Leaving France for Dubai: the 90 day deadline that decides everything

France taxes you on the way out. That much most people know. What almost nobody knows before booking the flight is that the Emirates sit on the wrong side of a list, and that one detail turns a routine filing into a hard 90 day deadline with a cash cost attached.

The exit tax, and who it catches

The French exit tax lives in article 167 bis of the Code general des impots. It applies only when two conditions are met together:

1. You were tax resident in France for at least six of the ten years before you left, counted date to date.
2. On the day you left, your household held either a direct or indirect stake of at least 50 percent of the profit rights in a company, or a securities portfolio worth more than 800,000 euros.

If neither is true, the exit tax is not your problem.

What gets taxed is unrealised gains on securities, previously deferred gains, and receivables from earn-out clauses. Securities held in a PEA or PEA-PME are outside it. The rate has two parts, and the second one moved this year:

Component	Departure in 2025	Departure in 2026
Income tax, flat rate	12.8 %	12.8 %
Social charges	17.2 %	18.6 %
Combined	30.0 %	31.4 %

The list the Emirates are not on

There are two forms of payment deferral, and the difference decides whether this is an administrative step or a real bill. The automatic one applies when you move to an EU state, or to a third country that has signed with France both an agreement on administrative assistance against tax evasion and an agreement on assistance in the recovery of tax debts, and that is not on the list of non-cooperative states under article 238-0 A.

The official notice to form 2074-ETD names the qualifying third countries one by one. The list runs to more than seventy entries and includes the United Kingdom, the United States, Japan, India, Morocco, Turkey and Kuwait, the neighbour two hours up the Gulf.

The United Arab Emirates are not on it.

That is not an oversight. The France to UAE treaty contains an information exchange provision in article 21 A, but no article on assistance in recovery. One of the two required conditions is simply absent from the treaty text.

What that means: three hard conditions

Moving to Dubai leaves you with the deferral on request only, under three conditions that all have to be met before you go.

1. Form 2074-ETD must be filed in the 90 days before your departure, with the deferral requested explicitly on the form.
2. You must appoint a tax representative resident in France, a representant fiscal.
3. You must provide security worth 12.8 percent of the total unrealised gains and receivables, offered on plain paper to the Service des Impots des Particuliers Non-Residents at 10 rue du Centre, TSA 10010, 93465 Noisy-le-Grand Cedex. If you later elect for the progressive scale and the resulting tax is higher, a top-up security is due within one month of the assessment.

Miss the 90 days and the whole exit tax is payable immediately, in cash. This is the single most expensive date in the move, and it sits three months before the date most people are actually planning around.

While the deferral runs, a follow-up return 2074-ETS3 is due every year alongside forms 2042 and 2042 C. Fail to file it, and fail to put it right within 30 days of a reminder, and the deferred tax falls due at once.

When the tax finally goes away

The deferred tax is written off after a waiting period that depends on the size of the portfolio on the day you left:

Value of securities at departure	Period until write-off
Under 2.57 million euros	2 years
Over 2.57 million euros	5 years

The condition is that you still hold the securities at the end of the period. Selling them, having them redeemed or cancelled, or gifting them triggers the tax early. Gifting deserves a note of its own: for someone living in a country without the automatic deferral, which includes the UAE, a gift triggers the tax unless you can show it was not mainly tax motivated.

Coming back cancels it outright. Re-establishing French tax residency wipes the tax, or gets it refunded if already paid, as long as the securities are still held at that point.

The part France is genuinely good at

The France to UAE treaty, signed in Abu Dhabi on 19 July 1989 and in force since 1 July 1990, covers not just income tax and corporation tax but also wealth tax and inheritance tax. Very few treaties do.

Article 17 is the one that matters. Immovable property is taxable only where it sits, business assets only in the state of the permanent establishment, and all other movable property, expressly including securities and bank deposits, only in the state where the deceased was resident at the time of death.

For someone who dies as a UAE resident, France taxes the French property and the French business assets, and nothing else. The domestic rule in article 750 ter, which would otherwise pull in an estate where the heir has lived in France for six of the previous ten years, is displaced by the treaty for movable property.

Gifts are the exception, and it is a sharp one. Article 17 speaks only of estates. The treaty contains no equivalent article for lifetime gifts, so domestic article 750 ter applies to them in full, including the six-in-ten-years rule for a recipient living in France. If your plan involves passing assets on while you are alive rather than at death, that is a different and much less favourable regime.

If you keep a property in France

Rental income stays taxable in France, and two things stack on top of it.

• A minimum tax rate. Non-residents pay at least 20 percent on French income up to 29,579 euros and 30 percent above it. You can apply for the lower average rate of your worldwide income instead, but only by declaring and evidencing your entire global income.
• Social charges in full. 17.2 percent on unfurnished lettings, 18.6 percent on furnished ones. The exemption from CSG and CRDS is reserved for people covered by the compulsory scheme of an EEA state, Switzerland or the UK, and UAE residents are not in that group.

The property wealth tax IFI catches non-residents on French property above a net 1,300,000 euros on 1 January, subject to the narrow conditional exemption in article 16 A of the treaty. One small piece of good news sits in article 18 paragraph 3: UAE residents are exempt from French income tax on the notional rental value of a French home kept for their own use.

What this means in practice

France is not the hardest country in Europe to leave. Italy shifts the burden of proof onto you indefinitely, and Spain has a treaty that will not recognise you as a UAE resident at all. But France has the tightest calendar, and calendars are what people miss. The order that works:

1. Test yourself against the two conditions. Six of ten years, and either 50 percent of a company or 800,000 euros of securities. If you are clear of both, most of this article does not apply to you.
2. If you are caught, work backwards from the 90 day deadline, not forward from your moving date. The form, the representative and the security all have to be in place before that window closes.
3. Appoint the representant fiscal early. It is the step most likely to slip, because it needs a French professional who will actually take the role.
4. Separate estate planning from gift planning. The treaty is generous on death and silent on lifetime gifts, and the difference is worth real money.

The Dubai side of this is the straightforward half. A company, a residence visa, an Emirates ID, a corporate tax registration, each with a published fee and a known deadline. You can work those costs out yourself, line by line, in our company cost calculator, and the answer is usually smaller than the French side of the same move. If you are comparing jurisdictions, the equivalent picture for Britain is in leaving the UK for Dubai.

We handle the UAE half, the accounting, the tax registrations and the deadlines here. The French half belongs with a French adviser who has filed a 2074-ETD before, and it belongs there before the move rather than after it.

This article is part of a series comparing what leaving costs across fifteen countries. The overview, with a table of every exit charge and how long each tail runs, is in what leaving costs, by country.