Aliyah from France: Complete Tax Guide for 2026

    French olim face Europe's most punitive exit-tax regime alongside one of the most favorable inbound regimes in Israel. Coordinated planning between the two systems is non-negotiable.

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    Last reviewed May 2026 by Tax-IL Editorial, CPA (Israel)

    TL;DR for French olim:

    • Article 167 bis exit tax applies, but deferral and eventual cancellation are typically available.
    • Close or unwind PEA before departure to lock in French tax-free status.
    • Assurance-vie often needs restructuring to align with Israeli post-exemption taxation.
    • French real estate keeps generating IFI and French-source income tax — restructure or sell pre-Aliyah.
    • The 10-year Israeli exemption window is ideal for pension drawdowns and large foreign-source disposals.

    The Exit Tax — Article 167 bis CGI

    When a French tax resident transfers residence abroad, holding either: (a) securities worth ≥€800,000, or (b) ≥50% of a company's profits, France imposes immediate tax on latent gains and certain claims. The taxpayer can request automatic deferral when moving within the EU/EEA or to states with a tax-and-mutual-assistance agreement — Israel qualifies for deferral subject to filing requirements.

    The tax is cancelled (degrèvement d'office) if the assets are still held after the relevant period (now 2 years for portfolios under €2.57M, 5 years above). Selling triggering assets during the holding period triggers payment.

    Practical workflow:

    • Identify all securities and corporate holdings as of departure.
    • Form 2074-ET filed with the year-of-departure return.
    • Track holdings annually with Form 2074-ETD.
    • Don't sell triggering positions during the holding period.
    • Track the cancellation date carefully — that's when the planning truly delivers.

    PEA and Assurance-Vie: The Wrapper Problem

    PEA

    A PEA held more than 5 years is income-tax-free in France (social charges still apply). Many olim close the PEA before departure to bank the favorable French treatment, since the wrapper's value diminishes once non-resident.

    Assurance-vie

    Assurance-vie remains a powerful structure even for non-residents, but Israel taxes contract gains after the 10-year exemption ends. Pre-Aliyah review questions:

    • Is the contract older than 8 years (best French regime)?
    • Should you migrate to a Luxembourg-domiciled wrapper for cross-border flexibility?
    • Is partial surrender pre-Aliyah optimal to reset basis?

    Real Estate and IFI

    French real estate continues generating:

    • Income tax on rental income at non-resident rates (with treaty relief).
    • IFI wealth tax above €1.3M net French real-estate holdings.
    • Plus-values immobilières on sale.

    Common restructuring: sell underperforming positions pre-Aliyah, retain primary holdings through an SCI or SARL where appropriate, and monitor the IFI threshold.

    Pre-Aliyah Checklist for French Residents

    • Identify exit-tax exposure and prepare Form 2074-ET.
    • Decide on PEA closure or maintenance.
    • Review assurance-vie contracts and wrapper jurisdiction.
    • Address French real estate (sell, restructure, or keep with IFI plan).
    • File a déclaration de départ and update tax address.
    • Document residence transition under CGI Article 4B.
    • Plan succession-tax exposure separately.
    • Coordinate with Israeli pre-Aliyah advisor on the 10-year window strategy.

    The France-Israel Treaty — Key Articles

    • Article 4 (Residence): tie-breaker tests — center of vital interests, habitual abode, nationality.
    • Article 6 (Immovable property): France keeps taxing rights on French real estate.
    • Article 13 (Capital gains): generally taxed in the residence country, with real-estate carve-outs.
    • Article 18 (Pensions): private pensions usually taxed in residence country — Israel for olim.
    • Article 23 (Relief from double taxation): the FTC framework.

    Year-by-Year Timeline

    • Year −1 to 0: Exit-tax filing, PEA closure, real-estate restructuring, déclaration de départ.
    • Year 1: Israeli filing as oleh; French exit-tax deferral tracking begins.
    • Years 2–5: Cross the exit-tax cancellation threshold; track Form 2074-ETD.
    • Years 1–10: Use exemption window for pension drawdowns and asset realignment.
    • Year 11+: Full Israeli worldwide taxation; French-source income coordinated via treaty.

    Pair this with our 10-year exemption deep dive and run estimates in the Aliyah Tax Calculator.

    Not sure how this applies to you?

    One free 30-minute call. Tell us the situation in a line — we'll reply with the specific rule that applies to you.

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    Frequently Asked Questions

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