Moving from France to Vanuatu collapses the entire French personal-tax stack — 45% top-bracket impôt sur le revenu, 4% contribution exceptionnelle sur les hauts revenus, the 30% Prélèvement Forfaitaire Unique on dividends and capital gains, the Impôt sur la Fortune Immobilière on net property above €1.3M, and inheritance tax that reaches 60% on transfers outside the direct line — into a flat zero. Vanuatu has never enacted a personal income tax statute, levies no capital gains tax, no inheritance, no gift, no wealth tax, and the Development Support Program delivers a Commonwealth passport in 30–60 days, the fastest CBI on the market. The economic case is unmatched in the entire French exit corridor. The execution case is among the hardest. Vanuatu is non-EU/EEA, so article 167 bis CGI exit tax runs without automatic deferral and almost always demands a financial guarantee. No double tax treaty and no Tax Information Exchange Agreement is in force between France and Vanuatu, removing the OECD-style tie-breaker entirely. And Vanuatu has appeared on the French liste des États et territoires non coopératifs (ETNC) under article 238-0 A CGI in recent updates — activating a punitive layer (75% withholding on French-source flows under article 119 bis 2° CGI, denial of expense deduction under article 238 A, the harsher article 209 B CFC regime) that does not bite Cyprus, Malta, or even Singapore exiters. This guide walks the corridor with that asymmetry as the central planning constraint.
The Tax Delta at a Glance
| France (current) | Vanuatu (after move) | |
|---|---|---|
| Personal income tax | 0% to 45% progressive (barème) | 0% — no personal income tax statute exists |
| Contribution exceptionnelle (CEHR) | 3% to 4% above €250K / €500K | None |
| Capital gains / dividends | 30% PFU (12.8% IR + 17.2% CSG/CRDS), +4% CEHR at top | 0% on all gains and dividends, foreign and domestic |
| Wealth tax (real estate – IFI) | 0.5% to 1.5% above €1.3M French + worldwide property | 0% — no wealth tax; IFI continues on retained French real estate post-departure |
| Inheritance / gift | 5%–60% (45% top direct line, 60% non-relatives) | 0% — no Erbschaftsteuer-equivalent exists |
| Worldwide vs territorial | Worldwide for residents under article 4 A CGI | No income tax at all — territorial vs worldwide is moot |
| Corporate tax | 25% IS standard | 0% on offshore activity (International Companies); revenue raised via 15% VAT and licence fees |
| Effective rate (typical entrepreneur) | ~49% on salary; 30% on dividends/CGT; up to 64% on inheritance | 0% personally, in full |
The right-hand column lands in full only after both legs close: cessation of residence under article 4 B CGI, and a Vanuatu citizenship plus genuine substance file capable of surviving DGFiP scrutiny — particularly given the ETNC overlay and the absence of treaty cover. Until then, the Direction Générale des Finances Publiques will continue to tax you 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 turns on article 4 B of the Code général des impôts, which lists four alternative tests — meeting any one keeps you French resident on worldwide income:
- Foyer — the habitual place of dwelling of you and your family (spouse and minor children). The Conseil d’État has consistently held that family location overrides personal day-counts.
- Lieu de séjour principal — the country with the most days, applied only when the foyer test is inconclusive (typically single people without dependants).
- Activité professionnelle principale — where you carry on your principal professional activity.
- Centre des intérêts économiques — where your principal investments, business management, and source of income sit.
There is no quantified day-count formula; the DGFiP applies a faisceau d’indices. For Vanuatu movers the foyer rule is the dominant trap because Vanuatu’s CBI imposes zero physical-presence obligation — you can hold the Vanuatu passport without ever visiting the islands. A founder with a Vanuatu passport, a Paris pied-à-terre “kept for visits”, and 200 days a year circulating between Dubai, Singapore and Lisbon is not, on those facts, non-resident for French purposes: the dwelling and the absence of any competing day-count anchor combine to preserve the foyer.
The defensive sequence is strict: terminate the French lease (or sell the residence, or place it on an arm’s-length 12+ month rental to a non-family tenant), file the avis de départ on form 2042 marked “départ à l’étranger” with the Centre des Finances Publiques des Non-Résidents (Noisy-le-Grand), enrol any minor children in a Vanuatu, UAE, or French-school-of-Singapore programme, and physically relocate the family. Because Vanuatu has no minimum-stay rule to point to as competing residency, establish a second jurisdiction with a real day-count footprint — UAE 90/180 day rule, or a genuine 183+ days physically in Vanuatu under the Self-Funded Retiree Visa (VUV 250,000/month foreign income) — so the DGFiP sees an affirmative tax home elsewhere, not an open-ended citoyen du monde profile.
