---
title: "France’s 2027 budget bill: exit tax and tax residence checks"
url: https://andorrefiscal.fr/en/news/france-2027-budget-exit-tax-residence
description: "France’s 2027 finance bill (draft): exit tax due on a gift after a contribution to a holding, social media scrutinised for Article 4 B, tax scale +2.1%."
updated: 2026-10-15
language: en
publisher: Andorre Fiscal (https://andorrefiscal.fr)
---

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

> Markdown version of the page https://andorrefiscal.fr/en/news/france-2027-budget-exit-tax-residence (Andorre Fiscal), up to date as of 15 October 2026. To cite this page, use its address: https://andorrefiscal.fr/en/news/france-2027-budget-exit-tax-residence

The finance bill for 2027, filed on 1 October 2026, contains two measures that directly target French nationals who leave France: the exit tax would become payable on a gift or inheritance of securities contributed to a holding company, and the tax authorities could make lasting use of public content on social media to check tax domicile. Nothing has been voted yet.

By [the Andorre Fiscal editorial team](https://andorrefiscal.fr/en/about#redaction) · Published on 15 October 2026 · Debated in the French National Assembly since 13 October 2026 · [8 official sources](https://andorrefiscal.fr/en/news/france-2027-budget-exit-tax-residence#sources)

- **1 Oct 2026** bill filed with the National Assembly
- **2.1%** proposed uprating of the income tax scale
- **5 years** proposed staggered payment of tax that has become payable
- **Draft** none of these measures has been adopted at 15 October 2026

## Key points

- The finance bill for 2027 (No. 3210) was filed on 1 October 2026; the Finance Committee rejected its “revenue” part on 9 October, and the plenary debate starts again from the government’s text.
- Article 5: a gift or inheritance of securities received in exchange for a contribution to a holding company would end the tax deferral, including for a taxpayer who has moved abroad and benefits from the exit tax payment deferral, for transfers made since 1 October 2026.
- Article 30: the automated collection of content published on social media would become permanent and would expressly be used to check tax domicile within the meaning of Article 4 B.
- Article 2: the tax scale would be raised by 2.1% for 2026 income; its rates do not change.
- Already in force since the Finance Act for 2026: the differential contribution on high incomes also applies to the year of departure, and a 20% tax targets certain assets of personal holding companies.

## 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.

The 2027 budget timetable

1. 1 October 2026

   Presentation to the Council of Ministers and filing with the National Assembly (bill No. 3210)
2. 7 to 9 October 2026

   Examination of the first part in the Finance Committee, which rejects it
3. Since 13 October 2026

   Examination in plenary session, on the government’s text
4. End of 2026

   Shuttle between the Assembly and the Senate, final adoption, possible review by the Constitutional Council, publication in the Official Journal

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](https://andorrefiscal.fr/en/glossary#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.

> Paragraph I applies to transfers made on or after Thursday 1 October 2026.
>
> — [Finance Bill for 2027, Article 5, II (free translation)](https://www.assemblee-nationale.fr/dyn/17/textes/l17b3210_projet-loi.pdf)

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](https://andorrefiscal.fr/en/tax/leaving-france-tax-residency), and holding structures are covered in the guide to the [holding company in Andorra](https://andorrefiscal.fr/en/business/holding-company).

## 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](https://andorrefiscal.fr/en/tax/tax-residency), and the case of creators in the profile [YouTuber or influencer in Andorra](https://andorrefiscal.fr/en/profiles/content-creator).

## 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](https://andorrefiscal.fr/en/tools/france-andorra-tax-comparison) uses the scale in force, the one for 2025 income.

**French tax scale for one share**

| Rate | 2025 income (Finance Act for 2026) | 2026 income (bill) |
| --- | --- | --- |
| 0% | up to €11,600 | up to €11,844 |
| 11% | €11,600 to €29,579 | €11,844 to €30,200 |
| 30% | €29,579 to €84,577 | €30,200 to €86,353 |
| 41% | €84,577 to €181,917 | €86,353 to €185,737 |
| 45% | over €181,917 | over €185,737 |

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](https://andorrefiscal.fr/en/tax/france-andorra-tax-treaty#nationalite) 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).

> **Caution: Before you leave, take stock**
>
> If you own a holding company that resulted from a contribution and sale, or if you are planning a gift of securities before or after departure, have your timetable reviewed by a French tax lawyer or chartered accountant: the text may still change during the debates, and the effective date chosen by the bill is earlier than the vote.

## Frequently asked questions

### Does the exit tax change for all French nationals moving to Andorra?

No. The bill changes neither the exit tax thresholds (€800,000 of securities or 50% of a company) nor its conditions on the length of residence in France. It targets a specific case: securities that, after departure, were contributed to a holding company under the regime of Article 150-0 B ter of the French General Tax Code, then given away or passed on through inheritance.

