Cyprus Non-Dom for French Residents — PFU, Exit Tax and the DTT

France taxes residents on worldwide income. Dividends are taxed at 30% under the PFU (prélvevement forfaitaire unique — 12.8% tax + 17.2% social charges), or optionally at the progressive income tax scale (0–45% plus 17.2% social charges) if that produces a lower rate for low-income taxpayers. The PFU is the default and applies to most dividend income.

The exit tax (taxe d'expatriation) applies when you transfer your tax residence outside France and hold shares or securities worth €800,000 or more. The unrealised gain on those shares is taxed as if you had sold them on the day before departure. The gain is calculated at market value minus acquisition cost. Payment can be deferred (sursis de paiement) in instalments, but the liability crystallises on departure.

The €800,000 threshold is per taxpayer — a couple can hold €1,600,000 of shares before the exit tax applies. The 15-year rule: if you remain outside France for 15 years, the exit tax is automatically cancelled. If you return within 15 years, the exit tax becomes payable (with credit for any tax paid in the destination country). If you sell the shares within 15 years, the deferred tax becomes payable immediately.

French-source income remains taxable in France regardless of residence. French dividends, French rental income, French employment income, and French capital gains are all taxed in France. The France-Cyprus DTT allocates taxing rights — French-source income stays with France. Foreign dividends and interest are not taxed in France once you are non-resident.

The France-Cyprus DTT follows the OECD model. Dividend withholding is limited to 15% (5% for 10%+ corporate shareholders). Interest is 0% in most cases. Royalties are 10%. The tie-breaker for dual residency: permanent home, centre of vital interests, habitual abode, nationality. French nationality is the final tie-breaker.

France applies anti-abuse rules (Code général des impôts Article 238 A and the EU Anti-Tax-Avoidance Directive / ATAD). Structures designed solely to avoid French tax may be challenged. If you move to Cyprus with genuine substance — real residence, real business activity — the treaty applies normally. Shell structures without substance are at risk.

French-source dividends: if you receive dividends from a French company while Cyprus-resident, France withholds 15% under the DTT (or 25% without treaty relief). As a non-dom, you pay 0% SDC, but the French withholding is a final cost. The PFU does not apply to non-residents — only the 15% treaty withholding applies.

Capital gains: the treaty allocates taxing rights on share disposals based on whether the shares are in real property companies. Gains on French real estate are taxed in France. Gains on other shares are taxed in the country of residence — so Cyprus-resident non-doms selling non-real-estate French shares pay 0% in Cyprus (0% SDC for non-doms on non-Cyprus shares). But the exit tax may have already crystallised the gain on departure.

As an EU citizen, you have freedom of movement. Register your residence with the Cypriot immigration office (MEU1). After 5 years of continuous legal residence, apply for permanent residency (MEU2). No immigration barriers for French nationals.

French residency is based on the household (foyer fiscal) test and the 183-day rule. You are French resident if your household or principal place of abode is in France, or if you spend more than 183 days in France, or if your principal professional activity is in France. To cease being French resident, move your household to Cyprus and spend fewer than 183 days in France.

The 60-day rule (from 2026, no non-residency requirement) is relevant if you want to split time. You need 60 days in Cyprus, under 183 in France, a Cyprus business tie, and a permanent residence. Since French residency uses both the household test and the 183-day test, moving your household (spouse, children) to Cyprus is the strongest signal of non-residency.

If you are a French national considering a move to Cyprus, the first step is confirming your domicile of origin is outside Cyprus — which it is, if your father was domiciled in France. Then establish tax residency through the 183-day or 60-day route, submit form TD38 to claim non-dom status, and begin tracking your 17-year clock.

For the residency mechanics, use our residency day checker. For the full non-dom rules, see the non-dom pillar page. Fifteen minutes with our advisory team will confirm whether you qualify, what it saves, and whether you are owed a DDD refund.