On Monday November 3, 2025, as part of the 2026 Finance Bill, the French National Assembly voted in favor of an amendment tabled by Jean-Philippe Tanguy (Rassemblement national) aimed at reinstating the exit tax in its original 2011 version.

This is a highly symbolic measure, which reopens the debate on the balance between tax fairness and economic attractiveness.

What is the exit tax?

Created in 2011 under the presidency of Nicolas Sarkozy, the exit tax was designed to prevent wealthy taxpayers from transferring their tax residence outside France to avoid paying tax on the unrealized capital gains on their shares or holdings.

To put it plainly: when a taxpayer left France, the value of his or her shares was treated as if they had been sold, and the corresponding capital gain became taxable.

Eased in 2019 by Édouard Philippe's government, the measure had lost its scope: the holding period to be exempt was reduced from 15 years to 2 or 5 years, depending on the amount of assets. The stated aim at the time was to make France more attractive in the face of European tax competition.

The vote on November 3, 2025

The amendment tabled by Jean-Philippe Tanguy (RN) was adopted by 70 votes to 55, with 9 abstentions (LCP, 03/11/2025).

The text provides for a return to the «original» version of the system:

- a 15-year period before the tax deferral lapses; ;

- immediate taxation of unrealized capital gains when the tax domicile is transferred; ;

- and the possibility of a refund if the taxpayer proves that he has not sold his shares during this period.

The adoption of this amendment came as a surprise: it was an opposition initiative, put forward by a member of the Rassemblement National party, which rallied a number of elected representatives from other groups keen to step up the fight against tax evasion.

Rassemblement National's motivations

For Jean-Philippe Tanguy, the return of the exit tax is intended to restore tax fairness:

« It's not right that some people should be able to avoid paying tax by transferring their tax residence a few weeks before selling their shares. » (statement reported by LCP, 03/11/2025)

The elected official believes that the partial abolition in 2019 has created a loophole, benefiting those with sufficient financial means to move their assets abroad.

In his view, the measure is not aimed at entrepreneurs or expatriate executives, but at the «ultra-rich» seeking to avoid capital gains tax.

Between attractiveness and tax control

On the government side, there are many reservations.

The French Minister for the Economy, Roland Lescure, pointed out that the initial system had been criticized for its administrative complexity and negative impact on investment.

« We need to strike a balance between the necessary fight against tax evasion and preserving the attractiveness of our economy. » (TF1 Info, 03/11/2025)

Business circles fear that too strict a return to the exit tax would discourage foreign managers from setting up in France, or accelerate the relocation of entrepreneurial fortunes.

Conversely, several members of the majority recognize that the amendment raises a legitimate question of tax justice.

An uncertain budgetary impact

No precise estimate of the expected budgetary return has yet been communicated.

In its original version, the measure brought in a few hundred million euros a year, but its application remained uncertain, depending on actual controlled departures and capital returns.

Today, the issue is above all symbolic: to give a political signal of firmness in the face of tax evasion, at a time when the government is looking for new revenue margins to contain the public deficit.

Scope still uncertain

The November 3 vote does not guarantee the final entry into force of the scheme. The amendment still has to pass through the Senate, before being confirmed in the final reading of the budget. As LCP points out, «we'll have to wait for the final copy of the finance bill to know whether this provision will be maintained».

In other words, the political battle has only just begun.

Analysis: a political signal rather than a fiscal turning point

The return of the exit tax comes in a tense budgetary climate.

While this measure is unlikely to upset government revenues, it does confirm a trend: tax mobility has once again become a central issue in the French debate.

Between those who advocate a more competitive France and those who defend a fairer tax system, the divide is taking root.

The question is no longer just how much to pay, but where and why.

In conclusion: anticipate, structure, protect

The return of the exit tax - however partial or symbolic - marks a turning point for all those considering international mobility, tax expatriation or the future sale of their company.

At WizeCounsel, We analyze these developments in real time to help managers, investors and entrepreneurs anticipate tax reforms and structure their assets in compliance with international law.

The aim is not to flee, but to anticipate. Because a well-thought-out strategy today is better than a hasty reaction tomorrow.