[Read: Leaving France for tax purposes › Exit tax and Andorra: who is affected (€800,000 or 50%)?](https://andorrefiscal.fr/en/tax/leaving-france-tax-residency#exit-tax)

### Why the date of 1 October 2026, before the vote?

The bill provides that the measure applies to transfers made from 1 October 2026, the day it was filed, to avoid a wave of gifts during the debates. If the article is adopted in this form, a gift made since that date would be affected.

### Can my Instagram posts be used to challenge my residence in Andorra?

That is the purpose of Article 30 of the bill: the tax authorities could collect and analyse, in an automated way, content made public by its authors on online platforms, without facial recognition, in particular to detect breaches of the tax domicile rules of Article 4 B. Photos or posts showing a life lived mainly in France could then support a tax audit.

[Read: Tax residency](https://andorrefiscal.fr/en/tax/tax-residency)

### Does the 2027 budget create a tax based on nationality?

No. The government’s text contains no tax based on nationality. The amendment known as the “targeted differential tax”, inspired by the “universal tax”, was rejected in the Finance Committee on 7 October 2026. The nationality clause of the France–Andorra treaty remains without effect in the absence of a French law.

[Read: France–Andorra tax treaty › The nationality clause (Article 25): written, but inoperative](https://andorrefiscal.fr/en/tax/france-andorra-tax-treaty#nationalite)

### When will we know what has been adopted?

A finance act is normally given final adoption in December and published before 1 January; it may also be referred to the Constitutional Council. We will update this page at each stage, once checked against the documents of the National Assembly and the Senate.

## Sources

1. [French National Assembly: Finance Bill for 2027, No. 3210, filed on 1 October 2026](https://www.assemblee-nationale.fr/dyn/17/textes/l17b3210_projet-loi) — Government text: Articles 2 (tax scale), 5 (contribution and sale, exit tax), 30 (tax audits) and 33 (entry into force).
2. [French National Assembly: full text of bill No. 3210 (PDF)](https://www.assemblee-nationale.fr/dyn/17/textes/l17b3210_projet-loi.pdf) — Article 5: new f bis of VII of Article 167 bis, Article 1681 G, application to transfers since 1 October 2026.
3. [French National Assembly, Finance Committee: examination of the first part of the Finance Bill for 2027](https://www.assemblee-nationale.fr/dyn/17/organes/commissions-permanentes/finances/actualites/projet-de-loi-de-finances-pour-2027-examen-de-la-premiere-partie) — The committee examined and then rejected the first part of the bill.
4. [French National Assembly: provisional report of the second sitting of Wednesday 14 October 2026](https://www.assemblee-nationale.fr/dyn/17/comptes-rendus/seance/session-ordinaire-de-2026-2027/deuxieme-seance-du-mercredi-14-octobre-2026) — Examination of the Finance Bill for 2027 in plenary session.
5. [Law No. 2026-103 of 19 February 2026, Finance Act for 2026 (Légifrance)](https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000053508155) — Tax scale for 2025 income, differential contribution on high incomes, tax on the non-business assets of holding companies.
6. [French General Tax Code, Article 224 (Légifrance)](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051200465) — Differential contribution on high incomes: at least 20%; year of departure included (V bis).
7. [French General Tax Code, Article 235 ter C (Légifrance)](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000053542687) — 20% tax on the non-business assets of personal holding companies.
8. [French General Tax Code, Article 167 bis (Légifrance)](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048806379) — Exit tax: version in force, unchanged by the Finance Act for 2026.

Consolidated texts on the Portal jurídic d’Andorra have no official value: only the version published in the BOPA is authentic. [How we verify](https://andorrefiscal.fr/en/methodology).

[EU tax haven blacklist: Andorra not listed in October 2026](https://andorrefiscal.fr/en/news/eu-tax-haven-blacklist-october-2026): Older9 October 2026[Andorra’s 2027 budget: no tax rates raised, but tax adjustments](https://andorrefiscal.fr/en/news/andorra-2027-budget-taxes): Newer14 October 2026[All news (11)](https://andorrefiscal.fr/en/news)

**General information, not advice.** This article sets out the rules in force on 15 October 2026, based on official texts. It is no substitute for a professional review of your situation (lawyer, tax adviser, gestoria).

## Further reading

- [Leaving France for tax purposes](https://andorrefiscal.fr/en/tax/leaving-france-tax-residency): Year of departure, tax returns, exit tax
- [Tax residency](https://andorrefiscal.fr/en/tax/tax-residency): 183 days, centre of interests, dual residency
- [Holding company in Andorra](https://andorrefiscal.fr/en/business/holding-company): Holding shareholdings
- [France–Andorra inheritance](https://andorrefiscal.fr/en/tax/inheritance-tax-france-andorra): Heirs, gifts, the 6-year rule
- [Andorra vs France taxes](https://andorrefiscal.fr/en/tax/andorra-vs-france-taxes): The main taxes side by side
- [France–Andorra tax treaty](https://andorrefiscal.fr/en/tax/france-andorra-tax-treaty): Who taxes what: signed in 2013, in force since 2015