Moving Abroad from France: How Your Financial Assets Are Taxed in Switzerland, Belgium and Italy
You can move your furniture, but rarely your tax system. Yet when leaving France for Geneva, Brussels or Milan, it is often the structure of a financial portfolio that brings the worst surprises: a securities account perfectly optimised in Paris, a French life insurance policy opened twenty years ago or a personal holding company can suddenly become tax-inefficient in the new country of residence.
The first instinct is to compare rates. The same stock market gain is currently taxed at 31.4% in France, 26% in Italy, 10% in Belgium and 0% in Switzerland. Stopping there would be a mistake: each country takes back with one hand what it gives with the other, through the taxation of dividends, wealth, insurance premiums or transfers on death.
Here is a wrapper-by-wrapper review of the taxation of financial assets when moving abroad from France in 2026, and of the decisions to make before you leave.
Capital gains on shares: four countries, four rates
For a private investor, the tax on a gain from the sale of listed securities looks as follows in 2026:
France, 31.4%: 12.8% flat tax plus social contributions, whose increase on investment income brings the overall rate to 31.4% from 2026 (the option for progressive income tax rates remains available);
Italy, 26%: flat substitute tax of 26%, reduced to 12.5% for the portion relating to government bonds;
Belgium, 10%: new tax on financial capital gains in force since 1 January 2026, above an annual allowance of €10,000;
Switzerland, 0%: exemption of capital gains realised on private wealth.
This ranking only makes sense once the other levies on the same portfolio are taken into account: tax on dividends, wealth tax, taxes on securities accounts and on stock exchange transactions. These are reviewed below.
Securities accounts: king in Switzerland, under pressure in Belgium
Switzerland: exempt capital gains, taxed dividends and wealth
In Switzerland, capital gains realised on private movable assets are exempt from income tax (Article 16(3) of the Federal Direct Tax Act). The advantage is real, but it comes at a price: dividends are taxed at progressive rates, with combined federal, cantonal and municipal marginal rates that can approach 43% depending on the place of residence, and securities are included every year in the base of the cantonal wealth tax, assessed on their value at 31 December.
Two practical consequences follow. First, growth stocks and accumulating funds should be preferred, since their performance takes the form of exempt capital gains rather than taxable dividends. Second, overly active management exposes the investor to requalification as a “professional securities dealer”: gains then become taxable as self-employment income and are also subject to social security contributions. The frequency of transactions, holding periods and the use of leverage are the criteria examined by the Swiss tax authorities.
Example: a Geneva resident holding a €2 million portfolio focused on high-yield stocks will pay, every year, income tax on dividends at progressive rates and wealth tax on the value of the securities. Rebalanced towards growth stocks, the same portfolio will mostly generate tax-exempt capital gains.
Belgium: the end of the capital gains exemption
Belgium has put an end to a long-standing exemption. Since 1 January 2026, capital gains realised by individuals on financial assets are taxed at 10%, above an annual allowance of €10,000. A favourable transitional rule applies: only the increase in value after 31 December 2025 is taxable, as the acquisition cost may be set at the market value on that date.
Other levies come on top:
an annual tax of 0.15% on securities accounts with an average value above €1 million;
the tax on stock exchange transactions, payable on every purchase or sale of securities;
no carry-forward of capital losses to later years, which penalises volatile portfolios;
a 30% withholding tax on dividends, with no credit for tax already withheld at source abroad.
Italy: a 26% flat tax and no general wealth tax
Italy applies a 26% flat rate to both capital gains and dividends and has no general wealth tax. Two points nonetheless require attention. Financial assets held abroad by an Italian resident are subject to IVAFE, an annual levy of 0.2% of their value, while securities held in Italy bear a stamp duty at the same rate. In addition, as in Belgium, foreign-source dividends are taxed with no credit for the tax withheld in the source country: the reduced treaty rate should therefore always be claimed there.
For newcomers with significant wealth, the Italian “new residents” regime (Article 24-bis of the TUIR), which replaces the taxation of foreign-source income with an annual lump-sum tax, is also worth considering.
