Business owners planning a move abroad · Practical guidance
French exit tax: what should you check before leaving France?
Are you planning a move abroad while holding company shares? French exit tax may affect gains you have not yet received. Review your position before changing residence, considering your move, any planned sale and your cash needs together.
Martins Patrimoine · Updated on
Which shares and transactions need reviewing?
For unrealised gains, Article 167 bis of the French Tax Code covers, in particular, people who were French tax residents for at least six of the previous ten years and whose relevant shares exceed €800,000 or represent at least 50% of a company's profits. Deferred gains and earn-out claims require a separate review.
These criteria are not an individual assessment. Have the relevant holdings, their values and past transactions reviewed. An earlier contribution of shares to a holding company may matter as much as your current portfolio.
- My tax residence history
- My shares, their values and previous contributions or sales
Does moving to Spain remove all filing obligations?
No. A move to Spain generally qualifies for the automatic payment deferral provided for the European Union. Deferring payment does not remove filing obligations. The treatment also depends on the type of gains and subsequent events.
Clarify who will handle French filings and who will review the implications in your destination country. Someone needs to coordinate both calendars, including if your plans change.
- My planned moving date and destination country
- The professionals responsible for filings in each country
Why timing matters before a sale
Selling or gifting shares, or moving to another country again, may change how your case must be handled. A payment deferral does not mean later transactions can be ignored: have their implications checked before committing.
Prepare a simple timeline: your move, transactions already signed, likely deadlines and cash needs. Then request a written schedule of the matters to address and documents to retain.
- My planned transactions before and after moving
- The deadlines and supporting documents to confirm
What we can clarify in our first meeting
Tell Gary about your destination, timing and current decisions. The meeting helps identify the wealth planning issues and expertise to coordinate. Personal tax analysis then requires a defined engagement with the relevant professionals; this page does not automatically calculate tax liabilities.
Sources and scope
This sheet helps to prepare a discussion. It is neither an analysis of your situation nor a recommendation for investment.