French presidential election 2027: packing season is open

Manifestos vie with one another to dream up new taxes on the very wealthy, TV studios get heated, and removal firms rub their hands. Nothing new under the sun, except the timing: with the presidential election in sight, the first promises are already flying.

While Paris debates, other capitals are out actively prospecting. Three approaches are taking shape, and they look nothing alike.

Switzerland: taxed on your lifestyle

For decades, Switzerland has offered taxation based on expenditure, better known as the lump-sum tax. Tax is calculated not on your actual income but on your annual spending, estimated chiefly from your rent or the rental value of your home. Elegant, discreet, very Swiss.

The scheme does come with conditions, though. It is reserved for foreign nationals who settle in Switzerland without pursuing any gainful activity there, and the federal tax base has a floor set at more than CHF 400,000.

Above all, it is no longer available everywhere: Zurich, Basel-Stadt, Basel-Landschaft, Schaffhausen and Appenzell Ausserrhoden have abolished it. The lump sum has become a cantonal product rather than a national one.

Italy: entry-ticket inflation

Italy sniffed out the opportunity in 2017 with its new residents regime: an annual flat tax on all foreign-source income, however large, for up to fifteen years. Price of admission: €100,000.

Then the price followed a trajectory any shareholder would envy: €200,000 for arrivals from August 2024, €300,000 since 1 January 2026. The ticket has tripled in under ten years and, curiously, Milan has not emptied.

The real lesson lies elsewhere. A regime that changes with every budget looks less like a regime than a special offer. Those who got in at €100,000 keep their terms in principle; those still hesitating now know that the rules of the game can shift from one year to the next.

Luxembourg: no lump sum, no red carpet

The Grand Duchy offers no special regime designed to attract the very wealthy. No lump sum, no entry ticket, no introductory offer. It simply refrains from doing certain things, and that is precisely what makes it attractive.

No wealth tax for individuals, abolished in 2006. No inheritance tax in the direct line, within the limit of the heirs’ statutory share. And a complete wealth-planning toolkit: the SOPARFI to hold shareholdings, the SPF to manage private financial assets, the SCSp to structure investments with wide contractual freedom.

Add political stability that would turn any finance minister green with envy, a AAA rating that has never slipped, and a border less than an hour from Metz, A31 tailbacks not included. In short, Luxembourg does you no favours: it simply leaves you in peace.

The beauty contest: advantage Switzerland and Italy, for now

Admittedly, between the Swiss lakes, the Tuscan hills and the Alzette valley, the contest is over before it starts. When it comes to sunshine and la dolce vita, the Grand Duchy starts with a slight handicap.

But with global warming, who knows? In twenty years, we may be sipping a spritz on the banks of the Moselle, laughing at Genevans wilting in the heat. Might as well get a head start.

Before you pack: what the border doesn’t settle

Let’s be honest: Luxembourg is not a tax haven; it is a serious country (perhaps too serious). Income tax rates go up to 42%, or around 45.8% once the employment fund surcharge is added. And leaving France never comes free: three points call for forward planning.

Exit tax. A taxpayer domiciled in France for at least six of the last ten years is taxed on unrealised capital gains if their shareholdings exceed €800,000 or represent at least 50% of a company. For a move to Luxembourg, deferral of payment is automatic. The tax nevertheless falls due if the shares are sold within two years, or within five years above €2.57m.

IFI. Becoming a Luxembourg resident does not make France’s real estate wealth tax (IFI) disappear. Property located in France remains taxable, including when it is held through a company.

Inheritance. The absence of direct-line inheritance tax in Luxembourg offers no protection from French duties. If your heirs have been domiciled in France for at least six of the last ten years, France taxes what they receive, wherever the assets are located. And there is no Franco-Luxembourg treaty on inheritance tax.

Finally, tax residence has to be proven: household, principal place of stay, centre of economic interests. A lease in Kirchberg and a letterbox will not do.

Run, or get organised

Between running and getting organised, there is one difference: anticipation. A departure prepared well in advance has nothing in common with a move decided the morning after a budget vote.

Structuring your assets, the timing of the exit tax, what happens to your French property and your children’s situation should all be settled before you cross the border, not after.

And that is what we do. Consider it done.