Step 2: Plan around article 167 bis CGI — and the non-EU collateral demand
France’s exit tax under article 167 bis CGI is the single largest line item for most founders leaving France. It is targeted, not general: it does not touch French real estate (which is taxed on sale regardless of residency), salary, or French savings accounts. It hits portfolio shareholdings.
The trigger conditions:
– You have been French tax resident for at least 6 of the 10 years preceding departure, and
– On the departure date you hold either (a) shareholdings worth more than €800,000 in aggregate, or (b) a 50%+ stake in the droits aux bénéfices sociaux of any single company.
If triggered, the deemed gain — fair market value on the departure date minus your acquisition cost — is taxed at the 30% PFU (12.8% IR + 17.2% social contributions) plus, where applicable, the 3–4% CEHR. For a founder leaving with €5M of unrealised gain on a private SAS stake, the headline exposure is roughly €1.5M to €1.7M.
Vanuatu is non-EU/EEA, which is decisive: deferral is not automatic. Under the post-2019 regime, a non-EU/EEA move requires you to either pay the tax up front or apply for deferral with financial guarantees — typically a French bank guarantee or pledged French securities equal to the tax due. The deferred liability extinguishes after 15 years (provided you do not actually dispose of the shares), at which point the deferred tax is cancelled. Annual filing on formulaire 2074-ETS3 is mandatory throughout the deferral horizon — missing a single year can unwind the deferral.
The Vanuatu-specific complication: because there is no FR–VU treaty and Vanuatu has appeared on the ETNC list, the DGFiP is unlikely to accept Vanuatu-located assets as collateral. Plan for French-custodied securities, a French bank guarantee, or a Grundschuld-equivalent French real-estate hypothec as the only realistic posting options. Pre-positioning options — donation-cession below the threshold, interposing a French holding before residency cessation, accelerating a partial market-rate exit while still resident — are the same as for any French departure but become more important when the destination removes the EU/EEA softening.
Step 3: Establish Vanuatu citizenship — Development Support Program
Vanuatu’s residency and citizenship framework is the easy leg. The Development Support Program (DSP), administered by the Citizenship Office of the Republic of Vanuatu and submitted exclusively through government-licensed agents, grants citizenship for life on a non-refundable contribution of US$130,000 (single applicant), US$150,000 (couple), US$165,000 (family of three), US$180,000 (family of four), plus due-diligence fees (~US$5,000 per adult) and licensed-agent fees (~US$15,000–25,000). Processing is 30–60 days from clean filing — the fastest CBI on the market — with no obligation to visit Vanuatu before, during, or after approval.
For a French exiter that speed is double-edged. The passport and Vanuatu tax-residency status arrive together; the substance file does not. To anchor Vanuatu tax residency credibly against article 4 B scrutiny — and against the DGFiP’s tendency to read ETNC destinations as artificial — pair the CBI with one of: the Self-Funded Retiree Visa (VUV 250,000/month verifiable foreign income transferred to a Vanuatu bank account, plus 183+ days physical presence); the Investor Visa (active business operation in Vanuatu); or a paired second residency in a higher-substance jurisdiction (UAE, Cayman) used as the actual day-count home, with Vanuatu held purely as the citizenship anchor. This pairing pattern is the standard structure for token-rich founders and is described in the crypto founder residency guide.
CBI applicants submit apostilled birth certificate, marriage certificate, French casier judiciaire B3 plus equivalents from every country of residence in the prior 10 years, certified passport copies, source-of-funds dossier, medical and HIV-test certificates, and professional CV. Full destination-side mechanics are in Tax-Free Residency in Vanuatu.
Step 4: Confront the missing treaty and the ETNC overlay
The defining feature of the France-Vanuatu corridor is that no comprehensive double tax convention and no Tax Information Exchange Agreement is in force between France and Vanuatu. The DGFiP’s published list of conventions does not list Vanuatu in any form. Combined with Vanuatu’s appearance on the French liste des États et territoires non coopératifs (ETNC) under article 238-0 A CGI in recent updates (the list is set by joint arrêté of the Ministers of the Economy and the Budget and is reviewed annually — verify the current status with the most recent arrêté before transacting), this produces a uniquely punitive French-side regime:
- Article 119 bis 2° CGI — punitive withholding. Dividends, certain interest payments, and analogous distributions paid by a French source to a Vanuatu-resident beneficiary are subject to withholding at 75% where Vanuatu is on the ETNC list, against the standard 12.8% (or 25% on undeclared accounts).
