Moving from France to Thailand can convert a combined French burden of roughly 49% on top-bracket income, 30% on portfolio dividends and capital gains (PFU plus CEHR), and 0.5–1.5% wealth-tax exposure on real-estate (IFI) into 0% Thai personal tax on foreign-source income — but only if both legs are executed cleanly. Three French rules dominate the planning: the article 4 B CGI residency tests, the article 167 bis exit tax on substantial portfolio shareholdings, and the IFI trailing exposure on retained French real estate. On the Thai side, the move only delivers a 0% outcome if you qualify for the Long-Term Resident (LTR) Visa in one of its three “wealthy” categories — ordinary Thai tax residents are now caught by the 2024 remittance reform. The 1974 France-Thailand double-tax convention is still in force in 2026 and gives a usable tie-breaker, but does nothing to neutralise article 167 bis. This guide walks the realistic 9–14 month sequence and the post-departure compliance most French exiters underestimate.
The Tax Delta at a Glance
| France (current) | Thailand (after move) | |
|---|---|---|
| Personal income tax | 0% to 45% progressive (barème) | 0% on foreign-source income remitted under the LTR Royal Decree exemption (Cat. 1–3); 17% flat for LTR Highly Skilled; 5–35% otherwise |
| Contribution exceptionnelle sur les hauts revenus (CEHR) | 3% to 4% above €250K / €500K | None |
| Capital gains / dividends | 30% Prélèvement Forfaitaire Unique (12.8% IR + 17.2% CSG/CRDS) | No separate CGT statute; foreign gains exempt under LTR remittance rule; SET-listed share gains exempt |
| Wealth tax | IFI 0.5%–1.5% above €1.3M of French + worldwide real estate | None |
| Inheritance / gift tax | 5%–60% (45% top direct line, 60% non-relatives) | 5%/10% only above THB 100M from a single estate |
| Worldwide vs territorial | Worldwide for residents under article 4 A CGI | Resident-and-source; foreign income only taxed when remitted, and exempt for LTR Cat. 1–3 |
| Effective rate (typical entrepreneur on LTR) | ~49% top marginal IR + CEHR; 30% on dividends/CGT | 0% personal on foreign-source income; 20% Thai corporate |
The right-hand column applies in full only after you cease French residency under article 4 B CGI and establish Thai tax residency (180+ days in a calendar year) under an LTR category that grants the foreign-income exemption. Until then, the Direction Générale des Finances Publiques (DGFiP) treats you as fully taxable on worldwide income.
Step-by-Step Move
Step 1: Confirm you can legally cease French tax residency under article 4 B CGI
French tax residency is decided by article 4 B of the Code général des impôts, which sets four alternative tests — meeting any one makes you French resident on worldwide income:
- Foyer — your habitual place of dwelling and that of your spouse and minor children. Even with zero personal days in France, a spouse and children living in Paris keeps you French-resident.
- Lieu de séjour principal — the country where you spend the most days, applied when foyer is inconclusive (typically single people without dependants).
- Activité professionnelle principale — the country where your principal professional activity is carried on, judged by time spent and income generated.
- Centre des intérêts économiques — where principal investments, business management and source of income are located.
Unlike the UK Statutory Residence Test, there is no quantified day-count formula. The DGFiP applies a faisceau d’indices — a cluster of indicators. The biggest practical trap for France-to-Thailand movers is the foyer rule: if your spouse and children remain in Paris while you take a Bangkok or Phuket condo, you remain French-resident regardless of physical presence. Couples who keep children at the lycée français in Bangkok are fine for the foyer test (the family is unified at the new location); couples who try to split — children in Paris, principal in Thailand — fail it.
Mechanical sequence: terminate the French principal lease (or sell, or convert to an arm’s-length 12+ month tenancy to a non-family party); enrol the children in a Thai or international school; file the avis de départ on form 2042 marked “départ à l’étranger” with the new Thai address; close or downgrade French bank and brokerage accounts to non-resident profile; physically relocate the family. Without a clean foyer break, the article 167 bis planning below is moot — France never lost taxing rights to begin with.
