Key Takeaways
- France taxes unrealised gains on departure (Article 167 bis) if securities exceed €800,000 or you hold 50%+ of a company.
- The deemed gain is taxed at about 30% (12.8% + 17.2% social charges).
- Because the France–Andorra treaty (2015) includes administrative assistance, payment can usually be deferred.
- This makes the French exit gentler than the Spanish or Dutch one.
- IFI wealth tax applies only to French real estate once you are non-resident.
Moving from France to Andorra can cut income tax from up to 45% (plus social charges) to a maximum of 10%. France has an exit tax on unrealised gains — Article 167 bis — that applies if your securities are worth more than €800,000 or you hold 50% or more of a company. But because France and Andorra have a tax treaty with administrative assistance, payment can usually be deferred, which makes the French exit gentler than the Spanish or Dutch one.
The upside
France taxes income up to 45%, adds social charges (up to 17.2% on investment income), levies the IFI wealth tax on real estate above €1.3m, and applies inheritance tax up to 45%. Andorra caps income at 10%, has no wealth or inheritance tax, and taxes most capital gains at 0%. Andorra is also on France’s doorstep — the border is a short drive from the south-west.
The French exit tax (Article 167 bis)
If you have been French tax resident for at least 6 of the last 10 years, the exit tax crystallises the unrealised gains on your securities when you leave, if either:
- your securities portfolio has unrealised gains and is worth more than €800,000, or
- you hold 50% or more of a company.
The deemed gain is taxed at the flat rate (12.8% income tax plus 17.2% social charges — about 30%), as if you had sold on the day you left.
Why the treaty helps
France grants an automatic deferral of payment (sursis de paiement) when you move to an EU/EEA country or to a country that has a tax treaty with France containing an administrative-assistance clause. France and Andorra have had such a treaty in force since 2015. So a move to Andorra generally qualifies for deferral — you do not have to pay the exit tax up front, and the liability is reduced or cancelled over time (historically the charge on securities still held can fall away after a number of years).
This is a real advantage over Spain and the Netherlands, where a move to Andorra is treated as a move to a third country with no automatic deferral.
What else to plan
- IFI (wealth tax on real estate): once non-resident, you are taxed on French real estate only, not worldwide property.
- Assurance-vie: the French life-insurance wrapper loses its French tax treatment when you leave; Andorra does not recognise it. Review before you move.
- Social charges: ceasing to be in the French social-security system is part of leaving; you join Andorran CASS as an active resident or take private cover as a passive one.
- The date you break residence matters — France taxes worldwide income up to your departure and French-source income after.
France also watches Andorra moves
As with Spain, the proximity and the tax gap mean the French administration scrutinises departures to Andorra. Genuinely relocate: a home in Andorra, your family and economic centre there, and limited days back in France.
The Andorran side
Active residency through an Andorran company if you keep working; passive residency if you live off capital. The non-refundable €50,000 AFA payment and the day requirements (183 active, 90 passive) apply.
Frequently asked questions
Does France have an exit tax when you move to Andorra?
Yes, under Article 167 bis, if your securities are worth over €800,000 with unrealised gains, or you hold 50% or more of a company. But because of the France–Andorra tax treaty, payment can usually be deferred.
Do I have to pay the French exit tax immediately when moving to Andorra?
Usually not. The France–Andorra treaty (in force since 2015) includes administrative assistance, which generally entitles you to defer payment — unlike a move to Spain or the Netherlands.
Will I still pay French wealth tax?
As a non-resident you are subject to the IFI only on French real estate, not on worldwide property.
Is moving from France to Andorra worth it?
For a high earner or someone with significant wealth, the recurring saving on income, wealth and inheritance tax is large, and the exit tax is more manageable than for Spanish or Dutch movers thanks to the treaty.
Last reviewed: 3 September 2026. General information, not legal or tax advice. French exit-tax and residence rules are detailed and change; use a French tax adviser and an Andorran adviser together before moving. Speak to our team.