- Article 244 bis A CGI — real-estate gains. Capital gains on French real estate realised by a Vanuatu-resident seller are taxed at 75% where the ETNC listing is active, against the standard 19% non-resident rate.
- Article 238 A CGI — denial of deduction. Payments to Vanuatu-resident counterparties are presumed non-deductible by a French payer unless the taxpayer proves the transaction is genuine and not abnormally priced. The reversed burden of proof is the practical bite.
- Article 209 B CGI — harshened CFC. A French-resident shareholder holding 50%+ of a Vanuatu entity is subject to the article 209 B CFC regime; ETNC listing reduces the threshold to 5% in some configurations.
- No Article 4 tie-breaker. A residency dispute opened two years post-departure is decided purely under article 4 B CGI without treaty assistance — no permanent-home / centre-of-vital-interests / habitual-abode cascade to lean on.
The practical workaround is structural: keep no operating substance in Vanuatu. Use Vanuatu purely as the personal citizenship and tax-status anchor, and locate operating companies, IP, banking and counterparties in jurisdictions with active French treaties and clean ETNC status — typically the UAE for operations and banking, Singapore or Switzerland for prime brokerage, and a Cyprus or Luxembourg holding for an EU-resident corporate vehicle. Most French-Vanuatu founders end up in this paired structure regardless.
Step 5: First-year compliance and the inheritance-tax tail
In France, file a final partial-year return on form 2042 covering 1 January to your departure date for worldwide income, then a non-resident form 2042 NR for any retained French-source income (rental on French real estate, French dividends, retained French SAS director’s fees) thereafter. The article 167 bis declaration is filed on formulaire 2074-ETD in the year of departure and 2074-ETS3 annually thereafter for as long as the deferral runs. IFI continues at full rate on French real estate above €1.3M after departure — the move does not strip French property from the IFI base.
Vanuatu first-year compliance is by design trivial: there is no annual personal tax return because there is no income tax. CBI holders have no ongoing renewal; retiree-visa holders renew annually for ~US$400–800. The genuine compliance work for a French exiter sits not in Vanuatu but in the contemporaneous-evidence file: terminated French lease or notarised sale acte, utility cut-off notices, Vanuatu / paired-residency lease, day-count records, school enrolment, and source-of-funds dossiers ready for any DGFiP audit.
The trap that catches French nationals late is article 750 ter CGI: French inheritance tax can apply to a worldwide estate where the deceased was domiciled in France for at least 6 of the 10 years preceding death, or where the heirs are French-domiciled. Vanuatu has zero inheritance tax, but a French national who dies in Port Vila three years after departure may still leave a worldwide estate fully exposed to French succession tax through the heirs-domicile branch. Pre-departure use of donation-partage, family civil-law structures (SCI, SARL de famille), and the €100,000 per-child / €80,724 spouse abatements is the conventional workaround.
Cost & Timeline
| Phase | Cost (USD/EUR) | Time |
|---|---|---|
| French tax planning + valuation of shareholdings | €15K–€50K | 2–3 months |
| Bank guarantee / collateral for article 167 bis deferral | 0.5–1.5% of tax due/year | Locked for ≤15 years |
| Vanuatu DSP government contribution — single applicant | $130,000 | One-off |
| Vanuatu DSP government contribution — family of four | $180,000 | One-off |
| Vanuatu due-diligence fee (per adult) | ~$5,000 | One-off |
| Vanuatu licensed agent / legal | $15,000–$25,000 | 30–60 days to passport |
| Optional: paired UAE / Cayman residency for substance | $10,000–$30,000 | 1–3 months |
| Optional: Vanuatu retiree visa for 183-day anchor | $1,000–$3,000 + $24,000 p.a. demonstrated income | 1–3 months |
| Move + setup (lease, schools, banking) | $20,000–$60,000 | 1–2 months |
| First-year FR 2042 départ + 2074-ETD + non-resident filings | €5K–€12K | Annual |
| Total year-1 effective cost (single founder, CBI only) | ~$160,000–$200,000 ex. exit-tax cash | 2–4 months to passport |
| Total year-1 effective cost (family of 4, CBI + paired UAE) | ~$220,000–$260,000 ex. exit-tax cash | 3–6 months to full structure |
The structure is the inverse of the France-to-Portugal NHR or France-to-Italy impatriati corridor: capital-heavy at the door, but the timeline is the fastest in the entire matrix and the destination-side ongoing cost is effectively zero.
