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Andorimo, real estate and company formation in Andorra

Leaving France for Tax Purposes for Andorra: Tax Residence

The short answer

For France, you are tax resident there as soon as any one of these three criteria is met: home or main place of stay, main professional activity, or centre of economic interests. Leaving France for tax purposes requires getting out of all three.

The three criteria of French law

The General Tax Code uses three criteria (article 4 B). Meeting just one is enough to be considered tax resident in France:

  1. The home or main place of stay: where does your family live? where do you spend most of the year?
  2. The professional activity carried out in France, unless it is ancillary.
  3. The centre of economic interests: where are your investments, the seat of your business, the main source of your income?

What makes a departure fail

SituationRisk
Spouse and children stay in FranceHome in France
Director of a French SARL who keeps working thereProfessional activity in France
Assets and income mainly FrenchCentre of economic interests in France
French home kept, often occupiedMain place of stay challenged

What to prepare

  • Consistency of real life: housing in Andorra, schooling, doctor, accounts, subscriptions.
  • Proof of presence: travel records, invoices, contracts.
  • Treatment of shareholdings: the exit tax may apply above a threshold: 800,000 €verified on 09/10/2026.
  • Returns: declaring the departure and the income of the year of departure.

Company regimes to know

A foreign company held by a French resident may be subject to anti-avoidance rules (privileged tax regimes). See dividends from an Andorran company.

Our advice

A departure is prepared several months in advance with a tax lawyer who knows both systems. See lawyers and gestorias.

Work out your own case

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Frequently asked questions

What are the criteria for French tax residence?

Three alternative criteria: the home or main place of stay, the main professional activity, the centre of economic interests. Just one is enough to be resident in France.

How many days must you spend outside France?

French law does not rest solely on a number of days. The length of stay is one indicator among others. The benchmark threshold shown on our effective presence page is indicative.

What is the exit tax?

A mechanism targeting unrealised capital gains on certain shareholdings when tax residence is transferred out of France, subject to threshold conditions. It may concern company directors.

Can the tax authorities challenge a departure?

Yes. They examine whether the departure is genuine: housing, family, children's schooling, activity, accounts. A sham departure exposes you to a tax reassessment.

What should you do with your main residence in France?

Keeping it does not necessarily prevent the departure, but it is an indication that the home remains in France. Each situation must be analysed.

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.

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