How to leave France tax residency, legally

France doesn’t catch you on a day count alone. It uses the foyer test first: if your household — the home where your family normally lives — is in France, you can be a French tax resident however many days you spent in Paris, Bangkok or Buenos Aires that year. That single structural difference makes the French exit harder than most, and it explains why founders who’ve planned their move perfectly on paper are still paying French tax a year after boarding the plane.

This is the version we run with members going from France to Thailand or Paraguay. It assumes a clean foyer situation and a complete professional deregistration — the two places where French exits slip.

The residency test that isn’t the 183-day rule

Article 4 B of the Code Général des Impôts (CGI) makes you a French tax resident if any one of three conditions is met:

1. Foyer or main place of stay — your foyer is where you and your family (spouse, dependent children) normally live, even if work takes you elsewhere. If you have no foyer, the test is your main place of stay, and more than six months in France in a year counts.
2. Professional activity — you work in France, salaried or not, unless you show that work is only secondary.
3. Centre of economic interests — where your main investments, the base of your business or most of your income is.

Any single condition is sufficient. You can spend 60 days in France, have no apartment, have a Spanish bank account — and if your spouse and children are in a Paris flat you pay the rent on, France treats you as resident. Full French income tax. On worldwide income. Where your new country also treats you as resident, the tax treaty’s tie-breaker rules settle it.

The practical consequence: founders who move alone while their family stays in France have not cleanly exited French tax residency. They have created a compliance problem in two jurisdictions at once. This is the first question we ask on every diagnosis call: what is the foyer situation?

Three professional tracks

French professional deregistration depends on your legal structure. Each has a different sequence and different timing.

Micro-entrepreneur (auto-entrepreneur): Declare the cessation on the business formalities one-stop portal, formalites.entreprises.gouv.fr, within 30 days of stopping; it passes the information to URSSAF, the tax office and INSEE. Then file your last turnover declaration and pay your final contributions on autoentrepreneur.urssaf.fr — within 30 days if you declare monthly, or in the month after the quarter if you declare quarterly — and file a 2042-C PRO with your turnover from 1 January to the closing date within 60 days. The CFE (Cotisation Foncière des Entreprises) stays due for the whole year you stop, but you can claim back the months after closure through your business tax office (SIE) once the notice is issued.

Profession libérale: Your pension fund depends on your profession. Regulated professions in a CnavPL section (such as CARPIMKO) or the CNBF deal with that fund; Cipav members have paid all their contributions to URSSAF since 1 January 2023; non-regulated professions sit in the general self-employed scheme, with URSSAF and the Carsat. The cessation itself goes through the same one-stop portal.

SAS or SARL: The company does not close because you leave France. It remains a French legal entity, taxed under Impôt sur les Sociétés (IS), regardless of where the shareholders live. As a non-resident individual shareholder, you receive dividends net of a 12.8% French withholding tax, with no French social levies — 75% if paid into a non-cooperative state or territory. The France–Thailand treaty (signed 27 December 1974) does not reduce that for individuals: its dividend cap applies only to companies holding at least 25%. For founders with meaningful SAS equity, the pre-departure structuring question is often the most consequential part of the exit.

The exit tax (Article 167 bis CGI)

France’s exit tax fires when two conditions are met simultaneously:

Condition 1 — Residency duration: You’ve been a French tax resident for at least 6 of the 10 years before the move, counted from date to date.

Condition 2 — Asset threshold: On the day of the move, your household holds shares and similar securities worth more than €800,000 in total — OR securities representing at least 50% of the profits of one company. Shares in a PEA are left out.

If both conditions apply, France taxes the unrealised gains — plus earn-out claims and earlier gains whose tax was postponed — as if you had sold on the day you left. For departures in 2026 the rate is 31.4%: 12.8% income tax plus 18.6% social levies, the CSG on capital income having risen from 9.2% to 10.6% under article 12 of the LFSS 2026. For a 2025 departure the 2074-ETD notice still prints 17.2%, but that same article applies the rise “à compter de l’imposition des revenus de l’année 2025”, and exit-tax gains are L. 136-6 income — so expect an assessment at 18.6% and budget for it. You can elect the progressive income-tax scale instead if that produces a lower bill. Unrealised losses can’t be set against the gains.

Deferral isn’t the end of it. The tax is cancelled — or refunded if you paid it — if you still hold the shares 2 years after leaving, or 5 years if they were worth more than €2.57 million. A sale, a buyback or a cancellation of the shares before then makes the deferred tax due.

Form 2074-ETD is paper only. With automatic deferral, or without any deferral request, you file it the year after leaving, with your 2042 and 2042 C, at the tax office that handled your file before you left. If you ask for deferral, you file it twice: first at least 90 days before the move, at the non-residents’ tax office, with your offer of guarantees; then again the following year with your returns.

