A French pension for past private-sector employment is taxable only in Portugal when paid to a Portuguese resident (France-Portugal convention, art. 19). That includes the CNAV basic pension, while a French government-service pension stays taxable only in France unless the recipient is resident in, and a national of, Portugal, in which case only Portugal may tax it (art. 20(2)). IFICI does not exempt pensions, which fall outside categories A, B, E, F and G listed in CIRS art. 81(4).
This page helps you coordinate French departure rules, Portuguese residence, and the France-Portugal treaty before either side files from the wrong assumptions.
Most French cases turn on three things: whether the French exit tax applies on the way out, how the treaty splits pensions and French-source income, and the fact that the old NHR regime is gone.
Why French Movers To Portugal Face A Specific Corridor
Leaving France can trigger an exit-tax review if your shareholdings meet the statutory conditions. If you hold significant company shares or a securities portfolio, the exit tax can crystallise on the day you move.
Once you are resident in Portugal, the France-Portugal treaty decides which country taxes each income stream, and the answer is different for a public-sector pension than for a private one.
On the Portuguese side, the regime that retirees used to rely on (NHR, with its reduced pension rate) is closed to new arrivals and its replacement, IFICI, does not cover pensions at all.
The result is a situation where exit tax, pension classification, and Portuguese residence all interact. Getting the sequence and the classifications right before you file protects you from paying twice or filing the wrong position in either country.
How The France-Portugal Treaty Allocates Your Income
France and Portugal tax under a double tax convention (the 1971 convention as later amended), so each income type is allocated to one country, with the other giving relief. As a broad map:
| Income type | Where it is taxed |
|---|---|
| French public-service pension | Generally France, subject to the treaty exception where the recipient meets the residence and nationality conditions. |
| French private or occupational pension | Portugal (residence). Taxed at normal Portuguese rates once you are resident; IFICI does not exempt pensions. |
| Employment | Where the work is performed. Residence (Portugal) unless the work is physically done in France. |
| Dividends and interest | France may withhold, Portugal taxes with a credit. Reclaim any over-withholding with the French residence forms. |
| Capital gains on ordinary securities | Generally Portugal as the residence state, subject to treaty exceptions for real-property-rich interests, permanent-establishment assets, and other specified cases. |
| French real estate (rent and gains) | France (where the property is). Portugal taxes too and gives a credit for the French tax. |
Portugal, as your country of residence, generally taxes worldwide income and credits the French tax already paid, so the aim of planning is to avoid both double withholding and missed credits. Confirm the exact treaty articles and any capped withholding rates for your income before filing.
The French Exit Tax When You Leave For Portugal
France's exit tax (Article 167 bis of the CGI) can apply when you move your tax home abroad if you were French tax resident for at least six of the previous ten years and your securities and company rights are worth more than EUR 800,000 in total, or represent at least half of a company's profits. It treats your unrealised gains as if you had sold on the day before departure.
For a move to Portugal, payment can be automatically deferred without a guarantee. Cancellation periods and conditions vary by value and category, so there is no single unconditional holding period. So for most people the exit tax is a filing and monitoring obligation, not an immediate payment.
The risks are failing to file the departure-year and annual follow-up forms, or selling during the deferral window, which crystallises the tax. The exact rate, thresholds, and holding period should be confirmed for your departure year, and a securities sale in France during deferral may attract a Portuguese tax credit.
Pensions: The Public-Versus-Private Split, And Why IFICI Does Not Help Retirees
For French pensioners this is the decisive question. A French government-service pension is generally taxable only in France under Article 20(2), but only in Portugal if the recipient is both Portuguese treaty resident and Portuguese national. Pensions connected with a government business follow the separate rule in Article 20(3).
One key distinction: only true public-function pensions get this treatment. The ordinary French state old-age pension (the régime général / CNAV retraite de base) is not a civil-service pension for treaty purposes and is taxed in Portugal, like a private pension.
