France Considers Citizenship-Based Taxation: What French Expats Need to Know
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A recent development in France has captured the attention of globally mobile French nationals, international business owners, and high-earning professionals living abroad. The Finance Committee of the National Assembly has adopted an amendment that would require some French citizens to continue paying French taxes for up to ten years after relocating to another country.
While the measure is still under debate and not yet law, it signals a potential shift in how France approaches taxation, particularly for those with international lifestyles.
This evolving environment is prompting many French nationals to reassess how they structure residency, citizenship, and long-term financial planning.
Understanding the Proposal
The amendment applies to individuals who:
- Hold French citizenship.
- Have an annual income above five times the social security ceiling (approximately €235,500 in 2025).
- Relocate to jurisdictions where tax rates are 40% lower than France’s.
- Have lived in France for at least three years in the previous decade.
If enacted, these individuals may continue to be taxed under certain French tax rules for up to 10 years after establishing residency abroad.
To prevent double taxation, the system would allow tax credits for taxes already paid in the new country of residence.
This model aligns France more closely with countries such as the United States, which taxes based on citizenship rather than physical residency.
Why This Proposal Is Gaining Momentum
Supporters of the amendment argue that the current European tax landscape makes it too easy for high-income individuals to relocate to lower-tax countries while maintaining economic, business, or family ties in France. The proposal’s authors present the measure as a way to preserve what they describe as a fair contribution to the national budget.
This is not the first time such an idea has surfaced. Similar frameworks were discussed in 2019 and 2024, but those attempts did not progress. The renewed interest reflects a broader policy trend: debates around wealth mobility, public finance, and cross-border economic competition are shaping legislative agendas in many developed nations.
What This Means for French Nationals Abroad
For French nationals who live or plan to live abroad, particularly entrepreneurs and investors, the implications are meaningful:
- International mobility may involve additional administrative steps.
- Long-term residency planning becomes more important.
- The jurisdiction of one’s citizenship may play a more influential role than before.
- Financial planning must be aligned with regulatory developments.
Even if the proposal changes significantly during parliamentary review, one message is clear: The global tax environment is becoming more interconnected and more closely scrutinized.
Where Second Citizenship Fits In
A second citizenship does not erase existing tax responsibilities.
However, it does offer individuals:
- More freedom in choosing where to establish tax residency.
- Greater flexibility in shaping long-term lifestyle and investment decisions.
- The ability to operate within different legal and regulatory systems.
- A more resilient international mobility profile in the face of shifting national tax policies.
Importantly, if taxation frameworks increasingly become tied to citizenship rather than residency, having only one nationality could limit future choices. Holding a second citizenship provides the legal ability to restructure one’s residency and citizenship status if personal circumstances or national tax rules change in the future.
For French nationals with global business interests or family arrangements across borders, a second citizenship can become part of a strategic, lawful planning structure, especially when coordinated with experienced advisors and tax counsel.
This is not about tax avoidance; it is about future-proofing personal and financial flexibility in a changing policy environment.
What Happens Next
The amendment has cleared its first committee stage, but it must still:
- Pass the full National Assembly.
- Be reviewed and potentially revised by the Senate.
- Be reconciled if the two chambers disagree.
- Receive final approval and presidential signature before becoming law.
Even if adopted, implementation would require cooperation with foreign tax authorities and clarification of how income and credit would be calculated.
In short, the direction is significant, but the final form is not yet settled.
How UNO Capital Helps
At UNO Capital, we guide clients in navigating this evolving environment with clarity and discretion.
Our role is to help you:
- Evaluate second citizenship and residency program options.
- Understand how various jurisdictions align with your professional and family priorities.
- Coordinate planning alongside qualified legal and tax advisors.
- Build a global mobility structure that is responsible, compliant, and adaptable.
The goal is not to escape obligations. The goal is to ensure your life, work, and investments remain under your control.
If you would like to understand how these changes may relate to your circumstances, we offer confidential consultations tailored to your goals and investment profile.
Speak with our advisors to explore your citizenship and residency options.
* UNO Capital is an authorized advisor for citizenship and residency planning. However, this article is for general informational purposes only and should not be interpreted as tax or legal advice. Individual tax situations vary, and any decisions relating to tax residency or structuring should be made in consultation with a qualified tax professional or legal advisor.
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