Step 2: Plan around article 167 bis CGI (the French exit tax)
France’s exit tax under article 167 bis CGI is the dominant single cost for founders and investors leaving France. It is targeted, not general: it does not touch French real estate (which is taxed at sale, regardless of residency), salary or savings accounts. It hits portfolio shareholdings.
Trigger conditions:
- French tax resident for at least 6 of the 10 years preceding departure, and
- On the date of departure, holding (a) shareholdings worth more than €800,000 in aggregate, or (b) a 50%+ stake in the profits (droits aux bénéfices sociaux) of any single company.
If either threshold is met, the day French residency ceases, unrealised gains on those shareholdings are deemed realised. The deemed gain is taxed at the PFU rate of 30% (12.8% income tax plus 17.2% social charges — CSG, CRDS, prélèvement de solidarité), subject to the CEHR (3% / 4%) if total revenu fiscal de référence exceeds €250,000 (single) or €500,000 (couple). Top-bracket exiters typically face ~32–34% on the deemed gain.
Deferral rules — Thailand specifically. A move within the EU/EEA gets automatic interest-free deferral with no security required (article 167 bis II). A move to a state outside the EU/EEA — like Thailand — qualifies for deferral only if (a) the destination state has signed an administrative-assistance and recovery-assistance treaty with France, and (b) the taxpayer posts a guarantee (sûreté) covering the deferred amount, typically a bank guarantee or a pledge of the shares. France has the 1974 information-exchange clause with Thailand under the DTC, and Thailand became party to the OECD/Council of Europe Convention on Mutual Administrative Assistance in Tax Matters (MAC) when it deposited its instrument of ratification in 2022 (in force 2023). Practitioners should verify Thailand’s reservations under article 27 of the MAC (assistance in recovery) before relying on the recovery-assistance leg — some signatories opt out of recovery while accepting information exchange. If the recovery test fails, the exit tax is payable up-front rather than deferrable.
The 15-year extinguishment. If shares are not actually disposed of within 15 years of departure, the deferred exit tax extinguishes (article 167 bis VII bis). Return to French residency within that window cancels the exit tax entirely. For founders who plan a long Thai retirement and either sell after fifteen years or never sell at all, article 167 bis becomes a contingent rather than a real charge.
Mitigation that actually works: stay under the €800,000 / 50% thresholds through pre-departure dilution, gifts to family (subject to a 6-year donation lookback) or partial sales; time the move to a low-valuation window (the deemed gain is FMV at departure date); or pre-stage through an EU/EEA waystation (Cyprus, Portugal, Malta) for automatic sûreté-free deferral, then onward to Thailand later — sequencing carefully under the anti-abuse provisions.
Step 3: Establish Thai tax residency on the LTR Visa
Thai tax residency is triggered by 180+ days of physical presence in a calendar year, regardless of visa status. The visa choice, however, decides whether you arrive at 0% or at the full 5–35% Thai progressive scale on remittances.
For ex-French exiters the only product that delivers a clean tax outcome is the Long-Term Resident (LTR) Visa, in one of its four categories:
- LTR — Wealthy Global Citizens (USD 1M assets + USD 80K/yr income for 2 years + USD 500K invested in Thai bonds, FDI or real estate) — foreign-income exemption.
- LTR — Wealthy Pensioners (50+, USD 80K/yr passive/pension income) — foreign-income exemption. The natural fit for retiring French executives.
- LTR — Work-from-Thailand Professionals (USD 80K/yr from a foreign employer with USD 150M+ revenue, 5+ years experience) — foreign-income exemption.
- LTR — Highly Skilled Professionals — 17% flat on Thai-source employment income only; not the right product for a French founder retaining offshore income.
The 10-year LTR permit costs THB 50,000 (~USD 1,400) in government fees and typically USD 4,000–10,000 in professional fees end-to-end, with an additional USD 50,000 of qualifying health insurance. The full destination-side mechanics are in Tax-Free Residency in Thailand.
