Application process & timeline
Complete the analysis before the residence and ownership facts change.
01Establish the proposed departure factsBefore the move
Document homes, family, work and treaty connections.
Documents & evidence
- Travel and housing history
- Employment and company roles
02Value and classify the holdingsBefore transactions
Apply residence lookback and ownership tests to the correct asset categories.
Documents & evidence
- Share register
- Historic costs
- Valuations
- Deferred-gain schedules
03Resolve payment and destination coordinationBefore departure where required
04File the transition yearRelevant annual filing cycle
Reconcile resident-period worldwide and continuing French-source income.
A move is not the same as a tax departure
French residence depends on the household, work and economic facts as well as any treaty. Moving into accommodation abroad does not by itself settle the position if the family home or main activity remains in France. Prepare an evidence-based chronology instead of selecting the most convenient flight date.
For a founder, review where corporate functions continue after the move. A shareholder can become nonresident while the company still operates in France. The reverse problem is also possible: changing management or transferring functions can create company-level consequences that the personal departure return does not cover.
Inventory holdings before testing exit tax
List direct and indirect shares, percentages, acquisition costs, current values, deferred gains and claims linked to prior disposals. The unrealised-gain test combines the six-of-ten-year residence lookback with either more than €800,000 of qualifying holdings or at least 50% of a company’s profit rights.
An independent valuation can be particularly important for an unlisted business. Keep the valuation method, underlying accounts and any live sale discussions consistent with the departure date. A later cash exit may be evidence about earlier value, but it is not automatically the correct number.
Separate a deferral application from a later relief claim
The destination affects automatic payment deferral. Where a request or security is needed, resolve it before the move instead of discovering the problem at filing time. A subsequent change of country can also affect deferral; the official guidance identifies advance steps for moves outside qualifying cooperation conditions.
The two-year or five-year retention-based relief for qualifying unrealised gains has its own conditions. It does not simply forgive every deferred tax item. Sales, redemptions, transfers and other changes should be reviewed before they occur and reflected in the follow-up reporting.
The departure-year return and continuing French income
Notify the administration and distinguish the resident and nonresident periods. A 2042-NR schedule can be needed for French-source income received after departure. Rental property, pensions, dividends and continuing work require their own source and treaty analysis; nonresidence is not a blanket exemption for French income.
Keep bank self-certifications, correspondence addresses and accounting instructions aligned with the legal conclusion. Retain access to tax records and notices after moving. Someone should remain responsible for deadlines even where an overseas address makes ordinary post slower.
Company migration is a separate project
Before moving assets or management, identify which entity owns intellectual property, contracts and receivables, and where people perform the work. Article 221 can trigger company or asset-transfer taxation, with specific EU/EEA payment rules and acceleration events.
The implementation plan should therefore contain separate personal, corporate and operational calendars. It should say who values assets, files each return, maintains French registrations, monitors deferred liabilities and confirms the destination’s arrival tax basis. A new overseas company is not an alternative to that analysis.
Sources & research notes9 references
Sources supporting this guide. Research draft awaiting editorial review.
- DGFiP: domestic residence and treaty tests
- CGI Article 150-0 D: securities acquisition cost
- CGI Articles 167–167 bis: departure and shareholder exit tax
- DGFiP: departure exit tax and payment deferral
- DGFiP: foreign accounts and insurance reporting
- DGFiP: departure-year tax procedures
- DGFiP: permanent establishment and advance ruling
- CGI Article 221: company and asset departure
- DGFiP: nonresident individual dividends