If your securities are worth €800,000 or less and hold under half of any company’s profits, or you’ve been French resident for fewer than 6 of the 10 years, Article 167 bis doesn’t apply. Most early-stage founders are out of scope; established operators with material equity positions need to model it before the departure date is set.

The deferral request — what nobody plans for

For Thailand or Paraguay exits, deferral is not automatic. The tax office’s own list of countries with both agreements, published with form 2074-ETD, names neither. To defer, three things have to be in place:

• Timing: the first 2074-ETD goes in at least 90 days before you move your tax home — article 41 tervicies A of annexe III to the CGI sets that as the latest date, and the offer of guarantees rides with it. Start the file a month later than that and the deferral is gone.
• Guarantees: you propose them in writing. For the income-tax part, they cover 12.8% of the gains; a bank guarantee is one way, not the only one.
• A tax representative in France, authorised to receive the tax office’s communications about the assessment, collection and any dispute.

We have seen members discover the 90-day rule in their last month in Paris. The fix: put the exit-tax check in the first weeks of the plan, not the last.

The departure sequence

The French exit doesn’t have a single trigger document. It’s a sequence:

1. Exit-tax check — if Article 167 bis applies and you are moving to Thailand or Paraguay, file the deferral request at least 90 days before the move.
2. Professional deregistration — the one-stop portal within 30 days of stopping, then final URSSAF declarations and the 2042-C PRO within 60 days.
3. Destination paperwork — DTV application or Paraguay cédula, bank account, real lease in your name.
4. Departure.
5. Tell the tax office your new address — online, from your espace Finances publiques or its secure messaging.
6. Departure-year returns, the following spring: a 2042 with your income from 1 January to your departure date, stating that date, and a 2042-NR for French-source income from then to 31 December. Add form 2074-ETD if the exit tax applies. There is no special 60-day deadline for leaving France.
7. Year +1: Thai Revenue Department or Paraguayan DNIT tax-residency certificate. From then on, the non-residents’ tax office takes over your file without any step on your part.

A 16-to-18-week timeline

Most CERØ members run roughly this calendar from engagement to clean French exit:

• Week 1. Diagnosis call. We map the foyer, professional structure, Article 167 bis exposure and the timing.
• Weeks 2–4. Exit-tax check. If deferral is needed for Thailand or Paraguay, the 2074-ETD, guarantees and tax representative are prepared — the move must be at least 90 days after filing.
• Weeks 4–8. Destination visa. DTV file or cédula application. Thai or Paraguayan bank account. Real lease signed.
• Weeks 16–18. Departure, new address given to the tax office, professional cessation on the one-stop portal.
• Following spring. Departure-year returns: 2042 up to the departure date, 2042-NR after it, and 2074-ETD if it applies.
• Year +1. Thai or Paraguayan residency certificate — the evidence of your new residence.

What the DGFIP actually checks

The Direction Générale des Finances Publiques doesn’t just take your word for departure. In a France exit under examination, the questions follow Article 4 B:

• Whether the foyer actually moved — did the family leave France?
• Whether you still stay in France more than you stay anywhere else.
• Whether professional activity in France stopped, or is at most secondary.
• Whether your centre of economic interests moved with you.
• Whether you hold a genuine, signed lease at the destination, and a foreign tax-residency certificate in the year following departure.

The weak file: founder left for Bangkok, spouse stayed in Paris, car registered in France, income still paid to a French account. France has every reason to treat them as resident after departure.

The strong file: foyer moved. Business cessation filed. Bangkok lease signed. Thai certificate in year +1. The DGFIP has little to examine.

The piece nobody tells you

France and Thailand have a double taxation treaty in force since 1975, amended by the multilateral instrument from 2023. It settles which country taxes what once you are resident in Thailand, and resolves dual residence in the transition year. But the first twelve months require documentation, because that’s when most examinations focus.

The SAS dividend situation is the other piece that surprises founders. A French company paying dividends to a Thai-resident individual withholds 12.8%, and the treaty does not lower that for individuals. Founders who planned to draw income from their French company while living in Bangkok often end up paying more than they expected — just structured differently. Pre-departure restructuring changes this; post-departure restructuring from Thailand is harder.

Where to go from here

If you want the destination numbers first, run the Thailand tax calculator to estimate what changes once the French effective rate stops applying. Or read the Thailand vs France comparison for the side-by-side, and the EU exit tax cheatsheet for the eight-jurisdiction comparison, France included.

If you already know the move is happening and want the free diagnosis call, book it here. We’ll tell you on the call whether the foyer situation is clean, what Article 167 bis exposure looks like on your numbers, and the realistic calendar from your starting point.