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.<\/p>\n\n\n\n
This is a highly symbolic measure, which reopens the debate on the balance between tax fairness and economic attractiveness.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
Eased in 2019 by \u00c9douard 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.<\/p>\n\n\n\n
The amendment tabled by Jean-Philippe Tanguy (RN) was adopted by 70 votes to 55, with 9 abstentions (LCP, 03\/11\/2025\ufffc).<\/p>\n\n\n\n
The text provides for a return to the \u00aboriginal\u00bb version of the system:<\/p>\n\n\n\n
- a 15-year period before the tax deferral lapses; ;<\/p>\n\n\n\n
- immediate taxation of unrealized capital gains when the tax domicile is transferred; ;<\/p>\n\n\n\n
- and the possibility of a refund if the taxpayer proves that he has not sold his shares during this period.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
For Jean-Philippe Tanguy, the return of the exit tax is intended to restore tax fairness:<\/p>\n\n\n\n
\u00ab 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.<\/em> \u00bb (statement reported by LCP, 03\/11\/2025<\/a>)<\/p>\n\n\n\n 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.<\/p>\n\n\n\n In his view, the measure is not aimed at entrepreneurs or expatriate executives, but at the \u00abultra-rich\u00bb seeking to avoid capital gains tax.<\/p>\n\n\n\n On the government side, there are many reservations.<\/p>\n\n\n\n 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.<\/p>\n\n\n\nBetween attractiveness and tax control<\/h3>\n\n\n\n