Bilateral Practical Guide
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Israeli Resident or Olé Connected to France: Obligations and Compliance

You have made your aliyah or you are an Israeli resident while retaining ties to France: property, accounts, income or family. Since the activation of the automatic exchange of information and the reinstatement of the reporting obligation for olim, the historic opacity has disappeared. The firm Bensaid Avocats, admitted to the Paris and Geneva Bars, sets out your obligations on both sides and a step-by-step method for bringing your affairs into compliance.

Request a confidential first exchange Your obligations
Guide written by tax lawyers admitted to the Paris and Geneva Bars. Informational content that does not constitute personalised advice.
— In brief
Dual residence
Resolved by the tie-breaker of Article 4: home, vital interests, habitual abode, nationality.
Foreign accounts
Mandatory reporting via form 3916 / 3916 bis for the French resident.
Penalty
EUR 1,500 per undeclared account per year; the reassessment period extended to 10 years.
Transparency
Automatic CRS exchange effective since 2019, extended to crypto-assets in 2026.
Olim reporting
Reinstated on 1 January 2026, while the ten-year exemption is maintained.
— 01

Where Is Your Tax Residence?

The first, defining question is that of tax residence. Each State first applies its own domestic law. France uses the criteria of Article 4 B of the CGI: home, principal place of stay, principal professional activity or centre of economic interests. Israel applies its own criteria. The same taxpayer may therefore, at first, be regarded as a resident of both countries.

The conflict is then resolved by the treaty tie-breaker of Article 4: permanent home, then centre of vital interests, then habitual abode, then nationality, and failing that mutual agreement of the authorities. The classic case of the recent olé illustrates the risk: an effective aliyah but a home, a family or economic interests remaining in France may tip the centre of vital interests towards France.

The status of Israeli resident and the benefit of the olim exemption are therefore not sufficient, in themselves, to displace French tax residence. This is the first point to secure, for it governs all of your reporting obligations.

— 02

Issues and obligations

Your Obligations on the French Side

If you are a French tax resident, or an olé who has retained a sufficient connection to France, several reporting obligations apply. Bank accounts, digital-asset accounts and life-insurance or capitalisation contracts held abroad must be reported via form no. 3916 / 3916 bis, attached to the 2042 return. The failure is heavily penalised: the fine amounts to EUR 1,500 per undeclared account per year. It would be raised to EUR 10,000 for a State without an administrative-assistance agreement with France; as Israel has such assistance, the amount remains EUR 1,500. Above all, the reassessment period is extended from three to ten years in the event of a failure, which considerably widens the period open to audit. If you retain real-estate assets in France, you remain liable for the IFI where the net taxable value exceeds EUR 1,300,000. French-source property income and real-estate capital gains remain taxable in France, the capital gain falling under the non-resident regime when you are domiciled in Israel. These obligations do not depend on the Israeli olim regime: they stem from French law and from the French location of the assets or of your residence. Ignoring them exposes you to a ten-year reassessment, with interest and penalties.

Your Obligations on the Israeli Side

On the Israeli side, the new-immigrant regime (Olim Hadashim) remains highly favourable: the ten-year exemption on foreign-source income remains in force. It covers interest, dividends, rents from property located outside Israel, royalties, certain capital gains and remuneration from an activity carried out abroad. The major change takes effect on 1 January 2026: the obligation to report this foreign income is reinstated. The tax exemption subsists, but reporting secrecy comes to an end. In concrete terms, you keep the tax advantage, but you must henceforth report the income concerned to the Israeli authorities, subject to the definitive terms of entry into force. This reinstatement is part of a broader move towards transparency. Israeli and French filings must therefore be carefully coordinated, for the same income may be subject to obligations in both countries even if it is effectively taxed in only one of them. Coordinating the two systems is the heart of the compliance work.

