Expertise Exit tax (167 bis CGI) UAE tax residence Corporate Tax UAE France-UAE tax treaty Company formation Tax expatriation French impatriate regime Dubai real estate
Tools Impatriate HR pack Exit tax simulator UAE residence test 12-month checklist (PDF) Free zone comparator Impatriate eligibility test
Insights All articles Universal tax (CF380) Exit tax 2026 Press
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France · United Arab Emirates

International tax strategy, structured from Dubai.

GEOTAX advises entrepreneurs, investors and families on tax structuring, compliance and optimization between France, the United Arab Emirates and beyond.

Schedule a consultation Discover our expertise
Paris Bar Attorney Based in Dubai since 2024 90+ UAE tax treaties
90+
UAE tax treaties
0%
UAE personal income tax
9%
Corporate Tax > AED 375k
2024
Firm founded
Our Expertise

Complete tax expertise, from Paris to Dubai

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04 · Free Zone Company Formation Free Zone or Mainland — legal and tax analysis 05 · Transfer Tax Expatriation Transferring tax residency from France to Dubai 06 · Treaty 1989 France-UAE Tax Treaty Double taxation, tax credit, treaty of 19 July 1989 07 · Real estate Real estate investment Dubai real estate taxation for French tax residents 08 · QFZP UAE Free Zones QFZP status, qualifying activities, de minimis rule
Situations

Support tailored to your situation

Entrepreneur / Executive

You are creating or transferring your business to Dubai. Structuring, licensing, visa, Corporate Tax.

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Investor / Family Office

You are structuring investments between France and the UAE. Real estate, holding, capital gains.

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Expat / New resident

You are leaving France for Dubai. Exit tax, tax residency, disclosure obligations.

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Returning to France

Impatriate regime: tax-exempt bonus, 50% relief on foreign passive income, 8-year window.

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International company

You are developing your operations in the UAE. Tax treaties, transfer pricing, VAT.

Consult

A specific situation?

A free 10-minute call to assess your needs.

Get in touch

Specific situations: US persons moving to the UAE · UK residents moving to the UAE · French expats returning from the UAE

Jonathan Sémon
The founder

Jonathan Sémon

Tax attorney at Paris Bar · Founder of GEOTAX

With a Master's degree in tax law, Jonathan Sémon has built rare expertise in international tax between France and the UAE. With nearly 20 years alongside major firms — CMS Francis Lefebvre and Gide Loyrette Nouel — he has handled the most complex tax structures.

In 2024 he founded GEOTAX and established his practice in Dubai to support French professionals relocating to the UAE, with personalized and agile international tax advisory.

2006CMS Francis Lefebvre
2008Gide Loyrette Nouel
2011SELAS Jonathan Sémon founded (Paris)
2024GEOTAX firm founded
2024Established in Dubai
Paris Bar Master's Tax Law France-UAE dual expertise
Our Approach

Rigorous methodology, single point of contact

1

Diagnostic

In-depth analysis of your tax, personal and legal situation. Identification of issues and risks.

2

Strategy

Development of a tailored tax strategy, compliant with French law, UAE law and international treaties.

3

Implementation

Document drafting, administrative procedures, coordination with authorities (FTA, DET, DGFIP).

4

Ongoing support

Continuous support, regulatory monitoring, annual tax filings, strategy adaptation.

GEOTAX Meeting
Insights

Analysis and insights on international tax law

View all articles →
Amendment I-CF380: a universal tax contrary to EU law and tax treaties
Exit tax

Amendment I-CF380: a universal tax contrary to EU law and tax treaties

Adopted in committee and rejected on the floor by a single vote, the "targeted universal tax" sought to tax expatriates' worldwide income for ten years.

23 October 2025 — updated June 2026
Exit Tax: You Cannot Outwait Recovery (CE 15 December 2025)
Exit tax

Exit Tax: You Cannot Outwait Recovery (CE 15 December 2025)

The Conseil d'État confirms that the payment deferral suspends the recovery limitation period.

7 June 2026
BSPCE and Exit Tax: Common Pitfalls for Startup Founders
Exit tax

BSPCE and Exit Tax: Common Pitfalls for Startup Founders

Acquisition price, exercise gain and the interaction with article 163 bis G CGI: a worked example before a move to Dubai.

7 May 2026

Real cases, measurable outcomes

Anonymized cases. Professional references available upon request, subject to client approval.

Case 1 · Exiting founder

SAS sale and relocation to Dubai

€8M valuation, sale planned within 18 months: audit at T-12, independent valuation report, payment deferral structured with a bank guarantee.

