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French Exit Tax Simulator 2026

Estimate your exposure to the French exit tax (article 167 bis of the French Tax Code) for a transfer of tax residence to the United Arab Emirates. The calculation reflects the 12.8% flat income tax, the 18.6% social contributions in effect since the 2026 Social Security Financing Act, and the applicable payment deferral regime.

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Methodology

This tool produces an initial indicative estimate based on your inputs. It does not replace a personalized audit. For a binding calculation accounting for holding-period allowances, deferred capital gains (article 150-0 B ter CGI), earn-out receivables, the exceptional contribution on high incomes (Article 223 sexies of the CGI), and available elections (flat tax vs. progressive scale), a full audit is required.

1. Your inputs

Price paid upon acquisition, plus related costs and contributions incorporated into capital.
Estimated fair market value at the planned transfer date, ideally supported by a valuation report for unlisted shares.
The 6-out-of-10-years test determines whether the exit tax applies.
Percentage of capital or corporate profits. Threshold for application: 50% ownership OR EUR 800,000 in aggregate value.
The flat tax is the default regime. The election for the progressive scale is global and is only worthwhile where holding-period allowances apply.
Determines the applicable payment deferral regime.

Sources & case law

References current as at the date of last revision, cited for information only. Any application to a particular situation requires an individualised analysis.

Legislation

  • Article 167 bis CGI (exit tax, transfers since 3 March 2011); Article 238-0 A CGI (non-cooperative States list); Articles 91 undecies to 91 quaterdecies of Annex II to the CGI.
  • Décret n° 2019-868 of 21 August 2019 (on-election deferral, proposal of guarantees).

Administrative doctrine (BOFiP)

Case law

  • CE, 9th–10th Ch., 15 December 2025, No. 495783 — the deferral suspends the limitation period for recovery; a reporting failure restores immediate enforceability only after an unanswered formal notice to regularise.
  • CE, 5 February 2025, No. 476399 — limits on the retroactivity of the exit tax under EU law.
  • ECJ, 11 March 2004, de Lasteyrie du Saillant, C-9/02; CE, 10 November 2004, No. 211341; CE, 29 April 2013, No. 357576; CE, 20 May 2022, No. 449038.

Further reading

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