Once on LTR and physically present 180+ days, register a Thai address with the Revenue Department, obtain your Thai Tax Identification Number (TIN), and apply for a Thai Certificate of Tax Residence for the relevant Gregorian year. The certificate is what the DGFiP will demand to recognise your residency under article 4 of the France-Thailand treaty.
Step 4: Document the break and use the France-Thailand treaty tie-breaker
The double-tax convention between France and Thailand, signed 27 December 1974 and in force from 1975, is still applicable in 2026. Article 4 contains an OECD-style cascade for dual residents:
- Permanent home — if available in only one state, that state wins.
- Centre of vital interests — closest personal and economic ties.
- Habitual abode — where time is actually spent.
- Nationality — French nationals risk falling here if the upper steps are inconclusive.
- Mutual agreement procedure — competent authorities settle.
For most genuine moves, the permanent home test is decisive at step 1: terminate the Paris lease (or convert to arm’s-length tenancy), sign a Thai lease, and the home is exclusively in Thailand. If a French résidence secondaire is retained, the analysis falls to centre of vital interests — where the test depends on family location, business activity, banking and social ties.
Build a contemporaneous evidence file: avis de départ with the new Thai address, lease termination or sale contract for the French residence, EDF / Engie / Orange contract closures, résiliation of the carte Vitale (Sécurité sociale) with attestation, school deregistrations, French bank accounts moved to non-resident profile, brokerage off any PEA (closed by operation of law on departure). On the Thai side: LTR endorsement, registered Thai lease, Thai TIN, Certificate of Tax Residence, Thai bank statements, utility bills, school enrolments at the lycée français de Bangkok or another school. The DGFiP routinely opens audits 2–3 years after departure of HNW exiters; the strength of this file determines the outcome.
Step 5: First-year compliance — and the IFI / Trust / PEA tail
In the year of departure, file a final déclaration des revenus (formulaire 2042 with annex 2042-NR) marked départ à l’étranger: worldwide income for the period of French residency (1 January to departure date), French-source income only thereafter. The article 167 bis exit-tax assessment is filed on formulaire 2074-ETD, with the deferral election explicitly requested; the 2074-ETSL monitors the deferral each subsequent year until disposal or 15-year extinguishment.
After departure, three trailing nexus issues continue:
- IFI on French real estate. If French real property is retained and net real-estate worldwide assets exceed €1.3M, the IFI continues on French-situated property even after income-tax residency ceases. The €1.3M threshold is then assessed only against French property. A retained Paris pied-à-terre or Provence house is a real annual cost.
- Withholding on French-source income. French-source dividends suffer 12.8% domestic withholding, capped at the treaty rate. Under the 1974 France-Thailand treaty, dividend withholding is capped at 15% in the source state (and similar caps apply to interest and royalties — verify the exact protocol-amended rates with a French tax adviser before structuring large flows). French rental income remains taxed at minimum 20% (or progressive scale, whichever is higher) plus 17.2% social charges. UAE-resident former French nationals get no reduction in the social-charges rate; Thai-resident exiters are in the same position — they pay the full 17.2%, not the 7.5% prélèvement de solidarité reserved for EEA / Switzerland residents.
- Trusts and Pacte Dutreil structures. Any trust with a French connection (settlor, beneficiary or French assets) remains within scope of the trust-reporting regime under article 1649 AB CGI for 5 years post-departure. Pacte Dutreil shareholdings that gave inheritance / IFI discounts in exchange for holding commitments are unwound on departure to a non-EU/EEA state.
Thai compliance is light by comparison. File the annual Thai personal return by 31 March of the following year; LTR Cat. 1–3 holders declare the foreign-income exemption on remittances; Thai-source income is taxed at the regular brackets unless the LTR Highly Skilled flat 17% applies. The LTR is renewed at year 5 with an updated qualification check. Annual reporting to Immigration is once a year, not the 90-day cycle of other long-stay visas.
