France’s National Assembly Finance Committee approved a left-wing proposal that would require that wealthy French nationals continue paying domestic taxes for a decade after relocating to lower-tax jurisdictions.
The October 20 vote marks a legislative victory for La France Insoumise (LFI), the far-left party that has pushed for stricter controls on capital flight since 2019.
Amendment I-CF380 establishes what its authors call a “targeted universal tax” applying to persons of French nationality with income exceeding five times the annual social security ceiling (approximately €235,500 in 2025) who move to countries with tax rates at least 40% lower than France’s.
Finance Committee chair Eric Coquerel filed the measure on October 17 alongside around 70 LFI co-sponsors, targeting individuals who have lived in France for at least three years during the decade before changing their tax residence.
The proposal’s authors compare it to taxation systems in the United States and several European nations. The amendment text notes that extended taxation mechanisms exist in Sweden, Finland, and Germany, though France has historically refrained from such measures.
Key Provisions
The amendment modifies Article 4 bis of France’s General Tax Code (Code général des impôts) to create four core requirements, subject to tax treaties signed by France:
- Ten-year tax obligation following departure from France
- Income threshold set at five times the social security ceiling (approximately €235,500 in 2025)
- Minimum three-year French residency in the decade preceding relocation
- Tax credit for foreign taxes already paid in the new country of residence
The measure applies only to moves targeting jurisdictions with substantially lower tax rates. Countries must have taxation on work income, capital, or assets at least 40% below French rates to trigger the obligation.
Political Rationale
The amendment’s explanatory statement frames the proposal as a response to what it describes as competitive tax reduction between nations.
According to the text, current policy allows “the wealthiest taxpayers and multinationals to circumvent taxes” through international relocation.
Coquerel and his co-sponsors argue that the existing system creates an imbalance.
The proposal quotes Tocqueville’s observation about the Ancien Régime, noting that taxation policy should not be designed to “affect those most able to pay it, but those most incapable of defending themselves against it.”
The amendment resurrects a 2019 recommendation from a parliamentary fact-finding mission on universal taxation that Coquerel and centrist deputy Jean-Paul Mattei co-authored.
The proposal revives previous similar proposals from 2019 and 2024 that failed to advance through the legislative process.
Compatibility and Implementation
LFI legislators structured the amendment to comply with European Union law and France’s existing bilateral tax treaties.
The proposal explicitly states that it remains “subject to tax treaties signed by France,” acknowledging the hundreds of international agreements that could limit its application.
The tax credit mechanism prevents double taxation by allowing French nationals to deduct foreign taxes already paid. French authorities would calculate only net amounts due after accounting for obligations in the new country of residence.
The measure targets what its authors characterize as tax havens while maintaining diplomatic relationships with treaty partners.
This approach differs from blanket exit taxes that some jurisdictions impose regardless of the destination country.
Revenue and Equity Arguments
The amendment’s proponents frame the measure as both a revenue tool and an equity mechanism.
They argue it would address what they call “the problem of lower revenues” while improving public acceptance of taxation among French citizens who remain in the country.
Legislative Pathway
The committee’s adoption represents an initial legislative hurdle rather than final passage.
The full National Assembly must examine the Finance Bill for 2026 in plenary session, where the amendment could be retained, modified, or rejected during debate.
Following Assembly approval, the bill advances to the Senate for review. The Senate can propose its own modifications to the text, potentially including changes to this amendment.
If the two chambers disagree on the final text, a joint committee convenes to seek compromise language.
Once both houses reach an agreement or the National Assembly exercises its constitutional authority to override the Senate, the bill receives a final vote. The President then signs the measure, and it is published in the Journal officiel, making it law.
The measure’s fate remains uncertain given France’s fragmented parliament. LFI holds fewer than 100 seats in the 577-member chamber and would need support from other left-wing factions or centrist deputies to secure passage during floor debates.
Implementation would require regulatory decrees and coordination between France’s tax authority and foreign counterparts to track income and verify foreign tax payments.
