Until now, anyone leaving France generally assumed that their unlimited tax liability would end upon departure, provided their centre of life was clearly and properly moved abroad. That core principle remains. However, with the 2026 Finance Act, France has introduced a new tax rule that affects particularly high incomes and, for the first time, explicitly links taxation to French nationality.
In doing so, France moves a step towards a form of "universal taxation" previously associated mainly with the United States—albeit far more limited and narrowly targeted at very high incomes.
The question now is: who is affected, and what really applies after leaving?
As part of the Projet de loi de finances pour 2026, an addition to Article 4 bis of the Code général des impôts was adopted. It provides that, under certain conditions, French nationals may continue to be brought within the French tax net for a period of ten years after leaving France.
The rule applies only if several conditions are met at the same time:
French nationality
at least three years of tax residence in France within the last ten years before departure
moving to a state where taxation is more than 40% lower than the French level
income above five times the annual social security ceiling (currently over €230,000 per year)
Crucially, the taxation applies only to the portion of income above that threshold. It is therefore explicitly not a general nationality-based tax for all French people living abroad.
In addition, a credit for tax paid in the country of residence is предусмотрено. The intention is not to create classic double taxation, but rather a kind of top-up tax to the French level.
No. France is not introducing a full citizenship-based taxation system.
Whereas the United States generally taxes all citizens regardless of where they live, the French model is:
income-dependent
limited in time to ten years
restricted to low-tax states
applicable only to high earners
It is a targeted measure to combat "exil fiscal"—that is, tax-motivated relocations by very wealthy individuals.
The new rule does not replace the existing Exit Tax.
The Exit Tax continues to apply to substantial shareholdings or large securities portfolios, where latent gains are deemed and taxed upon departure. It concerns assets.
By contrast, the new rule in France’s 2026 Finance Act concerns ongoing income—such as employment income, investment income or property income—above the stated threshold.
In theory, both regimes can apply side by side, but they relate to different tax matters.
The new rule targets states where taxation is more than 40% lower than the French level.
This is not a fixed list of countries; it is determined by a comparative calculation based on the effective taxation of:
employment income
investment income
property income
Whether a country falls within scope therefore depends on its specific tax profile. Typically, the focus is on classic low-tax jurisdictions or states without income tax.
Within the EU, application is likely to be limited in many cases by double taxation agreements.
For the vast majority of French nationals abroad, the new rule changes virtually nothing in practice. The nationality-based taxation adopted in the 2026 Finance Act is expressly income-based and requires several cumulative conditions.
Anyone who remains below the relevant income threshold, does not move to a state with markedly lower taxation, or does not meet the timing requirements for residence will not fall under this new provision.
In such cases, the classic system of limited tax liability continues to apply. This means only France-source income is taxed, such as rental income from property located in France or certain investment returns from French sources.
French nationality on its own does not trigger any additional tax liability for average levels of income.
The political intent of the new rule is clearly aimed at very high incomes. It is intended to capture, in particular, cases where substantial income is shifted to states with a significantly lower tax burden.
For typical employees, pensioners or business owners with moderate income, the existing system largely remains in place.
The political direction is plainly aimed at very high incomes.
Regardless of the newly introduced nationality-based taxation, the existing tax instruments remain fully in force. This includes, in particular, the Exit Tax, which applies to substantial shareholdings and captures latent increases in value at the time of departure. This rule still concerns assets, not ongoing income.
Likewise, the taxation of French-source income remains unaffected. Anyone who continues to let property in France after leaving, or holds interests in French companies, may still be subject to French taxation.
The same applies to the real estate wealth tax (IFI) if net real estate assets located in France exceed the statutory threshold.
Inheritance and gift tax also continue to include connecting factors to former residence or to assets situated in France.
The new rule does not replace these mechanisms; it merely supplements them. It adds another building block to the existing system, tailored specifically to certain high-earner scenarios.
The explanatory statement for the relevant amendment makes it clear that the measure is primarily intended to combat tax-motivated relocations.
The legislature cites the aim of curbing tax flight, preventing so-called "dumping fiscal" and strengthening France’s tax sovereignty. Under this logic, very high earners should not be able to escape the French level of taxation simply by changing residence.
At the same time, the political debate emphasises that the rule should remain compatible with existing double taxation agreements and should not create a full double burden.
The introduction of this targeted nationality-based taxation therefore fits into a broader European debate, where there is increasing discussion of whether—and how—states can tax very high incomes even after a relocation of residence.
In practice, this means: while little changes for most French people abroad, the need for planning and review rises sharply for very wealthy nationals.
For very wealthy French nationals planning to move their residence to low-tax states, tax planning becomes significantly more complex.
In particular, the following should be reviewed:
the level of future income
the destination state and its effective tax burden
the length of prior residence in France
possible crediting of foreign taxes
interactions with the Exit Tax
For very high incomes, simply leaving may no longer be sufficient to fully remove oneself from France’s taxing reach.
France is not introducing a blanket tax on all citizens living abroad.
However, the 2026 Finance Act has adopted a targeted, income-based nationality tax for very high incomes. It applies for ten years after departure and affects only cases involving substantial income and relocation to states with significantly lower taxation.
For ordinary emigrants, little changes. For high earners, however, the need for tax review increases considerably.
Anyone who, as a French national, is planning to leave or is already living abroad and falls within the income groups mentioned should analyse their individual situation carefully.
We are happy to help you review your personal position in a structured way and develop a legally robust strategy for the period after departure.
