How to Leave France for Thailand Without a Tax Audit?

📅 Published in 2017 — Updated in June 2026
⚖️ Exit tax, Thai tax reform 2024, bilateral convention: the rules have changed.

⚖️ Tax Guide 2026 — Leaving France for Thailand

🏛️ Exit Tax (article 167 bis CGI)

Source: impots.gouv.fr — March 2026 version.

Are you affected? 3 cumulative conditions:

1. 🇫🇷 French tax residence for ≥ 6 of the last 10 years
2. 💼 Movable assets (shares, company shares) ≥ €800,000 — OR ownership ≥ 50% of a company
3. ✈️ Effective transfer of tax domicile outside France

What IS NOT concerned: direct real estate, life insurance, SICAV/FCP, current accounts.

2026 rate: 30% (PFU) = 12.8% IR + 17.2% social security contributions.

⏳ Suspension of payment:

• 🇪🇺 To EU/EEA: automatic reprieve
• 🇹🇭 To Thailand: reprieve on request (form 90 days before departure + guarantees)

✅ Reduction (cancellation of tax):

• < 2 570 000 € → dégrèvement après 2-year securities without sale
• Securities ≥ €2,570,000 → relief after 5 years without sale
• ⚠️ Sale during the suspension = tax immediately due

Forms: 2074-ETD (start) + 2074-ETSL (annual follow-up).

🇫🇷🇹🇭 France-Thailand Tax Convention (1974)

Management: DGFIP (France) + Revenue Department (Thailand).

• ✅ Private pension (AGIRC-ARRCO, CNAV) → Taxed in France, exempt in Thailand
• ✅ Civil service pension → Taxed in France, exempt in Thailand
• 🏠 Real estate income France → Taxed in France, tax credit in Thailand
• 💼 Income from work in Thailand → Taxed in Thailand

🆕 Thai tax reform (January 1, 2024)

Clarified by: Embassy of France in Thailand + Revenue Department Thai (th.diplomatie.gouv.fr).

✅ French pensions imposed in France are exempt in Thailand (article 23 of the convention). They do not have to be declared in the Thai declaration.

🏥 Mandatory O-A visa insurance (since October 2019)

• 🏨 Hospitalization: ≥ 400,000 ฿
• 🩺 Outpatient: ≥ 40,000 ฿
• 🦠 COVID (since 2021): ≥ 3,000,000 ฿
• 📋 Approved insurers: tgia.org | Foreign insurer: Foreign Insurance Certificate required

💡 My experience

I have lived between the United Kingdom and Thailand since 2019. The key: prepare your tax exit BEFORE leaving. €500 consultation with a specialist tax lawyer can save you tens of thousands of euros.

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⬇️ The original article is just below — the basics remain the same, the context has changed

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