Exit tax: MPs restore the fifteen-year rule, wealth created in France must contribute to France

On Friday 30 October, during a sitting devoted to the revenue side of the 2027 budget, the National Assembly passed an amendment that tightens the exit tax, the levy on the unrealised capital gains of wealthy taxpayers when they move their tax residence abroad. Won in a sparsely filled chamber, the vote nonetheless says a great deal about the state of the tax debate a few months before the presidential election.

What was voted

According to LCP, the parliamentary channel, the amendment was adopted by 31 votes to 20, with 35 abstentions. It restores the original rule: to escape for good the tax on the gain recorded at the time of departure, one would once again have to hold one's shares for fifteen years after leaving France.

To understand what is at stake, we need to look back. The exit tax was created in 2011, under the presidency of Nicolas Sarkozy, to prevent a major shareholder from moving to a lower-tax country just before selling their company. The 2019 finance law, LCP recalls, cut this period from fifteen years to two or five years depending on the case. In practice, an entrepreneur who moves abroad and waits a few years before selling their stake can today see the tax fall away.

The amendment defended by the ecologist Éva Sas joined similar proposals from the Socialist, Communist and Les Démocrates groups, according to LCP's account. MPs from the central bloc also argued for a return to the original scheme.

The positions at play

The objections must be heard fairly. The budget's general rapporteur, Philippe Juvin (Droite républicaine), did not oppose the measure head-on, according to LCP. But he pointed to a modest yield, around 25 million euros a year between 2011 and 2016, and warned of a signal that could deter some investors from settling or staying in France. This is the classic attractiveness argument: taxation perceived as punitive would drive away capital and talent.

The government chose a middle path. It did not support the amendment as it stood, without opposing it to the point of defeating it. The Minister for Public Action and Accounts, David Amiel, opened the door to "durées intermédiaires" (intermediate periods) in the compromises to come, LCP reports.

On the left, by contrast, it is seen as correcting a 2019 decision regarded as unfair. Éva Sas described the reform of the time as a gift to the wealthiest, according to LCP's account of the sitting.

Analysis: a matter of principle more than revenue

The low-yield argument deserves to be taken seriously, but it partly cuts the other way. An exit tax is not designed to fill the coffers: it is designed to deter. If it brings in little, it is also because it works as a dam. Its purpose is to ensure that the capital gain built up over years in France, thanks to its infrastructure, its workforce trained by public schools and its health system, does not vanish at the very moment it is realised.

As for the fear of exile, the available research calls for nuance. A note from the Conseil d'analyse économique published in summer 2025, summarised by Public Sénat, concluded that higher taxation of large fortunes does speed up departures, but that the effect remains marginal for the French economy. According to that document, only 0.28% of households in the wealthiest 0.1% had left France for tax reasons in 2017. The authors considered that tax optimisation weighed more heavily than emigration in revenue losses. That is precisely what the exit tax seeks to limit.

This vote is part of a series. On 27 October, the Assembly scrapped, against the government's advice, the renewal of the surtax on the profits of very large companies, by 79 votes to 77, according to Moneyvox. The same week, it narrowly adopted a Communist amendment aimed at taxing multinationals on the share of their global profits made in France, according to LCP. These votes, shifting with attendance, sketch out a zigzagging tax policy that is hard to read for citizens and businesses alike.

Their impact remains uncertain, moreover. The formal vote on the revenue section is scheduled for 3 November, according to the National Assembly's website, and several observers expect it to be rejected, which would send the original text to the Senate. Without a majority, the government could resort to Article 49.3 or to ordinances, and then choose what it keeps from the debates.

Conclusion: setting a stable rule

For a right faithful to a sense of the State, the question is not to punish success, but to defend a simple idea: wealth created in France must contribute to France, and consent to taxation requires that everyone, including the most mobile, bear their fair share. Created under a right-wing government, the exit tax is no partisan whim.

The compromise mentioned by David Amiel may be a good thing if it leads to a lasting rule, rather than yet another back-and-forth as majorities shift. A clear holding period, coupled with a public evaluation of the scheme by the Cour des comptes or the Conseil des prélèvements obligatoires, would at last make it possible to decide on the facts. That is the real question: if it forces the budget through, will the government agree to keep what the Assembly voted in favour of tax fairness?

Article written with the help of artificial intelligence.