French exit tax lawyer for article 167 bis CGI
A focused page for non-French and bilingual searches about French exit tax, Form 2074-ETD and relocation from France to Dubai.
French exit tax before leaving France
French exit tax is not a Dubai tax. It is a French tax mechanism triggered by the transfer of tax residence outside France when the conditions of article 167 bis CGI are met. The analysis must be performed before departure where payment deferral on option may be relevant.
Covered assets
Shareholdings, securities, certain deferred gains and earn-out receivables require specific review.
Form 2074-ETD
The filing timeline depends on the deferral regime. For payment deferral on option, the first Form 2074-ETD filing is due no later than 90 days before the transfer.
Dubai context
Dubai residence and UAE tax certificates are evidence points, but do not mechanically displace the separate French tax residence analysis under article 4 B CGI and the France-UAE tax treaty.
Tax precision
French exit tax under article 167 bis CGI is not triggered merely because a person owns assets. The taxpayer must have been French tax resident for at least six of the ten years preceding the transfer, and the relevant assets must be qualified. For latent gains on shares, securities or rights, the 50% company profit-rights threshold or the EUR 800,000 global value threshold must be checked. Earn-out receivables and deferred gains follow their own analysis.
For Dubai departures, UAE residence evidence is useful but does not by itself displace French rules. Where payment deferral on option is relevant, the pre-departure Form 2074-ETD timing — no later than 90 days before the transfer — must be checked.