A French private-sector or occupational pension is taxable in Portugal as your country of residence, and the position has changed: under IFICI (the regime that replaced NHR for new arrivals from 2024), foreign pensions are not exempt. They are taxed at Portugal's normal progressive rates.
So the old expectation, a low flat rate on a French pension under NHR, no longer holds for new movers. A French private pension is now taxed in Portugal at standard rates, and most retirees do not qualify for IFICI in any case. A review classifies your pension and checks that the public pension is reported on your Portuguese return.
French Social Charges And The EU Exemption
Beyond income tax, French social charges on French-source investment income, rents, and property gains depend on the income category and the taxpayer's social-security affiliation. If you live in Portugal and are covered by the Portuguese social-security system, EU rules generally exempt you from CSG and CRDS, leaving only a smaller solidarity levy.
The exemption is not automatic; you must claim it with evidence of your Portuguese affiliation. The precise scope (which income types and which levy survives) should be confirmed for your situation.
Coordinating DGFiP And Finanças
Keeping a French rental property or French investments usually means you continue to file in France as a non-resident at the same time as filing in Portugal, with the treaty deciding who taxes what and Portugal granting a credit for French tax. Two returns, one treaty position.
The work is making the French and Portuguese filings use the same facts and the same numbers, so the credit lines up and nothing is taxed twice or missed.
Frequently Asked Questions
Does France still tax me after I move to Portugal?
Generally only on French-source income once your tax home has shifted to Portugal and the treaty tie-breaker treats you as resident there. France can still tax French public-service pensions, French real estate income and gains, and French-source dividends within treaty limits, while Portugal taxes your worldwide income as the country of residence and credits the French tax.
What is the French exit tax, and will it apply to me?
French exit tax can apply if you were resident for at least six of the preceding ten years and the relevant holdings represent at least 50% of a company’s profits or exceed EUR 800,000 in total value. A move to Portugal qualifies for automatic payment deferral, which is not cancellation.
For covered unrealised gains under the current rule, relief can follow after two years of continued ownership, or five years where the relevant total value exceeds EUR 2.57 million. Earlier disposals and other events can change the result; previously deferred realised gains follow separate conditions. Keep the departure valuation and required forms with your French adviser.
How is my French pension taxed once I live in Portugal?
A French government-service pension is generally taxable only in France. Under the treaty exception it is taxable only in Portugal if the recipient is resident in Portugal and has Portuguese nationality. Pensions paid for services connected with a government business follow the separate ordinary provisions. A private or occupational pension generally follows the residence-country pension rule. Classify the scheme before filing.
Does IFICI cover my French pension?
No. IFICI, the regime that replaced NHR for new arrivals, does not exempt pensions. A French private or occupational pension that Portugal taxes is taxed at normal Portuguese rates. A true French civil-service pension is different and generally stays taxable in France, so the pension type must be classified before filing.
I have a French rental property. Where is it taxed?
French real estate income and gains are taxable in France because that is where the property sits. Portugal also taxes the same income as your country of residence and gives a credit for the French tax, so you usually keep filing in both countries. The aim is to align the two filings so the credit works and nothing is double-counted.
Related guides
- Guide · How Portugal taxes foreign pensions in 2026Check how Portugal taxes UK, US and other foreign pensions: treaty treatment, existing NHR rights, pension deductions and lump-sum risks.
- Guide · Foreign income in Portugal: Anexo J step by stepA Portuguese tax resident is taxed on worldwide income, including income obtained abroad (CIRS art. 15(1)).
- Guide · Moving to Portugal: tax checklist for 2026Plan the tax steps before and after a move to Portugal: home-country departure, tax residence, NIF, income records, IFICI and your first return.
For people living in Portugal with ties to France: we answer your questions, prepare your Portuguese return with your income from France and work with your adviser there.
Tax Consultation
A 30-minute call with your adviser, then a follow-up memo within 3 working days after the call.
Bring one question, such as your tax residence this year, whether IFICI applies to you, or the tax on a pension or a sale.