For French Founders
Moving Your Company From France to Montenegro
France's top marginal rate reaches 55.4% once the CEHR surtax is layered on. Before the delta gets exciting, know what the impôt de sortie does to significant shareholdings on the way out — it's the number that actually decides whether the timing works.
Read this before the rate comparison excites you
If you've been a French tax resident for 6 of the last 10 years and hold securities worth €800,000 or more (or 50%+ of a company's profits), the impôt de sortie taxes the unrealized gain on those holdings as if you'd sold them the day you leave, at the 31.4% flat rate (12.8% income tax plus 18.6% social levies as of 2026). Automatic deferral without posting security only applies for moves within the EU/EEA — Montenegro is neither, so expect the French tax administration to require a financial guarantee, or full payment within 90 days of departure. Hold the position for 2 years (portfolios under roughly €2.57M) or 5 years (above), and the deferred liability is waived for good — but that horizon has to be modeled against your actual plans before the rest of the pitch matters.
What Actually Changes
Where the savings come from
Progressive 9–15% corporate tax
Profit up to €100,000 is taxed at 9%; above that it's €9,000 plus 12% up to €1.5M, then 15% beyond — a fraction of what the same profit faces as French personal income once drawn out.
A salary structure that keeps the gain
A properly built executive salary paired with the corporate rate keeps take-home income from quietly reverting to French-style levels once you start drawing from the business.
EU accession, pre-EU prices
Montenegro is further along the accession track than most candidate countries, with living costs well under Paris or Lyon.
Coastal climate, Mediterranean feel
Year-round Adriatic sun and a coastline that echoes the French Riviera, without the French Riviera's price tag.
Where This Won't Suit You
The impôt de sortie, and other real friction
Exit tax on shares, likely with a guarantee
Moving outside the EU/EEA means no automatic interest-free deferral. The French tax administration will typically require a financial guarantee, which changes the near-term cash picture for founders with an appreciated company.
Residency has to be real
Keeping a French home, family ties (foyer fiscal), or day-to-day management in France can keep you fully tax liable regardless of where your company is registered.
Banks are cautious, and slow
Montenegrin banks are risk-averse by regional standards. Opening a corporate account takes longer than it did at a French bank.
Not Schengen access
A Montenegrin residence permit gives you the right to live and work in Montenegro. It doesn't replace the free movement a French passport already gives you across the EU.
Want the exit tax and savings modeled together?
The corporate tax comparison only tells half the story until the impôt de sortie number is on the table. Run the calculator, then talk to us about the full picture for your specific shareholding.
Not moving from France?