France's tax year is calendar-year. India's is April-March. Your PEA needs timing decisions before you become Indian-resident.
TL;DR
Returning to India from France is more than booking a flight and updating an address. The PEA, PEL, French social security record, AGIRC-ARRCO retirement contributions, and the Sécurité Sociale departure formalities all need active management. The 3-month gap between the French calendar year and the Indian financial year is where unprepared returners lose lakhs.
By Vipul Sharma, Founder
Reviewed by Preetesh Maloo, Chartered Accountant, NRI Tax Partner
Exit-year residency split — French side and Indian side
On the French side, the Centre des Impôts splits your departure year into a resident period (1 January to your departure date) and a non-resident period (departure date to 31 December). You file the standard French income tax return (déclaration 2042) for the resident period covering worldwide income; for the non-resident period, only French-source income (rentals, French dividends, French capital gains) is reportable.
On the Indian side, Section 6 day-count determines residency for the full Indian financial year (April-March). There is no split-year mechanism. You are either Indian resident for the FY or not.
The practical mismatch: if you leave France in September 2025, your French residency covers Jan-Sep 2025 and Indian residency covers FY 2025-26 (April 2025-March 2026). The overlap (October 2025 to March 2026) is when France no longer taxes you on worldwide income but India already does. For Indian-French NRIs returning, this 6-month window contains the highest-stakes timing decisions: when to unwind the PEA, when to close the PEL, when to liquidate French brokerage holdings, when to settle remaining French private pension entitlements.
PEA (Plan d'Épargne en Actions) — the unwind decision
The PEA is France's tax-advantaged equity investment account. Hold the PEA for 5 years and capital gains within it are exempt from French income tax (you still pay the 17.2% social charges). The 2019 PACTE law removed the older 8-year threshold — after 5 years you can take partial withdrawals without closing the plan, retain the tax exemption on the gains, and continue making fresh contributions.
For a French resident, the PEA is a powerful tax shelter. For an Indian-French NRI returning to India, the calculus changes.
Once you become a non-resident of France, the PEA's account can continue (some brokers allow non-resident PEA maintenance; others force closure on residency change — check with your provider). However, the tax-exempt status on gains is a French domestic concession that India does not recognise. Once you're an Indian tax resident, capital gains realised within the PEA become taxable in India as global income at the relevant slab rate. The 5-year/8-year French shelter is meaningless on the Indian side.
The optimisation decision: liquidate the PEA before becoming Indian-resident (i.e., during your final French residency period). Realised gains during French residency are French-taxable but exempt under the 5-year rule if eligible. Liquidating in this window keeps the gains 100% sheltered.
Alternative: liquidate during the RNOR window after Indian arrival. While RNOR, foreign-source capital gains are not Indian-taxable. France still has its own non-resident-source capital gains rules (which can apply to non-resident sales depending on the asset type), but for PEA holdings the French source connection is generally weaker than for direct French real estate.
Worst case: hold the PEA into your full Indian-resident-and-ordinarily-resident status. Now every realised gain inside the PEA is Indian-taxable at slab. The French shelter is gone; the structure becomes purely an inconvenience.
PEL (Plan d'Épargne Logement) — interest tax treatment after exit
The PEL is France's housing savings plan. It accrues interest at a rate set by decree (variable in recent years), with the interest tax-free for French residents after 12 years of holding.
For an Indian-French NRI who's leaving France with a PEL still open: the tax-free shelter is again a French-resident-only benefit. Once you're an Indian tax resident, interest credited to the PEL becomes Indian-taxable foreign-source income.
The RNOR window applies here too. PEL interest received during RNOR years is not Indian-taxable. After RNOR, the interest joins your global income and gets taxed at Indian slab rates.
The decision: keep the PEL open until the RNOR window closes if the interest accrual rate is competitive against what you'd earn redeploying the funds into Indian instruments (post-tax). If the PEL rate is below 2.5-3%, the maintenance isn't worth it — close it during the French resident period, take the gains tax-free, and redeploy.
Closure procedure: notify your French bank, transfer balance to your nominated French account, file the closure documentation. French banks generally accept written closure requests from non-residents but may require notarised documentation if you've already left France.
CSG/CRDS and the Sécurité Sociale departure
While in France, you paid CSG/CRDS (Contribution Sociale Généralisée + Contribution au Remboursement de la Dette Sociale) on your French salary and other income at rates totalling 9.7%. The contributions fund French social security and the broader social safety net.
On departure, you formally notify Sécurité Sociale via the URSSAF (the collection authority). The notification stops your contributions and triggers the end of your affiliation. You retain accrued rights (notably the AGIRC-ARRCO complementary retirement, see next section) but new contributions stop.
