France – 2026 Finance Bill: The General Assembly votes for a major reform of the exit tax and French expatriates
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2026 Finance Bill: the National Assembly adopts a major reform of the Exit Tax
The examination of the finance bill for 2026 introduces a significant change in the Exit Tax regime, with the adoption of amendment no. I-807. This measure deepens the modification of Article 167 bis of the General Tax Code and marks a turning point for international taxation, particularly for taxpayers considering expatriation and holding significant unrealized capital gains.
Why is the Exit Tax regime being tightened?
The authors of the amendment consider that the lightened regime resulting from 2019 has reduced the effectiveness of the Exit Tax to nothing. The return of the long period is presented as a response to tax optimization strategies and as a way of adapting the measure to economic realities, in which the valuation of a company often occurs several years after its creation.
Conclusion
The adoption of amendment no. I-807 as part of the 2026 finance bill marks an important step for French international taxation. If the measure is confirmed by the Senate and integrated into the final version of the finance law, the Exit tax will become a central mechanism in the analysis of any expatriation involving significant financial assets.
Entrepreneurs, investors and managers will now have to anticipate these constraints in their tax and wealth strategy.