Treaty Considerations
The defining feature of the France-Vanuatu corridor is the complete absence of treaty cover. There is no double tax convention, no TIEA, and no agreement on the avoidance of double taxation. Where Cyprus, Malta or Singapore offer a French exiter a layered treaty safety net, and even Monaco offers a uniquely structured 1963 fiscal convention, Vanuatu offers nothing.
The practical implications run in three directions. First, on the income side, French-source flows to a Vanuatu resident are taxed at full domestic rates under articles 119 bis, 182 A, 182 B and 244 bis A CGI, with the 75% punitive withholding overlay where Vanuatu’s ETNC listing is active in the relevant year. Second, on the residency side, an article 4 B dispute opened post-departure runs purely through the faisceau d’indices without treaty assistance — meaning a contemporaneous evidence file and an affirmative second jurisdiction (UAE day-count, Cayman investor permit, Vanuatu retiree visa with 183+ days) is the only defence. Third, on the inheritance side, article 750 ter CGI runs without convention override, and there is no treaty mechanism (such as the FR-US, FR-UK or FR-DE estate-tax treaties) to displace it.
The compensating fact is that Vanuatu’s 0% regime is unilaterally generous on the inflow side — there is no Vanuatu tax to credit against, in the first place. Double taxation in the strict sense rarely materialises. The risk that does is single-sided punitive French taxation on items the DGFiP can still reach — French dividends, French real-estate gains, and the worldwide estate of a French national under the article 750 ter heirs-domicile rule.
Common Mistakes
- Treating Vanuatu like an EU exit. No treaty, no TIEA, no automatic article 167 bis deferral, no Article 4 tie-breaker, and the ETNC overlay on top. The planning checklist is materially longer than for Portugal, Cyprus or Singapore — and the post-departure French-source withholding is brutal where the ETNC listing applies.
- Holding the Vanuatu passport without a real day-count anchor. The passport itself is not residency. A Paris apartment kept “for visits” plus a Vanuatu passport plus 200 days of circulating travel is exactly what the DGFiP reads as preserved foyer under article 4 B.
- Locating operating substance in Vanuatu. As long as Vanuatu sits on the ETNC list, payments to Vanuatu counterparties trigger article 238 A’s reversed burden of proof, French dividend withholding to Vanuatu shareholders escalates to 75% under article 119 bis 2°, and the article 209 B CFC regime hardens. Use Vanuatu for the passport — operate elsewhere.
- Skipping the annual 2074-ETS3 filing. Deferred article 167 bis tax requires an annual declaration for the entire 15-year deferral horizon. Missing a single year unwinds the deferral, accelerates payment, and adds late-filing interest.
- Forgetting article 750 ter CGI. Vanuatu has 0% inheritance tax, but a French national whose heirs remain French-domiciled exposes the worldwide estate to French succession tax at up to 60%. The estate-planning side of the move is rarely the headline but is often the largest unmodelled risk.
- Posting Vanuatu collateral for the 167 bis guarantee. The DGFiP will not accept Vanuatu-located assets, particularly under an active ETNC listing. Plan French-custodied securities, a French bank guarantee, or a French real-estate hypothec from the start.
FAQ
Will I still have to file in France after moving to Vanuatu?
Yes. For the year of departure, a part-year avis de départ return on form 2042 covering worldwide income to the departure date and French-source income only thereafter. Then non-resident form 2042 NR returns annually for any French-source income retained — French rental income, French dividends, IFI on French property above €1.3M. If article 167 bis was triggered with deferral, you also file form 2074-ETS3 every year until the 15-year extinguishment or actual disposal.
Is there a tax treaty between France and Vanuatu?
No. Neither a comprehensive double tax convention nor a Tax Information Exchange Agreement is in force between France and Vanuatu. The DGFiP’s conventions internationales portal lists no Vanuatu entry. French-source withholding to a Vanuatu-resident beneficiary stays at full domestic rates, and there is no Article 4 tie-breaker available in a residency dispute.
