15 expert analyses by Jonathan Sémon, Paris Bar Tax Attorney, on France-UAE international tax matters: expatriation, exit tax, tax residence, UAE Corporate Tax, tax treaties, holding structures.
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French departure rules
9% standard rate explained
Key treaty provisions
Setup in UAE
Adopted in committee and rejected on the floor by a single vote, the "targeted universal tax" sought to tax expatriates' worldwide income for ten years after their departure from France. Legal analysis: TFEU freedoms of movement, CJEU case law, OECD model treaties.
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The payment deferral suspends the recovery limitation period; a reporting failure counts only after formal notice. CE 15 Dec 2025, No. 495783.
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Acquisition price, exercise gain, interaction with article 163 bis G CGI: a worked example for a founder exercising BSPCE before Dubai.
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Optional deferral: who can act as fiscal representative, duties, indicative cost (EUR 1,500-15,000/year) and appointment procedure.
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Automatic deferral (paragraph IV) vs optional deferral (paragraph V) of article 167 bis CGI: why a move to Dubai falls under paragraph V.
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FTA registration deadlines, filing errors, QFZP confusion, penalties: the most common UAE Corporate Tax registration mistakes.
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Combine Free Zone (0% QFZP) and Mainland licences under one entity, under strict compliance conditions: a structuring guide.
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QFZP regime, real substance requirements, dividend flows, transfer pricing compliance: how to structure a Dubai holding company.
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Acquisition costs, rental income, capital gains, IFI and Articles 5 and 11 of the France-UAE treaty for French investors in Dubai.
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French exit tax (Article 167 bis CGI) for residents relocating to the UAE: scope, calculation, deferral conditions, Form 2074-ETD.
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ESFP procedure, taxpayer rights, defense strategies and negotiation under French tax law for expatriates audited from Dubai.
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How French tax authorities detect fake UAE residents: information exchange (art. 21 A), CRS data and social media analysis.
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Public pensions, information exchange, real estate income, anti-abuse rules: five overlooked treaty articles affecting expatriates.
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UAE Free Zone 0% corporate tax: qualifying activities, de minimis rule, Cabinet Decision 100/2023 and the real limits of QFZP status.
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Fake residency, missed Corporate Tax registration, neglected exit tax: the most common tax mistakes by French expats in Dubai.
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A 10-year universal tax on expatriates, rejected by one vote on 25 October 2025. Analysis: TFEU, CJEU case law, OECD model treaties.
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