Leaving France: What 800 Departing Millionaires Teach Us About Tax Uncertainty

July 2026

By Will Glyn

Last Friday, Euronews asked a question that has been circling French dinner tables for a couple of years now: why are the country’s top earners leaving, and where are they going? The number doing the rounds comes from Henley & Partners, who projected that France would lose a net 800 millionaires over the course of 2025 — the first time they had forecast a net outflow from France at all.

On one reading, that’s nothing. UBS’s 2026 wealth report counts around 2.4 million dollar millionaires in France, and reckons the country added some 34,600 of them during 2025 — the biggest increase in the EU. Against that, 800 is a rounding error. But the people moving are concentrated at the very top, among the households with the most to lose and the least friction in leaving. When the most mobile money starts eyeing the exits, it’s rarely about this year’s tax bill.

And that’s the genuinely interesting part. France does already tax wealth — the IFI has applied to French property assets above €1.3 million since 2018 — but nobody is leaving over a levy that has been in place for eight years. They’re moving ahead of the taxes that might come next. Whatever your politics, and this piece has none, there’s a planning lesson in that for anyone who lives, owns or earns across borders.

What they’re running from isn’t a tax — it’s a question mark

The centre of the storm is economist Gabriel Zucman’s proposal: a 2% annual levy on fortunes above €100 million, paired with an exit tax that would have kept those who left on the hook for five years. Supporters say it would touch only around 1,800 households and raise somewhere between €15 and €20 billion a year. Critics dispute both numbers, loudly.

What matters for our purposes is the journey. The proposal passed the National Assembly in February 2025, was blocked by the Senate that June, and was defeated again in October during the 2026 budget debate. What survived instead was narrower: a 20% levy on non-productive assets held inside passive family holding companies worth €5 million or more, which takes effect this coming January and is expected to raise a fraction of the original. The budget carrying it only got through by decree and two failed no-confidence votes.

Now look forward. The 2027 budget reaches the National Assembly on 30th September, with the government hunting somewhere between €30 and €50 billion of savings, a minority it cannot reliably whip, and a presidential election the following April — first round on 18th April 2027. Zucman himself says his tax will be a defining issue of that campaign. Nobody, genuinely nobody, can tell you what French wealth taxation will look like two years from now.

That is the thing the departing millionaires are pricing. Not a 2% levy most of them would never pay, but the impossibility of planning around a system that reinvents its intentions every budget season. Uncertainty is a cost, and above a certain wealth level, relocation is simply what paying it looks like.

Where they’re going tells you what they’re buying

Look at Henley’s 2026 scoring and a pattern jumps out. It no longer tracks where millionaires actually go; it scores how attractive each jurisdiction looks to mobile wealth. On that measure Cyprus, the Netherlands, Portugal, Italy, Switzerland and Greece all sit near the top in Europe. The UK, Germany and France sit in a group Henley calls “competitive jurisdictions under pressure” — and France scores lowest of the three.

Switzerland offers its long-standing negotiated lump-sum arrangements, available in most cantons though not all. Italy sells certainty as a product: a flat annual charge on all foreign income for new residents, whatever that income turns out to be — and the price went up to €300,000 in January, from €200,000. Portugal’s narrower successor to its old NHR regime still gives qualifying professionals a defined deal. The common thread isn’t low tax; several of these places aren’t remotely cheap, and Italy just raised its price by half without denting demand. It’s predictability. People at this level aren’t buying rates. They’re buying the ability to plan a decade ahead.

The mechanics that catch people on the way out

For anyone tempted to follow, a word of caution from the trenches: leaving France is itself a tax event, and a badly sequenced departure can cost more than staying ever would.

France already applies an exit tax to large shareholdings when you transfer residence, and it keeps being proposed for tightening — an amendment lengthening the clawback period passed the Assembly last November before falling out of the final budget. It will be back. The timing of a mid-year move changes which country taxes what. Selling a business or property just before departure produces a very different outcome from selling just after. And French exposure doesn’t end at the border: property left behind stays firmly within reach of French tax, and French succession rules can still reach back to it in certain circumstances, whatever your new passport stamp says.

None of this is a reason to stay put. It’s a reason to plan the sequence before booking the movers — with a French tax specialist involved early. We’re financial planners rather than tax advisers, and this is exactly the terrain where the two need to work together.

If you live in France and aren’t going anywhere

Most people reading this aren’t running a nine-figure fortune, and aren’t leaving. But the lesson scales down surprisingly well, because uncertainty isn’t reserved for the ultra-wealthy — and the sensible responses are the same at any size:

• Don’t plan on headlines — most mooted taxes never become law, and reacting to each one is exhausting and expensive. Build a setup that would be robust under several outcomes, then let the politics play out.
• Keep your structures portable — hold investments in arrangements that survive a change of country without being dismantled. The people coping best with all this decided how to hold their wealth before they needed to move it.
• Diversify jurisdiction, not just assets — where your accounts, platforms and policies sit is a decision in itself. Spreading across borders isn’t exotic; it’s the financial equivalent of not keeping every document in one drawer.
• Know your exposure map — if a wealth levy arrived, what of yours would actually be in scope? The headline proposals start in the tens of millions, but the versions that actually pass tend to start far lower: the new holding-company levy bites from €5 million, and the IFI from €1.3 million. Knowing your own number replaces vague worry with an actual answer.
• Review before budget season — French fiscal drama crystallises every autumn. A calm review in September beats a panicked one in December, every single year.

How We Can Help

At Proctor Wealth Associates we work with internationals on both sides of this story — people building a life in France, and people planning a move away from it. We can help you:

• Stress-test your setup against uncertainty — so your plan works under multiple versions of the rules, not just today’s.
• Structure investments to travel — flexible, cross-border arrangements that don’t need rebuilding every time your residence changes.
• Sequence a move properly — the order of residency, sales and transfers decides the tax outcome; we plan it with you before anything is booked.
• Coordinate the specialists — we work alongside French tax and legal professionals, and can introduce you to the right ones.
• Keep the plan current — an annual review timed ahead of budget season, so changes reach you as adjustments rather than surprises.

If France is part of your life — as home, as a future move, or as the place you’re weighing leaving — you can book a call with me and we’ll look at what the uncertainty actually means for your numbers.

Will is an Independent Financial Adviser with over a decade of experience helping expats make the most of their international status.