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French exit tax: leaving France while holding shares

The exit tax is the taxation of unrealised gains on shareholdings when tax domicile is moved out of France. Under article 167 bis of the French Tax Code, it applies where the holdings exceed €800,000 or 50% of a company’s profits.

The firm determines whether the departure falls within the scope of the exit tax, quantifies the tax, prepares the deferral request where one is needed and handles the reporting follow-up until relief is granted.

What should be prepared before leaving France with shareholdings?

Conditions of application: prior period of residence, €800,000 or 50% of profits thresholds.
Valuation of the shares on the date of departure and calculation of the unrealised gain.
Automatic or on-request deferral of payment depending on the destination State, and security.
Events that end the deferral: sale, buy-back, redemption or cancellation of the shares.
Departure return (form 2074-ETD), annual follow-up return (form 2074-ETS) and relief at the end of the period.

What are the key concepts?

What are the figures and thresholds for 2026?

Item	Value	Reference
Prior tax residence	6 of the 10 years before departure	Art. 167 bis CGI
Value threshold of holdings	€800,000	Art. 167 bis CGI
Shareholding threshold	50% of a company’s profits	Art. 167 bis CGI
Relief, general case	2 years after departure	Art. 167 bis VII CGI
Relief, shares above €2.57m	5 years after departure	Art. 167 bis VII CGI

In which cases has the question arisen?

Questions

Frequently asked questions

Who is liable to the French exit tax?

Under article 167 bis of the French Tax Code, a person who moves their tax domicile out of France after being resident for at least six of the previous ten years, where their holdings exceed €800,000 or 50% of a company’s profits.

Must the exit tax be paid on departure?

Not necessarily. Deferral of payment is automatic on a move to an EU State or a State bound to France by administrative assistance and tax recovery agreements, provided it is not on the list of non-cooperative States; elsewhere it is granted on request, against security.

When is the exit tax discharged?

The deferred tax is discharged if the shares are still held two years after departure, or five years where their value exceeds €2.57 million. A sale before then makes the tax payable.

Answers current as at 9 October 2026