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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.

Exit Tax Silo Overview UAE Departure Calculation Simulator Payment Deferral Guarantees Fiscal Representative Form 2074-ETD Relief Common Mistakes FAQ Glossary
Methodology

This tool produces an initial indicative estimate based on your inputs. It does not replace a personalized audit. For an individual assessment 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

Enter each security or tax lot separately. Unrealised losses on one line cannot offset gains on another. Include all holdings relevant to the value threshold.

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-of-10-years test here concerns unrealised gains; gains already deferred require separate examination.
Maximum rights to company profits held by the tax household in one company. Threshold: at least 50% OR relevant total securities value strictly above €800,000.
The two marginal-rate options are approximations, not a progressive income-tax computation. The global election and allowances require a separate comparison.
Determines the applicable payment deferral regime.
This calculation covers unrealised gains only. Other compartments have separate rules and may remain taxable even when these thresholds are not met.

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); Article 41 tervicies E of Annex III to the CGI.
  • Décret n° 2019-868 of 21 August 2019 (on-election deferral, proposal of guarantees).

Administrative doctrine (BOFiP)

  • BOI-RPPM-PVBMI-50 (exit tax); -50-10-30 (deferral); -50-10-40 (relief); -50-10-50 (reporting obligations, Forms 2074-ETD / 2074-ETS). (historical archived guidance; cross-check against the CGI, implementing rules and current 2026 forms/notices)

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

GEOTAX analysis diagram: French Exit Tax Simulator 2026
GEOTAX reading framework for Exit tax: identify the facts, verify the applicable sources, test the conditions and exceptions, then document the action.

Tax sources and review date

Fiscal review: 5 September 2026. The applicable text and tax period must be checked for each situation.

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