France’s 2027 budget: what the finance bill changes for French nationals moving to Andorra

Where does the 2027 budget stand?

The finance bill for 2027 was presented to the Council of Ministers and filed with the National Assembly on 1 October 2026, under number 3210. The Finance Committee examined its first part, on revenue, from 7 to 9 October, then rejected it: MPs are therefore debating the government’s initial text in plenary session, and the amendments adopted in committee are no longer in it, unless they are tabled again.

On the evening of 14 October 2026, Articles 2 to 6 of the bill had not yet been put to the vote in plenary session.

Exit tax: a gift of securities contributed to a holding company would no longer cancel the tax

The so-called “contribution and sale” regime (Article 150-0 B ter of the French General Tax Code) defers tax on the capital gain realised when you contribute securities to a company you control, often a holding company. Today, this deferral ends on a sale for consideration; a gift or an inheritance can, under certain conditions, cancel it. Article 5 of the bill replaces the notion of sale with that of transfer: a gift or an inheritance would make the tax payable.

The bill also targets taxpayers who have moved abroad. It adds to the exit tax (Article 167 bis, VII) a new event ending the payment deferral: the transfer without consideration of securities which, after the transfer of domicile outside France, were contributed to a holding company under the contribution and sale regime. An Andorran resident who contributed their securities to a holding company after leaving, then gives their children the securities received in exchange, would therefore pay the tax on the capital gain recorded on departure.

In return, a new Article 1681 G would allow the tax that has become payable to be paid over five years, on request and against guarantees. The thresholds and conditions of the exit tax do not change: our explanations on departure are in the guide to leaving France for tax purposes, and holding structures are covered in the guide to the holding company in Andorra.

Tax residence: social media used for Article 4 B checks

Article 30 of the bill creates an Article L. 80 S in the French Book of Tax Procedures. It makes permanent the automated collection, by the tax authorities, of content “manifestly made public by their authors” on online platforms, including those that require an account, without any facial recognition system. Its purposes expressly include detecting breaches of the tax domicile rules of Article 4 B of the French General Tax Code.

For a French national living in Andorra, the consequence is concrete: what you post about where you live, your stays or your activity can feed into a check on your residence. The criteria do not change (household, main activity, centre of economic interests), but evidence of them becomes easier for the tax authorities to gather. The criteria and the evidence to keep are detailed in our guide to tax residency in Andorra, and the case of creators in the profile YouTuber or influencer in Andorra.

Income tax scale: a 2.1% uprating

Article 2 raises the bands of the scale by 2.1% for 2026 income, without changing the rates. This scale will apply only once the law has been adopted; our France⁠–⁠Andorra comparison tool uses the scale in force, the one for 2025 income.

The bill also raises the family quotient cap from €1,807 to €1,845 per half-share.

What the bill does not contain

• No tax based on nationality: the “targeted differential tax” amendment was rejected in committee on 7 October 2026, and the nationality clause of the France⁠–⁠Andorra treaty remains inapplicable without a French law.
• No change to the differential contribution on high incomes, the tax on real estate wealth or the minimum tax rates for non-residents in the government’s text.
• The exit tax on crypto-assets (amendment No. I-CF1822) had been adopted in committee, before the whole first part was rejected: it is not in the text debated in plenary session, unless a new amendment is tabled.

What is already in force since the Finance Act for 2026

Two measures of Law No. 2026-103 of 19 February 2026 already affect those who leave:

• Differential contribution on high incomes, year of departure included: a taxpayer whose reference income exceeds €250,000 (€500,000 for a couple) must pay tax of at least 20%; if they transfer their domicile abroad, they are liable for it for the year of departure, on the income received up to that date (Article 224, V bis, of the French General Tax Code).
• Tax on personal holding companies: 20% on certain non-business assets (homes occupied by the shareholder, yachts, vehicles, jewellery…) of companies subject to corporate income tax that hold at least €5 million of assets, are 50% controlled by an individual and receive mainly passive income. A company with its registered office in France is subject to it whatever the shareholder’s residence; a foreign company, only if the person who controls it has their tax domicile in France (Article 235 ter C).