Deferral granted, departure on schedule, relief expected after 5 years.
— M. D., SAS founder · Paris → Dubai · 2024
Case 2 · Family Office

Wealth structuring France-UAE

24-month structuring plan, coordination with the notary and private banker, UAE QFZP holding company for new investments.

UAE residency secured, IFI optimized, succession prepared.
— L. family, entrepreneurs · Lyon → Dubai · 2023-2025
Case 3 · Investor

Securing tax residency

Ongoing French tax audit (ESFP): full evidentiary file, technical memorandum, negotiation with the audit office.

UAE residency recognized, audit closed without reassessment.
— T. B., senior executive · Dubai · 2025

Outcomes described are specific to each case and do not prejudge the outcome of other situations.

Frequently asked questions

Since June 2023, the United Arab Emirates has applied a 9% corporate income tax on annual profits exceeding AED 375,000. Free Zone companies may benefit from a 0% rate on their qualifying income if they meet the QFZP conditions. Otherwise (QFZP status not met or non-qualifying income), the standard 9% rate applies. We support you in optimizing the tax regime applicable to your structure.
The Tax Residency Certificate (TRC) is issued by the UAE tax authority (FTA) after meeting residency conditions. You must establish your physical residence in the UAE (housing), obtain a resident visa and register with the FTA. This certificate is essential to benefit from bilateral tax treaties and prove your status to France. GEOTAX guides you in obtaining and managing this critical document.
Yes, exit tax (article 167 bis of the French General Tax Code) applies to your transfer of tax residency to Dubai if you have been a French tax resident for at least six of the ten years preceding departure. This tax applies to unrealized capital gains on shares and securities at the time of departure, where you hold a stake of at least 50% or a portfolio exceeding €800,000. Its impact can be significant. Planning and anticipation are essential: payment deferral (automatic or upon election), guarantees, and relief after 2 or 5 years. GEOTAX implements strategies to minimize this cost and secure your transition.
A Free Zone is a defined economic area offering tax and regulatory advantages: exemption or reduced corporate income tax, no VAT on certain transactions, 100% foreign ownership allowed. Mainland (UAE general jurisdiction) subjects companies to standard tax (9%), now allows 100% foreign ownership for most activities (2021 reform, save for a few regulated activities), and applies standard VAT. The choice depends on your sector, clients and structure. GEOTAX analyzes the optimal regime based on your objectives.
This depends on the chosen regime. In Free Zones, you can own 100% of the capital without a local partner. On the Mainland, 100% foreign ownership is now the rule for most activities (2021 reform); only a few regulated or strategic activities still require an Emirati partner. It is crucial to analyze your sector before choosing a structure. GEOTAX clarifies these requirements and optimizes your registration.
Once tax resident in the UAE, your worldwide income falls under UAE taxation, not French. Thus, invoicing French clients does not, in principle, expose you to French income or corporate tax, provided you have established and maintained your tax residency in the UAE and do not have a permanent establishment or fixed base in France. However, France may scrutinize whether your transfer is genuine (French tax authority criteria). You must comply with your French reporting obligations (foreign accounts — forms 3916/3916 bis, French-source income); your UAE accounts are also reported to France under the CRS automatic exchange. GEOTAX secures your transition and manages formalities with both jurisdictions.
Forming a company in the UAE does not automatically grant residency. You must be a director or shareholder of the company to request a resident visa. Once you obtain the visa (usually via the company), you physically reside in the UAE and meet residency conditions. However, simply forming a company without physical residency does not make you a UAE tax resident. Taxation depends on objective criteria: primary residence, center of economic interests, etc. GEOTAX clarifies these distinctions and validates your tax status.
After expatriation, you must notify the DGFIP (French tax authority) of your change of residence and file, in the year following departure, a return covering your worldwide income up to the actual date of departure, then only your taxable French-source income after that date. As a non-resident, you remain subject to certain filing obligations in France for certain income (real estate, French-source income). Your UAE financial accounts are also automatically reported to France under the CRS. GEOTAX manages all your disclosure formalities with both jurisdictions.

Schedule a consultation with GEOTAX

Initial contact
10 minutes — assess your needs and point you in the right direction
Free
Video consultation
1 hour — in-depth analysis of your situation
2,000 AED
Office consultation
1 hour — in person at our Dubai office
2,500 AED
+971 55 659 4477 [email protected]

Response within 24 business hours · Covered by professional secrecy

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