France is one of the better-positioned countries in this cluster: it has a real, working tax treaty with Georgia, unlike several countries covered elsewhere in our full country-by-country guide. What decides whether Georgia's 1% is actually legal and durable for a French national is a shorter, sharper list: whether you have genuinely broken French tax residency under article 4 B, whether the exit tax under article 167 bis applies to what you hold, and whether article 155 A re-attributes your Georgian income back to you personally because you never really left. Get those three right and this works cleanly. Get them wrong and you have added a Georgian filing on top of a French one that never actually stopped.
What a French freelancer actually pays: home versus Georgia
Take a freelance consultant earning EUR 80,000 a year under the standard French regime for a non-regulated liberal profession, the real-earnings regime rather than micro-entrepreneur. Assume modest costs bring net profit to EUR 72,000. Cotisations sociales for this profile run, depending on income band and regime, roughly 30 to 45% of net profit; taking 35% as an illustrative midpoint gives about EUR 25,200, leaving EUR 46,800 taxable. Applying the 2026 income tax bands produces roughly EUR 7,150 of income tax, for a combined bill close to EUR 32,350.
| France (illustrative) | Georgia (Small Business Status) | |
|---|---|---|
| Turnover / net profit | EUR 72,000 net profit | EUR 80,000 turnover |
| Social contributions | roughly EUR 25,200 | none equivalent |
| Income tax | roughly EUR 7,150 | 1% of turnover |
| Total | roughly EUR 32,350 | EUR 800 |
This is an illustration built on published 2026 rates and a stated cost assumption, not a filing-ready number; the exact figure depends on your income band, regime, and what URSSAF's own simulator returns. What it shows honestly is where the saving actually comes from: not mainly income tax, which France caps well below its 45% top rate for most freelancers, but cotisations sociales, several times higher than anything Georgia charges.
Does the 1% actually apply to your income in the first place
Georgia's 1% only applies to Georgian-source income, and for services that generally means work physically performed in Georgia. We cover this fully in Georgia's 1% tax and 1% tax without living in Georgia. A French national who registers a Georgian IE and keeps working from an apartment in Lyon has a source-of-income problem before French tax law even enters the picture, because the work was not performed in Georgia at all.
What France does when you leave
Article 4 B of the Code général des impôts sets French tax domicile by three alternative tests, confirmed on Légifrance: a home or principal residence in France, a principal professional activity carried on there, or the centre of one's economic interests being there. Any single one is enough to keep you resident, so this is not a day-count test. The centre-of-economic-interests limb is the one that catches people who think they have left: it compares income and assets in France against those abroad, and French clients, a French bank account holding most of your wealth, or French-sourced income running alongside the new Georgian ones can keep it pointed at France.
Leaving is a filed act, not something that happens on boarding a flight. You file a departure-year return covering income to the date you left, notify the tax authorities of your new non-resident status, and deal with the Service des Impôts des Particuliers Non-Résidents afterward for anything still French-source. An unfiled departure leaves you looking, on paper, like someone who never left, which is exactly the position article 155 A exploits.
Article 155 A CGI, confirmed on Légifrance, lets France tax sums received by a person or entity established outside France as remuneration for services actually rendered by a person established in France. Keep living and working from France while invoicing personally-performed work through a Georgian IE or LLC, and France can re-attribute that income straight back to you at ordinary French rates and social contributions, with the Georgian 1% offsetting almost none of it. French case law has repeatedly held that interposing a foreign entity does not defeat this test where the individual physically performing the work stays in France. If you genuinely relocate and the work is genuinely performed there, article 155 A has nothing to attach to.
Article 167 bis treats certain unrealised gains as sold the moment French tax residency ends, confirmed on BOFiP, if you were resident for at least six of the ten years before departure and hold securities exceeding EUR 800,000 or 50% or more of a company's profit rights. Most freelancers running a Georgian IE never trigger this, since an IE holds no shares at all; it becomes relevant only if you also hold a French or foreign company above the threshold when you leave, most commonly an existing SASU or SARL, and deferral for a move outside the EU/EEA needs an active request, a bank guarantee and a French tax representative.
Article 209 B CGI, France's CFC rule, applies only where a French legal person subject to corporate tax holds more than 50% of a foreign entity in a privileged tax regime, confirmed on Légifrance. It does not reach an individual, so a Georgian IE or LLC held personally sits outside it either way, a different answer from most of this cluster, where CFC exposure turns on IE versus LLC. It only matters if you interpose a French holding company between yourself and the Georgian entity.
France's own blacklist of non-cooperative states (ETNC) under article 238-0 A CGI, set by the arrêté of 15 April 2026, names eleven jurisdictions, Anguilla, Antigua and Barbuda, the Turks and Caicos Islands, Vanuatu, Guam, the US Virgin Islands, Palau, Panama, Russia, American Samoa and Vietnam. Georgia is not one of them. The France-Georgia treaty, in force since 1 June 2010 and confirmed on BOFiP, gives a genuine tie-breaker if both countries assert residency in the same year, but it does not itself decide whether you have broken French residency or whether article 155 A applies.
You lose access to French state health cover (PUMA) once no longer resident, so cover elsewhere needs arranging separately. If you keep French-source income afterward, rental property or French clients, it remains taxable in France as a non-resident regardless of the treaty.
