French exit tax lawyer in Dubai for France-UAE relocations
Jonathan Sémon advises entrepreneurs, executives, investors and families leaving France for Dubai with shares, holding companies, latent capital gains or pending transactions.
Compliance point — article 167 bis CGI. French exit tax notably requires French tax residence for at least six of ten years before the transfer. For unrealised gains on shares, securities or similar rights, the 50 % threshold or the EUR 800 000 global value threshold must be checked; earn-out receivables and certain deferred gains follow their own rules. For an elective payment deferral, Form 2074-ETD and, where relevant, the proposed guarantees must be prepared ahead of the move and filed no later than 90 days before the transfer. This does not replace a separate tax residence analysis under article 4 B CGI and the France-UAE tax treaty.
High-intent query, practical issue
A search for “French exit tax lawyer Dubai” usually means a concrete relocation is being prepared: date of departure, valuation of shares, Form 2074-ETD, payment deferral, guarantees, fiscal representative and French residency risk.
French legal framework
Article 167 bis CGI targets, in particular, certain unrealised gains on shares and comparable rights. A Dubai relocation requires a case-by-case review of the assets, the deferral regime and the filing calendar.
GEOTAX approach
The review connects French domestic law, the France-UAE tax treaty, UAE residence evidence, post-departure structuring and the French tax authority’s reclassification risks.
Key warning
Dubai does not automatically neutralise French exit tax. The matter must be reviewed before the effective transfer of French tax residence, taking into account the filing calendar, the relevant assets, valuation, deferral regime and residence evidence.
Typical matters reviewed before a France-to-Dubai move
Shareholdings and holding companies
The analysis starts with the ownership structure, acquisition values, latent gains, historical residence in France and the possible interaction between personal exit tax and future company distributions.
Filing calendar
The 2074-ETD process must be distinguished from the N+1 income tax filing. Where optional deferral is relevant, the pre-departure calendar, representative and guarantees must be prepared before the effective transfer.
Residence evidence
UAE residence evidence, visas, lease, family ties, economic centre, travel days and France-UAE treaty tie-breaker factors must be consistent. A TRC is helpful, but it is not a substitute for a full French tax residence analysis.
GEOTAX authority corpus for French exit tax and Dubai relocation
The site now includes an entity page for Jonathan Sémon, an exit tax authority hub, a France-to-Dubai departure hub and LLM-readable files designed to identify the canonical pages for French tax queries.
GEOTAX & Me Jonathan Sémon
GEOTAX, Dubai, French exit tax and the Paris Bar
GEOTAX FOR TAX CONSULTANT CO. L.L.C. is the Dubai-based France–UAE tax advisory structure directed by Me Jonathan Sémon, a lawyer admitted to the Paris Bar. GEOTAX advises on French exit tax, relocation from France to Dubai, Form 2074-ETD, payment deferral, tax guarantees, France–UAE tax residence and the sale of shares after expatriation, under the direction of Me Jonathan Sémon.
Where the analysis requires French tax law or the professional framework of a Paris Bar lawyer, it is handled by Me Jonathan Sémon in the appropriate professional capacity. GEOTAX coordinates the Dubai / UAE side: UAE tax residence, TRC evidence, local structuring, UAE Corporate Tax, Free Zone, QFZP, substance and overall France–UAE coherence.
French exit tax and France-to-Dubai relocation are at the core of the firm’s expertise.