Life insurance: a very French reflex
In France, life insurance (assurance-vie) remains the central wealth planning tool: reduced taxation of withdrawals after eight years, an annual allowance on gains and, above all, transfer outside the estate, with each beneficiary entitled to a €152,500 allowance on amounts derived from premiums paid before age 70 (Article 990 I of the French Tax Code).
Outside France, the appeal quickly fades:
in Belgium, a 2% tax applies to every premium paid, and the gain realised on surrender in principle falls within the new 10% capital gains tax;
in Switzerland, the surrender value of the policy is included in taxable wealth, and the return on single-premium policies is exempt only under strict conditions of duration and age;
in Italy, the capital paid on death is exempt from inheritance tax, but the investment return is taxed at 26%, including where the policy ends on the death of the insured.
Above all, a French life insurance policy is not always recognised as such by the tax authorities of the new country. Depending on its structure (euro funds, unit-linked funds, protection cover), it may be treated as a mere financial investment and lose most of its benefits. Its portability must therefore be checked before leaving, so that the necessary decisions can be made: partial surrender in France, keeping the policy, or taking out a policy compliant with the rules of the destination country, in particular with a Luxembourg insurer.
Holding companies: for shareholdings, not for a securities portfolio
In each of the four countries, holding companies benefit from a near-exemption of dividends and capital gains on significant shareholdings:
France: parent-subsidiary regime from a 5% stake (Articles 145 and 216 of the French Tax Code) and exemption of gains on qualifying shareholdings held for at least two years, subject to a taxable share of costs and expenses;
Belgium and Switzerland: 10% threshold, or a minimum value of the shareholding, for the participation exemption or participation reduction;
Italy: participation exemption regime, which requires in particular an uninterrupted holding period of twelve months.
For a business owner who sells his or her company and reinvests the proceeds in new shareholdings, a holding company therefore remains fully relevant.
The position is different for a diversified listed portfolio. Using a company then adds a layer of corporate income tax, at 25% in France and Belgium, 24% in Italy and about 14% in Geneva, followed by a second layer of tax when profits are distributed. In France, the tax on non-business assets of personal holding companies (Article 235 ter C of the French Tax Code) reinforces this conclusion. On substance and residence issues for interposed companies, see our analysis of foreign holding companies and beneficial ownership.
In Switzerland, a holding company owning a securities portfolio simply makes no sense: held directly, listed shares produce tax-exempt capital gains for an individual. Placing them in a company would turn an exempt gain into taxable profit.
Passing on wealth: the gift-before-sale trap
In France, the “give before you sell” strategy is well known: the gift wipes out the latent capital gain, as the recipient takes the securities at their value on the date of the gift, which becomes the new acquisition cost. This mechanism, which requires a genuine gift made before the sale with no recovery of the proceeds by the donor, does not work everywhere:
in Belgium, neither a gift nor an inheritance wipes out the gain: the recipient or heir takes over the donor’s acquisition value;
in Italy, only an inheritance wipes out the latent gain, a gift passing it on to the recipient;
in Switzerland, the issue does not arise for privately held securities, whose gains are exempt.
The benefit of planning ahead therefore shifts to gift and inheritance tax itself, where the differences are considerable: 3% on a gift of movable assets in the direct line in Belgium versus 27% to 30% in the upper inheritance tax brackets, 4% in Italy above an allowance of €1 million per child, and 0% in the direct line in most Swiss cantons.
Shares in French companies: a lasting French tax connection
The last trap concerns shares in French companies. Under Article 750 ter of the French Tax Code, assets located in France, which include shares in companies with their registered office in France, remain subject to French gift and inheritance tax even where the donor or deceased lives abroad. For a Swiss resident, no treaty mitigates this rule: the France-Switzerland inheritance tax treaty ceased to apply on 1 January 2015 and no treaty has ever covered gifts. For an Italian resident, the analysis must take into account the France-Italy treaty of 20 December 1990 on inheritance and gift taxes.
The usual solution is to hold exposure to French markets through a foreign-law fund, whose units are not assets located in France. Bear in mind too that where the recipient has been resident in France for at least six of the last ten years, all assets received become taxable in France. On the civil law governing such transfers, see also our article International Succession: Which Law Applies?.
