Relocating from
France to Cyprus

Yes. France's impôt de sortie applies to unrealised gains on shareholdings exceeding €800,000, or where the shareholding represents more than 50% of a French company. As Cyprus is an EU member state, you can apply for automatic deferral (sursis de paiement) during EU residence. The tax is only triggered when you dispose of the shares or leave the EU.

Yes, but they must be commercially justified. Management fees paid to a Cyprus company must reflect genuine services provided, be priced at arm's length, and be documented with contracts and evidence of services rendered. Substance in Cyprus — directors, office, actual decision-making — is essential to rebut any DGFiP challenge.

Yes. The Cyprus-France DTT is in force and provides for reduced withholding tax on dividends (10% or 15%), interest (10%), and 0% on royalties in certain cases. It also provides a tiebreaker for dual residence and covers exit scenarios.

This depends on the value of the PEA, whether it has already passed the 5-year threshold, and your French exit tax position. In many cases, liquidating the PEA while still a French resident (benefiting from the PEA CGT exemption) before the exit tax kicks in is more efficient than retaining it. However, individual modelling is essential.