Exit Tax: Company Directors and Shareholders Leaving France for Andorra
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- La rédaction
The short answer
The exit tax targets taxpayers who hold significant shareholdings and transfer their tax residence out of France. The value threshold is 800,000 €, or holding half of a company's profits. It mainly concerns directors and shareholders, and must be prepared before departure.
Who is affected
- Shareholders and partners who hold shareholdings whose overall value exceeds 800,000 €verified on 09/10/2026.
- Those who hold at least half of a company's profits, whatever the value.
- Directors who leave France while keeping their shares.
The principle
Departure is treated as a taxable event: the unrealised capital gain on shareholdings may be taxed on departure, with deferral or postponement arrangements under conditions. The rules are technical and have changed.
What to do
- Value your shareholdings before departure.
- Measure the potential tax and the deferral options.
- Compare with an alternative: transferring or selling your company.
- Have it validated by a tax lawyer before you move.
A snapshot at departure, not a tax on departure itself
The French exit tax targets the unrealised capital gain on shares at the time tax residence is transferred out of France. It applies if the overall value of the shareholdings exceeds 800,000 €verified on 09/10/2026, or if the taxpayer holds at least half of a company's profits, whatever the value.
A calculation example
A director holds 100% of a company valued at 1,200,000 euros, acquired for 200,000 euros. The unrealised capital gain is 1,000,000 euros: this is the base that may be subject to the exit tax on departure, subject to deferral or postponement arrangements.
Questions to settle before leaving
| Question | Why |
|---|---|
| What value for the shares? | Determines whether the threshold is exceeded and the unrealised capital gain |
| What deferral or postponement is possible? | Depends on the destination State and the conditions |
| Is a guarantee required? | May be required to obtain a deferral |
| What happens if I sell later? | The actual capital gain may change the tax due |
| Must I file a return every year? | Monitoring the deferral imposes obligations |
What we do not detail here
The arrangements for deferred payment, relief and guarantees depending on the destination country are technical and have changed: they are not detailed here for lack of a reviewed primary source. Have the value, the base and the applicable regime established by an adviser before any transfer. See also transferring your French SARL and leaving France.
Work out your own case
Free simulators, built on the official values of this page.
- Andorra IRPF simulator (employment, rental and savings income)Estimate your income tax with the tax-free minimum, the bonus relief and family allowances.Open
- Leaving France for Andorra: are you still a French tax resident?The three criteria for French tax residence, in a few questions.Open
- Quiz: which residency status in Andorra?A few questions, a clear lead towards the right status.Open
Frequently asked questions
Does the exit tax apply to all expatriates?
No, only to those who hold shareholdings above the value threshold, or at least half of a company's profits.
Can the exit tax be avoided?
Deferrals and postponements exist under conditions. They must be studied before departure.
Who advises on this subject?
A tax lawyer who specialises in departures of company directors.
Going further
Official sources
This information is general and is not personalised legal, tax or financial advice. It is verified as of the date shown and may change.