Transfers from France
French exit tax, IFI on real estate, historical ISF: the Suisse romande and Ticino file.
French exit tax
CGI 167 bis taxes latent gains on shareholdings above €800,000 or 1% of the capital of French companies. For transfers to Switzerland, deferral of payment is available, subject to security and annual reporting.
IFI on real estate
The IFI hits French property even of non-residents. The residence transfer does not eliminate it on French assets, but can zero it out on Swiss assets.
Bilateral treaty
The 1966 Franco-Swiss treaty (with subsequent protocols) governs fiscal priority. On the forfait, dialogue with the French administration requires an accurate file on residence effectiveness.
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