France–United Arab Emirates (Dubai) cluster
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French expatriate in the UAE: obligations on both sides and compliance

Settling in Dubai is not enough to leave French taxation behind. Between the residence criteria, the exit tax, the automatic exchange of information and precise reporting obligations, the French expatriate must secure every step. The firm, admitted to the Paris and Geneva Bars, sets out here the full journey, on both the French and Emirati sides.

Request a confidential first exchange Your obligations
Guide based on primary sources (Article 4 B and Article 167 bis of the CGI, impots.gouv.fr, OECD standards) as of 1 July 2026. Certain thresholds are indicated subject to verification according to the individual situation.
— In brief
Residence
Alternative criteria of Article 4 B of the CGI: home, activity, centre of economic interests. Any one is enough.
The 183-day myth
The 183-day threshold is not the domestic-law criterion; it only applies as a treaty clause for salaries.
Exit tax
Applicable from EUR 800,000 of securities (or 50% of company profits) after 6 years of residence out of 10; rate of about 31.4% in 2026.
Automatic exchange
CRS active with the UAE since 2018; CARF on crypto-assets from 2026, first exchanges in 2027.
Filings
2042-NR for French-source income; 3916 for accounts held abroad as long as French residence remains.
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The benchmarks to know before leaving

A move to the United Arab Emirates raises three families of questions: am I genuinely a non-resident, do I owe an exit tax, and are my Emirati accounts visible to the French tax authorities? The answer to each determines the applicable regime and the risk of reassessment.

The Emirati appeal lies in zero personal taxation. But expatriation does not erase French obligations as long as tax residence has not been genuinely and demonstrably transferred. The benchmarks below frame the matter before the detail of the steps.

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Issues and obligations

Being genuinely a non-resident: beyond the 183-day myth

French domestic law sets tax domicile in Article 4 B of the CGI, according to alternative criteria: having in France your home or main place of stay, carrying out your professional activity there, or having there the centre of your economic interests. A single criterion is enough to connect a person to France. The 183-day myth deserves to be dispelled. This threshold is not the domestic-law criterion: the main place of stay means spending more time in France than in any other country, not crossing a 183-day counter. The 183-day rule only comes into play under the treaty, for salaries. An expatriate whose income mainly comes from a French company may thus remain a French tax resident through the sole operation of the centre of economic interests, even while living mostly in Dubai. The transfer of domicile must therefore be genuine and demonstrable: home relocated, activity relocated, accounts and substance present on site. The automatic exchange of information makes a fictitious residence quickly detectable. The firm builds the evidence file before departure, in Paris as in Geneva.

Exit tax and automatic exchange of information

The exit tax (Article 167 bis of the CGI) applies to anyone who has been a French tax resident for at least 6 of the 10 years preceding departure and holds securities with an overall value of at least EUR 800,000 or representing at least 50% of a company's profits. The rate, in 2026, combines the flat levy of 12.8% and social levies raised to 18.6%, i.e. a total of about 31.4% depending on the situation. Towards the UAE, there is no automatic deferral — that is reserved for the European Union and the EEA. Here the deferral is on option: it requires an express request via form 2074-ET and the provision of guarantees (mortgage, bank guarantee). The deferred tax is then written off after 2 years (wealth below EUR 2.57M) or 5 years of holding the securities. Latent capital gains on crypto-assets remain, to date, outside the scope of the exit tax. On the transparency side, the UAE has applied the CRS since its first exchanges in 2018: Emirati bank accounts become visible to the French tax authorities. The CARF, the OECD framework on crypto-assets, provides for collection from 1 January 2026 and first exchanges in 2027. Banking secrecy is not enforceable: any fictitious residence carries a high risk.

French reporting obligations: the year of departure and after

In the year of departure, the return comprises two parts: worldwide income received as a resident, from 1 January to the date of departure, then French-source income received as a non-resident, via the supplementary return 2042-NR. Once a non-resident, French taxation applies, subject to the treaty, only to French-source income (form 2042-NR, supplemented where applicable by form 2047). A minimum rate of 20% applies to a non-resident's French-source income, raised to 30% above a certain threshold, unless the taxpayer opts for the average worldwide rate where it is lower. Form 3916 requires the reporting of any bank account or digital-asset account opened, held, used or closed outside France as long as the person remains a French tax resident. For a genuine non-resident, the 3916 obligation on Emirati accounts disappears, but it remains central during the transition phase and where residence is disputed.

Compliance, step by step

Securing a move to Dubai follows an orderly sequence. First, assess residence: verify that no criterion of Article 4 B nor the treaty cascade connects the taxpayer to France. Next, measure the exit tax: value the securities, the 6-out-of-10-years condition, and decide between immediate payment and deferral on option backed by guarantees. Third, organise the filings: return for the year of departure, switch to the 2042-NR, management of form 3916 during the transition. Fourth, build the evidence file: lease or ownership in the UAE, proof of activity, local accounts, effective presence — enough to withstand a challenge based on automatic exchange. Finally, anticipate the wealth aspects: IFI on French real estate, dividends and withholding tax, transmission. The firm Bensaid Avocats carries out this compliance from end to end, combining French domestic law and the bilateral treaty. Our Paris and Geneva offices ensure the long-term follow-up of a France–UAE matter, including in the event of an audit.

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Lead counsel — Me Jonathan Bensaid

Me Jonathan Bensaid, founding partner, advises UHNWIs, family offices, executives and non-residents on international wealth taxation and cross-border compliance. The firm is admitted to the Paris & Geneva Bars.

  • tax expatriation
  • Dubai
  • exit tax
  • tax residence
  • CRS
  • CARF
  • non-residents
— Frequently asked questions

Expatriation to the UAE is prepared, not improvised

Is living more than six months in Dubai enough to no longer be taxed in France?

No. The 183-day threshold is not the French residence criterion. Keeping your home, your activity or the centre of your economic interests in France may maintain French tax residence, regardless of the number of days spent abroad.

Will I pay the exit tax when leaving for Dubai?

The exit tax applies if you have been resident for 6 out of 10 years and hold at least EUR 800,000 of securities or 50% of a company's profits. The rate is around 31.4% in 2026. A deferral is possible on option, with the provision of guarantees.

Can the French tax authorities see my accounts in Dubai?

Yes. The UAE has applied the CRS since 2018: bank accounts there are exchanged with France. From 2026, the CARF will extend this transparency to crypto-asset accounts, with first exchanges in 2027.

Which forms must I file after my departure?

In the year of departure, a two-part return with the 2042-NR. Thereafter, the 2042-NR for French-source income (and form 2047 where applicable), as well as form 3916 for foreign accounts as long as French residence subsists.

Does a minimum tax rate apply to my French income?

Yes. A non-resident's French-source income is subject to a minimum rate of 20%, raised to 30% above a certain threshold, unless the taxpayer opts for the average worldwide rate where it is more favourable.

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Preparing and securing your move to the UAE

A well-prepared move to Dubai provides lasting protection; poorly prepared, it exposes you to the exit tax, to a reassessment for fictitious residence and to claims under automatic exchange. The firm Bensaid Avocats, admitted to the Paris and Geneva Bars, assists French expatriates at every step: assessment of residence, exit tax, filings and evidence file. An initial discussion allows us to establish your roadmap.

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This page presents a general analysis as of 1 July 2026 and does not constitute personalised tax advice. Certain thresholds and guarantee amounts are indicated subject to verification according to the situation. Every situation calls for an individual review by a lawyer.