2nd Subsection: Overall income

1. A taxpayer domiciled in France who transfers his residence abroad is liable to income tax on the income he has disposed of during the year of his departure up to the date of his departure, on the industrial and commercial profits he has made since the end of the last taxed financial year, and on any income he has acquired without having disposed of it prior to his departure….

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…