By Dubai Tax Resident Editorial Team · Last reviewed: October 2026
France’s exit tax applies when you transfer your tax domicile abroad after being French tax resident for at least six of the last ten years, and you hold shares worth at least EUR 800,000 or at least 50% of a company’s profits. France then taxes the unrealised gains on those holdings as if you had sold them on departure. For 2026 departures, the flat tax rate is 31.4%. Payment can be deferred, and the tax is cancelled if you keep the shares for two years, or five years for larger holdings.
Key facts
- Legal basis: article 167 bis of the French General Tax Code
- Residence condition: French tax resident for 6 of the last 10 years
- Holding threshold: EUR 800,000 in total or 50% of a company’s profits
- Rate: flat tax of 31.4% from 2026 (12.8% income tax plus 18.6% social charges)
- Deferral: automatic for some destinations, on request with guarantees for others
- Cancellation: after 2 years, or 5 years if holdings exceed EUR 2.57 million
- Forms: 2074-ETD on departure, 2074-ETS during deferral
Who has to pay French exit tax?
Exit tax applies if all of the following are true:
- you transfer your tax domicile out of France, for example to Dubai,
- you were French tax resident for at least six of the ten years before leaving, and
- on the day before departure, you hold company shares and similar securities worth at least EUR 800,000 in total, or hold at least 50% of the profits of a company.
Besides latent gains on shares, the exit tax also covers certain receivables linked to earlier share sales, such as earn-out clauses, and gains whose taxation was previously deferred.
How is the tax calculated?
The taxable amount is the difference between the market value of your shares on the day before departure and their acquisition cost. The income tax part is charged at the flat rate of 12.8%, unless you opt for the progressive scale, plus social charges. Following the 2026 social security financing law, social charges on most capital income rose to 18.6%, bringing the overall flat tax to 31.4%. Check the current rates on impots.gouv.fr.
Deferral of payment
The tax is calculated on departure, but payment can be deferred:
- Automatic deferral applies when you move to an EU or EEA state, or to a country that has the required administrative assistance and recovery assistance agreements with France.
- Deferral on request is possible for other destinations, usually with guarantees and the appointment of a tax representative in France.
Whether a move to the UAE qualifies for automatic deferral depends on the assistance agreements in force, so confirm your position with the tax office for non-residents before you leave.
When is the exit tax cancelled?
If you keep the shares, the deferred tax is cancelled (dégrèvement) two years after departure, or five years after departure if the value of your holdings exceeded EUR 2.57 million. If you sell the shares, receive certain distributions or transfer them during the deferral period, the deferred tax becomes payable. If you return to France, the tax can also be cancelled under conditions.
Forms and deadlines
- Form 2074-ETD: filed with your income tax return for the year of departure, declaring the latent gains.
- Form 2074-ETS: filed each year during the deferral period to report the status of the shares.
- Deferral request: where deferral is not automatic, request it before departure with the required guarantees.
Leaving France for Dubai: the broader picture
Exit tax is only one part of leaving France and moving to Dubai. Your French tax domicile is determined by your home and family, your main professional activity and the centre of your economic interests. If your family stays in France or your main business remains French, you may still be French tax resident. The France-UAE tax treaty includes rules to resolve dual residence, and a UAE Tax Residency Certificate from the Federal Tax Authority supports your position. For a comparison with other countries, see our European exit tax guide.
Leaving France with significant shareholdings?
We help you assess your exit tax exposure, prepare the deferral and plan your move to Dubai with the right timing.
Frequently asked questions
The French exit tax taxes unrealised gains on shares when you transfer your tax domicile abroad, provided you were French resident for six of the last ten years and hold shares worth at least EUR 800,000 or 50% of a company’s profits.
For 2026 departures, latent gains are generally taxed at the flat tax of 31.4%, made up of 12.8% income tax and 18.6% social charges. You can opt for the progressive income tax scale instead.
Exit tax applies if your shares and similar securities are worth at least EUR 800,000 in total on the day before departure, or if you hold at least 50% of the profits of a company.
Yes. Deferral is automatic for destinations with the required assistance agreements with France; otherwise you can request it, usually with guarantees and a French tax representative. Check the status for the UAE before leaving.
If you keep the shares, the deferred tax is cancelled two years after departure, or five years after departure if your holdings exceeded EUR 2.57 million.
Declare the latent gains on form 2074-ETD with your income tax return for the year of departure, and file form 2074-ETS each year during the deferral period.
If you sell the shares during the deferral period, the deferred exit tax becomes payable. Gains after departure may then be taxed according to the France-UAE tax treaty and UAE rules.
You must move your home and family, your main professional activity and the centre of your economic interests out of France. The France-UAE treaty helps resolve cases where both countries consider you resident.
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Disclaimer: This article provides general information only and is not tax advice. French exit tax rules are complex; consult a qualified French tax adviser before leaving.