The Automatic Exchange of Information

The era of compartmentalisation between the two administrations is over. Israel adopted the CRS law on 2 January 2019 and has since exchanged, automatically and annually, information on financial accounts held by residents of more than 150 participating jurisdictions. France and Israel thus transmit to each other the account data of their respective residents. The CRS 2.0 revision, finalised by the OECD in 2023 and transposed into French law by Decree no. 2025-1277 of 19 December 2025, takes effect on 1 January 2026. It notably broadens the scope of the exchange to crypto-assets. Combined with the reinstatement of the olim reporting obligation, this development makes visible, on both sides, an olé who holds accounts or assets in France. The practical consequence is simple: an incomplete declaration now has a high probability of being detected by cross-checking. Voluntary regularisation, ahead of any audit, remains the most protective and least costly route.

Step-by-Step Compliance

A methodical clean-up generally follows six steps. Step one: determine your tax residence precisely, applying domestic laws and then the treaty tie-breaker of Article 4, so as to know which country has the right to tax you and on what basis. Step two: list all of your assets and income in both countries (accounts, life insurance, securities, real estate, crypto-assets). Step three: identify the applicable reporting obligations on each side, notably form 3916 / 3916 bis and the IFI in France, and the reinstated Israeli filings for olim. Step four: assess past failures and their bearing on the ten-year reassessment period, in order to quantify the exposure. Step five: prepare a voluntary regularisation where accounts or income have not been reported, prioritising the initiative ahead of any audit. Step six: structure for the future, calibrating the ownership of assets and anticipating transmissions, a particularly sensitive subject given the absence of an inheritance treaty between the two countries. The firm Bensaid Avocats, in Paris and Geneva, conducts this process end to end: residence diagnosis, mapping of assets, regularisation and forward-looking protection. As each file is unique, these steps must be adapted to your actual situation and to the timetable of the reforms.

— 03

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.

  • olé
  • aliyah
  • tax compliance
  • foreign accounts
  • automatic exchange
  • CRS
  • tax residence
— Frequently asked questions

Transparency Demands Anticipation

Am I a French tax resident despite my aliyah?

It is possible if your home, your family or your economic interests remain in France. The question is resolved first under Article 4 B of the CGI, then by the treaty tie-breaker of Article 4: permanent home, centre of vital interests, habitual abode, then nationality. The olim exemption does not prejudge this classification.

Must I report my Israeli accounts to France?

Yes, if you are a French tax resident. Bank accounts, digital-asset accounts and life-insurance contracts held abroad must be reported via form 3916 / 3916 bis, attached to the 2042 return. The omission exposes you to EUR 1,500 per account per year, with a ten-year reassessment period.

Does the olim exemption remain in force in 2026?

Yes. The ten-year tax exemption on foreign-source income remains. What changes on 1 January 2026 is the reinstatement of the obligation to report this income in Israel, subject to the definitive terms of entry into force.

Can the French authorities see my accounts in France?

Yes. Thanks to the automatic CRS exchange active between France and Israel since 2019, and reinforced by CRS 2.0 in 2026, the two administrations transmit information on the financial accounts of their residents. An incomplete declaration has a high probability of being detected by cross-checking.

How can undeclared accounts be regularised?

The most protective route is voluntary regularisation, undertaken ahead of any audit: listing of assets, identification of missed obligations, quantification of the ten-year exposure, then a corrective filing. The firm, in Paris and Geneva, assists with this process and its forward-looking protection.

Cité par

Taking Stock of Your France–Israel Situation

Between reinforced CRS transparency and the reinstatement of olim reporting, compliance can no longer wait. The firm Bensaid Avocats, admitted to the Paris and Geneva Bars, establishes your residence diagnosis, maps your assets and secures your regularisation.

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Jonathan Bensaid, avocat fondateur

Written by

Me Jonathan Bensaid, avocat fiscaliste, fondateur du cabinet Bensaid Avocats, inscrit aux Barreaux de Paris & Genève.

Informational content current as of 1 July 2026, not constituting personalised legal or tax advice. The reinstatement of the olim reporting obligation and the terms of the exit-tax deferral must be confirmed against the texts in force. The firm Bensaid Avocats, Paris and Geneva Bars.