Cost & Timeline
| Phase | Cost (USD) | Time |
|---|---|---|
| French tax planning + article 167 bis modelling (pre-move) | $8,000–$25,000 | 2–6 months |
| Article 167 bis exit-tax assessment (one-off, founders only) | Up to ~32–34% × deemed gain | Filed with departure return |
| Sûreté / bank guarantee for non-EEA deferral | 1–2% / yr of deferred amount | Held until disposal or 15 yrs |
| Final déclaration des revenus + 2074-ETD | $1,500–$5,000 | Filed by mid-May of following year |
| Thailand LTR application (non-investment categories) | $6,000–$12,000 (incl. fees, insurance, document prep) | 4–8 weeks |
| Thailand LTR — Wealthy Global Citizens variant | ~$510,000+ (incl. USD 500K Thai investment) | 6–10 weeks |
| Move + setup (Thai lease, banking, TIN, work permit) | $3,000–$8,000 | 1–2 months |
| First-year Thai return + Certificate of Tax Residence | $1,500–$4,000 | Annual |
| IFI monitoring (if French real estate retained) | $2,000–$6,000 / year | Ongoing |
| Total year-1 effective cost (LTR Pensioner / Work-from-Thailand, no 167 bis) | $20,000–$55,000 | 9–14 months |
The dominant cost line for taxpayers in scope is almost always the article 167 bis charge, not the Thai-side spend. For a founder with €5M of accrued gain on shareholdings worth €8M at departure, the deemed-disposal bill at PFU plus CEHR is roughly €5M × ~32% ≈ €1.6M — deferrable up to 15 years against a sûreté typically equal to the full liability.
Treaty Considerations
The 1974 France-Thailand convention provides three concrete benefits for movers.
First, the article 4 tie-breaker is operative. Dual-residency disputes are resolved through the OECD cascade, giving exiters a defined evidentiary path rather than a pure domestic-law contest. The DGFiP’s foyer interpretation is broad, but article 4 narrows it.
Second, withholding on residual French-source flows is treaty-capped. Thai LTR holders receiving French-source dividends, interest or royalties suffer French withholding only up to the treaty cap (commonly 15% on dividends — verify the protocol-current rate), creditable against any Thai liability when remitted. Without the treaty, French domestic withholding rates would apply in full.
Third, France-Thailand has an information-exchange clause under the 1974 convention. Combined with Thailand’s 2022 ratification of the OECD/Council of Europe MAC, this delivers the administrative-assistance leg required by article 167 bis IV for non-EU/EEA deferral. The recovery-assistance leg depends on Thailand’s specific reservations under MAC article 27 — confirm with a French expatriation specialist before electing deferral.
The treaty does not override article 167 bis itself (deemed disposal applies regardless), and does not override IFI on French real estate (preserved by the treaty’s source-state taxing right on immovable property).
Common Mistakes
- Leaving children at the lycée international in Paris while you “live” in Bangkok. The article 4 B foyer rule treats the family’s principal home as yours — minor children at school in France keep you French resident even with 0 days of personal presence.
- Choosing the wrong LTR category. A French founder who picks LTR Highly Skilled Professionals to access “the 17% rate” loses the foreign-income exemption entirely — the flat rate applies only to Thai-source employment income. The right product for offshore-income founders is Wealthy Global Citizens or Work-from-Thailand Professionals.
- Failing to post the sûreté on time. Without a guarantee accepted by the DGFiP within 90 days of departure, the article 167 bis deferral fails and the exit tax becomes immediately payable.
- Triggering the post-2024 Thai remittance reform without LTR cover. A French founder who arrives on a tourist or DTV visa, crosses 180 days, and then remits offshore income into Thailand is taxed at 5–35% on those remittances. The LTR Royal Decree 743 exemption is what insulates the position; the visa must be in place before the remittance.
- Keeping the PEA / PEA-PME open after departure. Both close de jure on the day French residency ceases, with the 5-year tax preference lost retrospectively if held under five years. Close them affirmatively before departure.
- Ignoring IFI on a retained Paris apartment. A founder keeping a €2M apartment in the 7th still pays IFI annually — the €1.3M threshold is then assessed against French real estate alone.