The steps, in order
- Decide which of the three article 4 B tests you are actually breaking, home, main professional activity, or centre of economic interests, before you assume residency has ended.
- Wind down French economic ties deliberately - French clients, bank balances and income streams that keep pointing the centre-of-economic-interests test back at France.
- File your departure-year return and notify the tax authorities of non-resident status, rather than leaving on paper as someone who never left.
- Make sure the work is genuinely performed from Georgia, since article 155 A re-attributes income earned by someone who stays in France in substance, whatever the invoice says.
- Check any shareholdings against the article 167 bis threshold (EUR 800,000 or 50% of profit rights) before departure if you hold a French or foreign company.
- Register a Georgian IE or LLC, either in person or under power of attorney through remote company registration; article 209 B does not distinguish between them for an individual owner.
- Deregister from URSSAF through the single formalities window once you stop the activity, effective within 30 days of the declared date.
- Arrange health cover before PUMA access ends, rather than assuming it continues past residency.
Timeline and cost
The Georgian side is fast: an IE with Small Business Status typically registers within days in person, or a few weeks under power of attorney. The French side takes longer to close properly: URSSAF deregistration runs about a month, the departure return follows the normal annual calendar, and an exit-tax declaration, where article 167 bis applies, needs preparing before filing. Budget for a French accountant to close the departure year and, if shares exceed the threshold, a cross-border adviser for the deferral and guarantee.
The verdict: works, but only if you actually leave
France has a real treaty, is not on its own blacklist against Georgia, and article 209 B does not reach an individual holding a Georgian IE or LLC directly. For someone who genuinely relocates, breaks residency under article 4 B, and does the work from Georgia, the 1% is legally durable and the saving, mostly on social contributions, is real and large.
The condition is doing the work of actually leaving. Article 155 A exists specifically to catch the version that fails: someone who keeps their home, clients and working life in France while routing invoices through a Georgian registration for the rate. That version adds a Georgian filing on top of a French bill that never stopped. Strong fit for someone genuinely moving, usually not worth attempting for someone who is not.
We'll work through whether your French residency is genuinely breakable given your specific ties, what article 167 bis and article 155 A mean for your situation, and what the honest all-in comparison looks like once social contributions are counted properly.
See what it costs
If you are weighing this against another jurisdiction entirely, our Georgia tax residency guide covers the 183-day test and the HNWI route from the Georgian side, and our guide on moving from the USA to Georgia covers the very different position a US national is in. A free consultation is the fastest way to get a straight answer on where your own situation actually sits.
Key takeaways
- Identify which article 4 B test currently keeps you French resident, home, professional activity or economic interests, and address that one specifically rather than assuming a day count alone will do it.
- Keep the work itself in Georgia once you move. Article 155 A attaches to where services are actually rendered, not to where the invoice is issued from.
- Check any real shareholdings against the article 167 bis threshold before you leave, not after, since the deemed sale is valued on your last resident day.
- File the departure-year return and URSSAF deregistration on time. An unfiled departure looks, on paper, like someone who never left.
- Arrange health cover before PUMA access ends, since it stops on residency rather than on a separate application.
Frequently asked questions
Does France have a tax treaty with Georgia?
Yes. The convention has been in force since 1 June 2010, confirmed on the French tax authority's own BOFiP database, giving a genuine tie-breaker if both countries have a residency claim in the same year.
How is French tax residency actually broken?
Article 4 B CGI sets three alternative tests: a home or principal residence in France, a principal professional activity there, or the centre of your economic interests being there. Meeting any single one keeps you resident, so genuinely leaving means relocating all three together, not just registering a foreign business.
Does the French exit tax apply to a Georgian Individual Entrepreneur?
Rarely, because an IE is a sole proprietorship with no shares. Article 167 bis targets unrealised gains on securities over EUR 800,000 or 50% or more of a company's profit rights, for someone resident at least six of the last ten years. It becomes relevant if you also hold a company above that threshold.
What is article 155 A and why does it matter here?
It lets France tax income received by a person or entity outside France as payment for services actually performed by someone still in France. Keep living and working from France while invoicing through a Georgian IE or LLC, and that income can be re-attributed to you directly at ordinary French rates, with the Georgian 1% offsetting almost none of it.
Do France's CFC rules reach a Georgian company I own personally?
No, not if you hold it directly as an individual. Article 209 B only applies where a French company subject to corporate tax holds a foreign entity in a privileged tax regime, not to individuals holding a Georgian IE or LLC in their own name.
Is Georgia on France's blacklist of non-cooperative states?
No. France's current list, updated April 2026, names eleven jurisdictions and Georgia is not one of them, which matters since being listed would trigger higher withholding and stricter anti-abuse tests regardless of the treaty.
How much do French social contributions actually cost compared to Georgia's 1%?
They are the larger part of the comparison. Self-employed cotisations sociales run roughly 25 to 45% depending on regime and income band, covering health cover, family benefits and retirement, while Georgia carries no equivalent charge.
What happens to my French health cover if I leave?
It ends once you are no longer French tax resident, since state health cover runs through the PUMA system tied to residence. Cover elsewhere needs arranging separately, and it is a real cost to weigh against the tax saving.
Can I keep French clients after I move to Georgia?
Yes, but the income may remain French-source and taxable in France as a non-resident regardless of where you live, and if you still personally perform the work while physically in France for part of the year, article 155 A and the residency tests both become relevant again.