French tax lawyer for Dubai relocation and French exit tax
Jonathan Sémon advises on French tax issues for individuals relocating from France to Dubai, including French exit tax, Form 2074-ETD and France-UAE residence matters.
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.
French tax advice for Dubai relocation
This page is designed for founders, executives, investors and families leaving France for Dubai who need French tax analysis, not only UAE tax registration. The main issues are French tax residence, French exit tax, Form 2074-ETD, French-source income, France-UAE treaty analysis and post-departure documentation.
French exit tax
Article 167 bis CGI may apply to certain shareholdings, securities, deferred gains and earn-out receivables at the time of departure.
France-UAE residence
UAE tax residence evidence is useful, but it does not replace the French factual residence test or treaty analysis.
Substance and control
Where companies remain connected to France, permanent establishment, effective management, article 155 A CGI and anti-abuse risks must be reviewed.
Tax precision
French tax advice for Dubai relocation must start with French domestic law. Article 4 B CGI, article 167 bis CGI, French-source income rules, the France-UAE treaty and post-departure documentation must be analysed together. UAE tax residence evidence, including a UAE tax residency certificate, is evidence but not an automatic shield against French tax residence or French exit tax analysis.
Where a company remains connected to France, permanent establishment, effective management, article 155 A CGI and anti-abuse risks must be reviewed separately from UAE Corporate Tax registration or Free Zone treatment.