Creation of the 'exit tax' on unrealised capital gains when the tax residence is moved outside France

Article 48 of the amending finance act of 29 July 2011 reinstates Article 167 bis of the General Tax Code. Taxpayers resident in France for at least six of the ten years before leaving are taxable, when they move their tax residence outside France, on unrealised gains on shareholdings where their household holds at least 1% of a company's profits or a stake worth more than €1.3 million, and on certain earn-out receivables. Payment is automatically deferred for departures to a European Union or European Economic Area state, and the tax is cancelled if the shares are held for eight years. The scheme applies to transfers from 3 March 2011. It was eased in 2019.