- Forgetting the social-charges trap. Capital gains realised by non-residents on substantial French holdings (25%+) remain subject to French income tax, and Thai-resident former French nationals do not benefit from the reduced 7.5% prélèvement de solidarité reserved for EEA / Switzerland — they pay the full 17.2%.
FAQ
Will I still have to file a French tax return after moving to Thailand?
For the year of departure — yes, a final déclaration des revenus (formulaire 2042 plus 2042-NR) covering worldwide income up to the departure date and French-source income thereafter, plus the 2074-ETD for any article 167 bis election. Beyond that, only if French-source income (French real-estate income, French dividends, French director’s fees) is retained — filed on form 2042-NR. The annual 2074-ETSL deferral monitoring continues each year until the 15-year extinguishment or actual disposal.
How much is the article 167 bis exit tax in practice?
For taxpayers in scope (French resident 6 of last 10 years, plus €800K+ portfolio holdings or 50%+ stake), the deemed gain is taxed at PFU 30% plus CEHR 3–4% — typically 32–34% of unrealised gain at departure. Deferrable up to 15 years against a sûreté for non-EEA destinations like Thailand; extinguishes if no actual disposal in that window.
Can I keep my French bank accounts, SAS shares and Paris apartment?
Bank accounts can be retained under non-resident profile; brokerage accounts must move off any PEA. SAS / SARL shares above the article 167 bis thresholds trigger the exit tax and continue under the deferral regime. A retained Paris apartment that remains “available” can re-establish foyer if the family uses it — convert to an arm’s-length tenancy (12+ months, not to family) before departure. IFI continues annually on French real estate above €1.3M.
How long does the full move from France to Thailand take?
Realistic timeline 9–14 months from first planning meeting to issued Thai Certificate of Tax Residence. The critical path is usually article 167 bis structuring (sûreté arrangement, valuation report) plus the LTR endorsement and Thai TIN registration.
Does the LTR Visa actually shield me from the post-2024 Thai remittance rules?
Yes for Categories 1–3 (Wealthy Global Citizens, Pensioners, Work-from-Thailand Professionals): Royal Decree 743 provides an explicit exemption from Thai personal income tax on foreign-source income remitted into Thailand. Highly Skilled Professionals are not covered and are taxed on Thai-source employment income at 17% flat, with no foreign-income exemption.
What about inheritance — am I free of French succession duties once I leave?
Mostly. After departure, French succession duty (droits de mutation à titre gratuit) applies only on French-situated assets if the deceased and heirs are both non-resident. There is no general 5- or 10-year trailing nexus on worldwide estates as in Germany. However, French nationals who inherit from a non-resident decedent remain liable on worldwide assets if the heir was French resident in 6 of the 10 years before receipt — a rule that catches family members who never themselves moved.
Next Step
For the full destination-side breakdown, see Tax-Free Residency in Thailand and the LTR category breakdown by profile. For the broader exit framework, see How to Legally Exit a High-Tax Country. For the cleaner France-to-zero-tax corridor with a longer-running treaty and no remittance complexity, compare France to UAE; for the EU-internal alternative with automatic 167 bis deferral, see France to Portugal.
Book a free consultation — we specialize in France-to-Thailand relocations and article 167 bis sûreté structuring for non-EU/EEA destinations specifically.
Last updated: 2026-04-27
Sources:
– Bulletin Officiel des Finances Publiques — BOI-RPPM-PVBMI-50 (article 167 bis CGI) (https://bofip.impots.gouv.fr)
– Code général des impôts, articles 4 A, 4 B, 167 bis, 244 bis (https://www.legifrance.gouv.fr)
– DGFiP — Convention fiscale France-Thaïlande du 27 décembre 1974 (https://www.impots.gouv.fr/international-particulier/conventions-internationales)
– PwC Worldwide Tax Summaries — France — Individual taxes (https://taxsummaries.pwc.com/france/individual)
– Thailand Board of Investment — LTR Visa portal and Royal Decree No. 743 on personal income tax exemption (https://ltr.boi.go.th/)
– Thai Revenue Department guidance on foreign-source income remittance (Departmental Instruction Paw 161/162, effective 2024)