Article 167 bis of the French General Tax Code
I. – 1. Taxpayers who have been domiciled in France for tax purposes for at least six of the ten years preceding the transfer of their tax residence outside France are taxable on the transfer in respect of unrealised capital gains on the corporate rights, securities or rights referred to in 1 of I of Article 150-0 A held, directly or indirectly, by the members of their tax household on…