Does article 167 bis apply if I move to Vanuatu?
If you hold portfolio shareholdings above €800,000 (or 50%+ of any single company) and were French resident for at least 6 of the 10 years preceding departure, yes. Vanuatu is non-EU/EEA, so deferral is not automatic — it requires application and the posting of financial guarantees (French bank guarantee or pledged French securities). The 15-year extinguishment horizon and annual 2074-ETS3 filing apply identically.
Is Vanuatu on the French ETNC list?
Vanuatu has appeared on the French liste des États et territoires non coopératifs (ETNC) under article 238-0 A CGI in recent updates. The list is fixed by joint arrêté of the Ministers of the Economy and the Budget and is reviewed annually; verify Vanuatu’s current status with the latest arrêté before transacting. Where the listing is active, the punitive overlay (article 119 bis 2° 75% withholding, article 244 bis A 75% real-estate gains, article 238 A reversed burden of proof, article 209 B harshened CFC) applies in addition to the standard non-resident regime.
Do I have to spend any minimum time in Vanuatu to keep the citizenship?
No. The DSP imposes zero physical-presence requirement before, during, or after approval. The passport is granted for life with no eligibility re-test on renewal. Standalone, however, the absence of day-count is the corridor’s biggest article 4 B weakness — anchoring tax residency credibly against the DGFiP typically requires either 183+ days physically in Vanuatu (retiree-visa route) or a paired residency in a higher-substance jurisdiction (UAE 90/180-day rule, Cayman investor permit) with its own day-count footprint.
How does Vanuatu compare to St. Kitts & Nevis or Monaco for a France exiter?
St. Kitts & Nevis wins on passport mobility (broader Schengen access on a stable basis) and has historically not appeared on the French ETNC list, which removes the article 119 bis 2° / 238 A overlay. Slower (4–6 months) and more expensive (US$250,000 minimum). Monaco offers a treaty (the unique 1963 fiscal convention with France) and 0% income tax for non-French Monégasque residents — but it is barred to French nationals on the income-tax side and requires substantial physical presence and a €500,000+ Monaco bank deposit. Vanuatu’s unique value is the 30–60 day passport timeline at $130K for non-French nationals with French residency, or for French nationals using Vanuatu purely as a citizenship anchor while operating from a treaty-protected jurisdiction.
How long does the full France-to-Vanuatu move take?
Realistic timeline 2–4 months from first planning meeting to Vanuatu passport — the fastest end-to-end CBI exit in the French corridor. Adding a paired UAE or Cayman residency for substance extends to 4–6 months. The French departure return, article 167 bis assessment, and bank-guarantee negotiation run in parallel and are usually the binding constraint, not the Vanuatu side.
Next Step
For the destination-side breakdown — DSP mechanics, retiree visa, Vanuatu banking — see Tax-Free Residency in Vanuatu. For the broader exit-tax framework that applies to every French departure, see How to Legally Exit a High-Tax Country. For the day-count rules that interact with article 4 B, see The 183-Day Rule Explained. For the operational pairing most Vanuatu founders end up in, see Tax-Free Residency in the UAE and the Crypto Founder Residency Guide.
Book a free consultation — we specialise in France-to-Vanuatu relocations, the article 167 bis deferral mechanics with non-EU collateral, the ETNC overlay, and the paired-residency structures that make Vanuatu credible against article 4 B scrutiny.
Last updated: 2026-04-27
Sources:
– Direction Générale des Finances Publiques — Article 167 bis CGI (exit tax) and article 4 B CGI residency rules: https://bofip.impots.gouv.fr/
– DGFiP — Liste des États et territoires non coopératifs (article 238-0 A CGI) and successive arrêtés ministériels: https://www.impots.gouv.fr/international-particulier/conventions-internationales
– France — list of double tax conventions in force (Vanuatu not listed): https://www.impots.gouv.fr/international-particulier/conventions-internationales
– Citizenship Office of the Republic of Vanuatu — Development Support Program (DSP): https://citizenship.gov.vu/
– PwC Worldwide Tax Summaries — France individual taxation and Vanuatu chapter: https://taxsummaries.pwc.com/france / https://taxsummaries.pwc.com/vanuatu
– Council of the European Union — EU list of non-cooperative jurisdictions for tax purposes: https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/