Form 2074-ETD: Step-by-Step Guide

The Initial 2074-ETD Return

Form 2074-ETD is the reference return for the expatriate taxpayer for exit tax purposes. It is filed in the year following the transfer of tax domicile out of France, in addition to the income tax return for the year of departure. Its quality conditions the validity of the deferral and the subsequent reporting and relief procedure.

Filing Calendar

The 2074-ETD is filed according to the schedule for the income tax return:

• For a transfer in year N, filing in May of year N+1, together with returns 2042 and 2042 C covering the income of the year of departure, with the individual tax office (SIP) on which the taxpayer's domicile depended before the transfer.
• Deadline aligned with the non-residents' income tax return (a single date whatever the place of residence: in 2026, 21 May for the online return, 19 May for the paper format).
• Forms 2074-ETD and 2074-ETS can only be submitted to the tax administration in paper format: they are made available on impots.gouv.fr but cannot be filed online.
• Where the on-election deferral is sought, a first filing of Form 2074-ETD together with the guarantee proposal is made with the non-residents' tax office no later than 90 days before the transfer (Article 41 tervicies A of Annex III to the CGI); a second, identical filing bearing the words "Deuxième dépôt dans le cas du sursis sur option" is made the following year with the income tax return.

Content of the 2074-ETD

The return sets out, line by line:

1. Taxpayer identification: surname, first name, former domicile in France, new domicile abroad, date of transfer.
2. Inventory of securities: ISIN or company identification, type of security, number, acquisition date, unit acquisition price, fair market value on the date of transfer.
3. Calculation of the unrealized gain per line and in aggregate.
4. Earn-out receivables arising from prior transactions, estimated value.
5. Deferred capital gains within the meaning of article 150-0 B ter, amount previously deferred.
6. Computation of the tax under the applicable regime (flat tax or election for the progressive scale).
7. Deferral status: box A (automatic deferral under IV), box B (on-election deferral under V) or box C (no deferral), and, where applicable, box D (global election for the progressive scale).
8. Appointment of the fiscal representative in France (section V only).
9. Reference to the guarantees previously offered (section V only).

Supporting Documents to Attach

• Detailed portfolio inventory (bank statements from the end of the previous year and as of the date of transfer).
• Valuation reports for unlisted securities.
• Articles of association of the unlisted companies held.
• Evidence of acquisition prices (notarized deeds, bank certificates).
• Written acceptance from the fiscal representative.
• Evidence of the guarantees accepted by the tax authorities.
• Evidence of the new address abroad (residence certificate, lease, utility bills).

Mistakes to Avoid on the 2074-ETD

• Omitting a security line or an indirect holding (securities held through an interposed company).
• Confusion between tax cost basis and accounting cost basis.
• Obvious undervaluation of unlisted securities (administrative reassessment is almost systematic).
• Forgetting deferred gains (article 150-0 B ter) arising from prior contributions.
• Failure to appoint a fiscal representative when section V applies.
• Missing supporting documents, which delays processing and exposes the taxpayer to denial of the deferral.

2074-ETS Follow-Up: Annual or Event-Triggered

Once the 2074-ETD has been filed and the deferral granted, the applicable form and frequency depend on the transfer date and the category of gain. For transfers from 1 January 2019, a deferral covering only unrealised gains is event-triggered rather than annual. Annual filing can remain necessary for instalment-price receivables, gains already under deferral, mixed cases and certain earlier transfers.

• 2074-ETS1: transfers effected between 3 March 2011 and 31 December 2012.
• 2074-ETS2: transfers effected in 2013.
• 2074-ETS3: transfers effected since 1 January 2014.
• 2074-ETSL: simplified follow-up return, whatever the date of transfer, reserved for taxpayers benefiting from a full payment deferral who have realised no event terminating the deferral or giving rise to relief during the year.

Follow-up returns are sent to the non-residents' tax office (Direction des impôts des non-résidents, 10 rue du Centre, TSA 10010, 93465 Noisy-le-Grand Cedex, France), together with returns 2042 and 2042 C. Since 2019, a taxpayer whose deferral — automatic or on election — covers only unrealised gains is exempt from annual filing: a 2074-ETS is filed only upon an event terminating the deferral or giving rise to relief.