Before leaving France: three reflexes and one must, the exit tax
Review your portfolio line by line, identifying for each security the tax treatment in the new country (dividends, capital gains, wealth) and the changes to make before the transfer of residence.
Have your life insurance policies audited, to check that they are recognised in the destination country and decide whether to keep, surrender or transfer them to a suitable solution.
Only make gifts after checking whether the donor or the recipient will bear the latent tax, and in which country gift or inheritance tax will be due.
Finally, leaving France may itself be taxed. The French exit tax under Article 167 bis of the French Tax Code applies to taxpayers who have been tax resident in France for at least six of the ten years preceding their departure, where the total value of their shares and securities exceeds €800,000 or where they hold at least 50% of a company’s profits. Latent capital gains are then assessed on the date of the transfer of residence. Deferral of payment is automatic when moving to Belgium or Italy; for Switzerland, it must be expressly requested and generally requires guarantees.
For a broader overview of holding structures, see our article on holding financial assets in the context of international mobility, our guide to moving to Switzerland and, for real estate kept in France, our analysis of the French real estate wealth tax (IFI) for non-residents.
Moving abroad is not just a change of address: it is a change of tax system, which requires each holding structure to be rethought. Planned several months before departure, this reorganisation turns a constraint into an opportunity. Our international tax law firm in Marseille and Geneva advises individuals and business owners on auditing their financial assets, preparing their move abroad and securing the transfer of their wealth, particularly in France-Switzerland situations.
FAQ: taxation of financial assets when moving abroad
Which country taxes capital gains on shares the least for someone leaving France?
On capital gains alone, Switzerland, which exempts gains realised on private wealth. However, dividends are taxed at progressive rates and securities are subject to the annual cantonal wealth tax. Belgium taxes capital gains at 10% above an annual allowance of €10,000, Italy at 26% and France at 31.4% in 2026. The comparison must therefore cover the overall taxation of the portfolio, not a single rate.
Does Belgium now tax capital gains on securities held by individuals?
Yes. Since 1 January 2026, capital gains on financial assets are taxed at 10%, above an annual allowance of €10,000. Only the increase in value after 31 December 2025 is taxable, as the acquisition cost may be stepped up to the market value on that date. Losses cannot be carried forward to later years.
Is my French life insurance policy (assurance-vie) still tax-efficient after moving abroad?
Not necessarily. Belgium levies 2% on every premium, Switzerland includes the surrender value in taxable wealth and Italy taxes the investment return at 26%, including on death. A French policy may also not be recognised as life insurance by the tax authorities of the new country of residence. Its portability should be reviewed before leaving.
Should I set up a holding company to hold a listed portfolio in Switzerland?
As a rule, no. Held directly, listed shares generate tax-exempt capital gains for a private individual. Holding them through a company would turn an exempt gain into profit subject to corporate income tax, then to dividend tax on distribution. A holding company remains relevant for significant shareholdings, especially after the sale of a business.
Does a gift before a sale wipe out the capital gain outside France?
Not always. In France, a gift wipes out the latent gain. In Belgium, neither a gift nor an inheritance does: the recipient takes over the donor’s acquisition value. In Italy, only an inheritance wipes out the gain. Before any gift, it must be established whether the donor or the recipient will bear the latent tax.
Does a Swiss resident who gives away shares in French companies pay French gift tax?
In principle, yes. Article 750 ter of the French Tax Code subjects assets located in France, including shares in French companies, to French gift and inheritance tax even where the donor lives abroad. No France-Switzerland treaty covers gifts, and the inheritance tax treaty ceased to apply on 1 January 2015. Holding French exposure through a foreign fund often neutralises this connecting factor.
Does the French exit tax apply when moving to Switzerland, Belgium or Italy?
Yes, where the taxpayer has been tax resident in France for at least six of the last ten years and holds shares and securities worth more than €800,000 or at least 50% of a company’s profits (Article 167 bis of the French Tax Code). Deferral of payment is automatic when moving to Belgium or Italy; for Switzerland, it must be requested and generally requires guarantees.
Eve d’Onorio di Méo
Avocat, Tax Law Specialist (Avocat Spécialiste en Droit Fiscal)
Marseille and Geneva Bars (EU/EFTA Lawyer)
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