but keep the business genuinely run from your new country to avoid a French permanent establishment.
- Founders of a French SAS/SARL: if you keep managing the company from abroad, its place of effective management and your own economic-interest test both need checking.
- French nationals moving to Monaco: under the France–Monaco treaty, French nationals who moved to Monaco after 1962 remain taxable in France – a well-known exception.
Frequently asked questions
Do French nationals living abroad pay tax in France?
Only on French-source income, provided they are no longer French tax residents. France does not tax on the basis of citizenship (except for French nationals in Monaco). French rent, French salaries, French property gains and French real estate above EUR 1.3 million remain taxable.
How do I stop being a French tax resident?
Ensure none of the four criteria applies: move your household and main place of stay, carry out your professional activity abroad and shift your centre of economic interests. Then update your address with the tax office and file the departure-year return.
Who pays the French exit tax?
People who were French tax domiciled for 6 of the last 10 years and hold shares worth more than EUR 800,000 or more than 50% of a company. Gains are taxed at 12.8% plus 18.6% social surtaxes, usually with automatic deferral.
When is the French exit tax cancelled?
For departures since 2019, it is discharged if you still hold the shares 2 years after leaving, or 5 years if they exceed EUR 2.57 million, or if you return to France.
Is there a 183-day rule in France?
Not in domestic law. Residence depends on household, principal place of stay, professional activity and economic interests. The 183-day concept mainly appears in tax treaties for employment income.
Related guides
- Capital gains tax in France
- Legal forms of business in France
- How to end your tax residency in Germany
- How to obtain tax residency in Portugal
Sources
- PwC Worldwide Tax Summaries – France: Residence
- PwC Worldwide Tax Summaries – France: Other taxes
- Code général des impôts, articles 4 A, 4 B and 167 bis
- impots.gouv.fr – non-residents section
This guide is general information, not personalised tax advice.
Planning to leave France? Get a personalised exit plan – residence, exit tax and new structure – with Heavnn → heavnn.io