For Indians moving to India (not to another EU country), there is no EU social security coordination. Your French contributions don't transfer to the Indian social security system (Indian residents are covered by EPFO + ESIC, but these are domestic schemes not aligned with French systems). The accrued French rights — particularly retirement — sit dormant until claim age.
Meticulous departure documentation matters: the URSSAF notification, the Sécurité Sociale departure form, a final attestation of contributions paid. Keep these for 30+ years — they're the proof you'll need at retirement age to claim French pension entitlements as a non-French resident.
Get URSSAF + AGIRC-ARRCO documentation organised pre-departure
The PEA + RNOR alignment is the single most valuable lever in a France → India return.
Free 15-minute call. We sequence the PEA unwind, the AGIRC-ARRCO documentation, and the Indian RNOR start date together.
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AGIRC-ARRCO complementary retirement — the long-term portability question
AGIRC-ARRCO is the French complementary retirement system covering most salaried employees. Contributions are mandatory and accrue 'points' that convert to a pension at retirement age. AGIRC-ARRCO's eligibility in practice tracks the statutory régime général retirement age — and that statutory age has been in flux. France's 2023 pension reform had pushed the régime général minimum age up from 62 toward 64. The National Assembly voted on 12 November 2025 to suspend that reform — freezing the régime général legal minimum at the pre-reform schedule (62 years 9 months for the cohorts most affected) at least until after the 2027 presidential election. AGIRC-ARRCO itself is governed by separate social-partner agreements but generally aligns with the régime général age in practice — you typically claim both together at full rate. Full-rate age remains 67 for those without the required quarters of contributions. The medium-term position is genuinely uncertain — confirm your current minimum-age slot with AGIRC-ARRCO directly before you plan around it.
For an Indian-French NRI who's contributed for 5-15 years in France, the accrued AGIRC-ARRCO points carry forward indefinitely. At retirement age, you can claim the pension from your country of residence — including India.
The Indian-side tax treatment of AGIRC-ARRCO pension payments: AGIRC-ARRCO is a private-sector complementary pension. Under the non-government-pensions article of the India-France DTAA (Article 20), pensions paid in respect of past private-sector employment are taxable only in the recipient's state of residence. For an Indian-French NRI who's an Indian tax resident at the point of pension payout, AGIRC-ARRCO is taxable in India, not France. France should withhold only the de minimis amount allowed for non-residents under its domestic rules (and any excess is recoverable through the French non-resident refund procedure with documentary proof of Indian residency).
This is the opposite of what many returning Indian-French NRIs assume. They expect France to tax the pension and India to give credit. The treaty actually gives India primary taxing rights and France's withholding is a default that needs to be recovered, not a final tax.
The administrative requirement: notify AGIRC-ARRCO of your departure and new contact details. Keep your French bank account open for pension deposits (much smoother than forex conversion to an Indian account). Maintain valid French ID documents and keep your numéro fiscal current — some can lapse without warning if not actively maintained.
For French nationals married to Indian nationals or with French-born children, additional considerations apply around survivor benefits and beneficiary designations under the AGIRC-ARRCO rules. These are typically administered through the same caisse de retraite as your primary pension.
100-day exit checklist for France → India
Day -100 (T-100): Set departure date. Notify employer. Engage French CA for the migration return + a Sécurité Sociale advisor if your record is complex.
Day -90: Inventory PEA, PEL, French brokerage holdings, French savings accounts. Decide liquidation timing for each based on tax-shelter status and Indian residency projection.
Day -60: Liquidate PEA if applicable (capture the 5-year tax-free status if eligible). Close PEL if rate doesn't justify post-RNOR Indian-tax exposure.
Day -45: Notify Sécurité Sociale via URSSAF. Get AGIRC-ARRCO accrued statement. Update beneficiary designations.
Day -30: Notify bank, broker, mortgage holder, insurance. Update contact details on all French accounts. Set up forwarding for tax correspondence.
Day 0 (departure): Final déregistration with the mairie (local town hall) if applicable. Confirm last day of physical residence in France for the migration return.
Day +30 (arrival India): Establish Indian banking. Notify Indian bank of return. Begin NRE/NRO restructuring under FEMA. Confirm RNOR status assessment with Indian CA.
Day +90: First Indian quarterly self-assessment if applicable. Monitor French tax correspondence forwarded to India.
Day +180: File the French migration return for the departure year. Coordinate with Indian CA for the cross-credit accounting.
Day +365: File first Indian ITR-2 as resident. Schedule FA disclosure for all foreign assets held. Form 67 for any French tax paid on income reported in the Indian return.
The France → India return is logistically heavier than the Netherlands or US equivalents because the French tax system has more shelter structures (PEA, PEL, LMNP, micro-BIC) and a stricter departure formalism. The 100 days of planning are easily worth ₹5-10 lakh in optimised tax outcomes over the first 3 Indian years.
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