Expatriation to Switzerland involves more than just a change of residence: it also entails a complete review of the tax situation, income and assets held. In the event of an ill-prepared departure, each category of investment or remuneration may trigger specific tax obligations in France, Switzerland, or both. Careful anticipation is essential to control flows, avoid conflicts of residence and manage the consequences of a departure on existing wealth structures.
Income to watch before you leave
Stock options and free shares
Deferred profit-sharing schemes (bonus shares, stock options) call for particular attention in the event of mobility. When part of the vesting or exercise period takes place in France, the tax authorities may consider that a portion of the capital gain remains taxable in France. The applicable regime depends on whether the gain is professional or not, the exercise date and the nature of the plan. A chronological breakdown of rights and detailed documentation are necessary to avoid any double taxation.
Cryptoassets and digital assets
Cryptocurrency portfolios should be examined prior to any change of residence. Transfers made before departure are subject to the French system (flat tax or scale), while after departure, Swiss rules apply depending on the status of the holder and the canton. An arbitration on the time of sale can be carried out to secure the applicable tax regime and prevent gains from being reclassified as professional income at a later date.
Employee savings and profit-sharing
Employee savings products (PEE, PERCO) benefit from a favorable framework in France. In the event of unlocking after departure, certain exemptions may no longer apply if the taxpayer has become a non-resident. In such cases, taxation depends on the country of residence, payment dates and associated social security regimes. Any withdrawal strategy must be anticipated, particularly in the months preceding the transfer of residence.
Impact on savings and insurance contracts
PEA and life insurance contracts
Transferring residence outside France renders PEAs inactive, but preserves their tax-exempt status. In the case of life insurance policies, the applicable tax regime depends on the investor’s place of residence at the time of surrender. Depending on the length of time the policy has been held and the date of subscription, tax arrangements may change. Arbitration before departure may be appropriate.
Bank accounts and financial investments
All accounts opened, held or closed abroad must be declared to the French tax authorities using form 3916. This obligation continues as long as the taxpayer remains a French tax resident. Failure to do so may result in financial penalties. Foreign-source income, including investments and interest, must also be included in the tax return using form 2047. Before changing residence, you should review your investment vehicles.
Logistical and regulatory aspects of departure
Transfer of goods and customs formalities
A cross-border move involves making an inventory of the goods being transferred. Valuable objects, vehicles, works of art and collections require special customs treatment. Careful preparation is essential to avoid any blockage or taxation upon entry into Switzerland.
Social protection and health insurance
Expatriation alters the taxpayer’s social security rights. Depending on the status chosen (frontier worker, self-employed, seconded or permanent resident), different regimes apply. It is important to determine the options available: affiliation to the LAMal, membership of the CFE or subscription to private coverage. The transition must be coordinated with the actual departure to avoid any discontinuity.
Interactions with administrations
Expatriation means dealing with the French tax authorities, cantonal tax authorities, social security funds and banking institutions. Precise coordination is essential to limit the risk of inconsistent declarations, particularly with regard to residence, social security affiliation or the location of accounts and contracts.
Prevent controls and organize documentation
Tax inspection on departure or return
A change of tax residence is a warning signal for the tax authorities. In the absence of sufficient justification, the tax authorities may contest the departure or return, requalify the income or initiate an adjustment. It is therefore essential to produce a complete file: lease of residence abroad, proof of schooling, certificates of transfer, proof of cessation of activity in France, etc.
Recourse and negotiation
In the event of disagreement over tax residence or the nature of income, amicable procedures can be initiated under the Franco-Swiss tax treaty. At the same time, there are still legal avenues open to contest a tax reassessment. A well-argued strategy, based on supporting documents and applicable legislation, enables you to engage in dialogue with the tax authorities.
Tailor-made tax support for expatriates and impatriates
BERGEOT PAOLI Associés helps individuals prepare for expatriation and manage the associated tax risks. Each situation is the subject of an in-depth analysis: nature of income, tax residence, asset issues, tax obligations. Working with our banking partners, notaries and chartered accountants, we structure flows, anticipate cross-border issues and ensure that tax returns are consistent in both countries. This support is part of a global security strategy, in line with the cross-border taxation of individuals.