Ambilatres

[ France–Switzerland corridor — Both banks ]

Your PEA on the day you leave France for Geneva

France no longer closes the account. Switzerland never recognised the shelter in the first place. What changes when you cross is not the account — it is who taxes what inside it, and how often.

The short answer

Your PEA is not closed when you transfer your tax residence out of France, and its acquired tax history is preserved. [impots.gouv.fr]

Switzerland does not recognise the wrapper at all. Geneva taxes what is inside it as though it were an ordinary custody account. [RS 0.672.934.91]

So the shelter survives on one bank and stops existing on the other. A one-off cost on the way out is replaced by a cost you carry every year you hold it.

1. What France does on the day you leave

The forced-closure rule is gone. Transferring your tax domicile out of France does not liquidate a PEA. The account stops accepting new money and keeps running on what is already inside it. The French tax administration publishes this directly. [impots.gouv.fr, international-particulier]

Le transfert de résidence hors de France rend les PEA inactifs, mais leur antériorité fiscale est préservée.
[bergeotpaoli.com — secondary source, restating the rule]
  • The five-year and eight-year holding clocks keep counting while you are non-resident. A PEA opened in 2019 is past five years in 2026 whether you live in Paris or in Geneva.
  • You cannot pay new money in. The account is inactive, not closed. [impots.gouv.fr]
  • For a French resident, a withdrawal from a PEA held more than five years is exempt from income tax but the gain still carries French social levies, 18.6% for 2026 — CSG 10.6%, CRDS 0.5%, prélèvement de solidarité 7.5%. [LFSS 2026]
  • Whether those social levies still reach you once you are affiliated to the Swiss system is the single largest open figure in this corridor. See section 4.

Separately, transferring your tax domicile out of France triggers a deemed taxation of unrealised gains on securities — the exit tax. [CGI art. 167 bis] It only bites above thresholds: a direct or indirect holding of at least 1% of a company's profits, or an aggregate portfolio value commonly cited at €800,000. We could not re-confirm the current in-force monetary threshold against the article text, so treat it as a trigger to check, never as a figure to rely on.

2. What Geneva does with the same account

Switzerland has no PEA, and neither Swiss law nor the France–Switzerland convention mentions the wrapper anywhere. The convention allocates taxing rights by the nature of the income — dividends, interest, capital gains — and never by the account the asset happens to sit in. [RS 0.672.934.91, art. 11, 12, 15] The result is a look-through: Geneva taxes the securities, not the envelope.

The first consequence is favourable, and it has nothing to do with your PEA.

Les gains en capital réalisés lors de l'aliénation d'éléments de la fortune privée ne sont pas imposables.
[LIFD art. 16 al. 3 — fedlex.admin.ch, state 1 January 2026]

Sell a share inside your PEA as a Geneva resident and the gain is not taxed in Switzerland — not because it was in a PEA, but because Switzerland does not tax private capital gains at all. The exemption is lost if you are classed as a professional securities trader, a test based on transaction frequency, holding period, leverage and whether you live off the proceeds.

The second consequence runs the other way. Dividends and interest are taxable as income from movable wealth, at your combined federal, cantonal and communal marginal rate. [LIFD art. 20 al. 1] The 70% partial taxation exists only for holdings of at least 10% of a company and does not reach a retail portfolio. [LIFD art. 20 al. 1bis]

  • France may withhold on the dividends it sources, capped at 15.0% of the gross amount for a Swiss-resident beneficial owner. [RS 0.672.934.91, art. 11 §2 a]
  • French-source interest is taxable only in Switzerland. [art. 12]
  • Switzerland relieves the French tax withheld, so the same income is not taxed twice. [art. 23 §2]
  • A French PEA administrator applies French domestic withholding mechanics unless treaty relief is claimed at source. We found no primary source confirming that, so it is listed below as unverified.

The third consequence has no French equivalent at all: the portfolio itself becomes taxable every year. Geneva levies an impôt sur la fortune on net wealth, and a PEA is wealth.

  • Déduction sociale on wealth, 2025 tax year: CHF 87'632 for a single person, CHF 175'264 for spouses or registered partners in a common household, plus CHF 43'816 per dependant. [AFC-GE, guide 2025]
  • Above that, the impôt de base runs through progressive brackets — 2.55‰ marginal between CHF 355'194 and CHF 473'591, 2.76‰ above it — and a separate impôt supplémentaire sur la fortune stacks on the same brackets. [AFC-GE, barème fortune 2025]
  • The bill you actually pay is that base tax multiplied by cantonal and communal centimes additionnels, which differ by commune. On a portfolio near CHF 500'000 the total lands somewhere between 0.3% and 0.6% a year. That is an order of magnitude, not a figure: we did not confirm the current centimes.

A CHF 500'000 portfolio in a PEA opened in 2019

Capital gain on a share sold inside the account

French tax resident

Exempt from income tax; 18.6% social levies on withdrawal [LFSS 2026]

Geneva tax resident

Not taxable [LIFD art. 16 al. 3]

Dividends received inside the account

French tax resident

Sheltered while they stay in the account [PEA regime, article unverified]

Geneva tax resident

Ordinary income at your marginal rate [LIFD art. 20]

Annual tax on simply holding the portfolio

French tax resident

None

Geneva tax resident

Wealth tax, order of 0.3% to 0.6% a year [AFC-GE barème, estimate]

Paying new money in

French tax resident

Permitted, within the statutory ceiling

Geneva tax resident

Not permitted; the account is inactive [impots.gouv.fr]

An illustration on stated assumptions, not a computed Position. Your own figures move with your dividend yield, your Geneva marginal rate and your commune.

3. If you commute to Geneva instead of moving there

This is the most common confusion in this corridor, and it changes everything above. If you keep your home in France and cross the border to work, you never become a Swiss tax resident, and nothing in section 2 applies to you. Your PEA stays entirely French.

  • Geneva taxes your Swiss salary at source under its own 1973 arrangement and retrocedes 4.5% of gross cross-border salaries to Ain and Haute-Savoie. France then avoids double taxation with a credit. [RS 0.672.934.91, art. 25 A] You are explicitly not a frontalier under the 1983 accord. [impots.gouv.fr, salariés en Suisse]
  • The eight other cantons work the opposite way. A French resident working in Vaud, Valais, Neuchâtel, Jura, Berne, Bâle-Ville, Bâle-Campagne or Soleure is taxed on that salary only in France. [art. 17 §4 and accord of 11 April 1983]
  • So two people with identical payslips, one in Geneva and one in Lausanne, have different French tax returns and a different answer on every asset they hold.

4. The three figures that actually decide this

Everything above is the general rule. What it costs you comes down to three numbers, and none of them are in this article because none of them are ours.

  • Whether French social levies still reach your PEA. As a French resident the gain carries 18.6%. [LFSS 2026] For non-residents affiliated to a compulsory social security scheme in an EEA state or Switzerland, France drops CSG and CRDS and levies only the 7.5% prélèvement de solidarité — confirmed in the official text for property gains [impots.gouv.fr], not confirmed for a PEA. That is an 11.1 point swing on your whole gain.
  • The dividend yield of what you hold. Crossing stops your gains being taxed and starts your dividends being taxed at a Geneva marginal rate. A portfolio that distributes almost nothing and one that distributes 4.0% cross the same river to very different bills.
  • Your commune. The wealth-tax brackets are cantonal but the centimes additionnels are communal, so the same portfolio at two Geneva addresses does not produce the same annual amount. [LIPP, centimes additionnels]

What we could not verify

We publish this list because a figure without its confidence is not a figure. Everything above carries a source; these are the points where that source is weaker than we would like, and they are exactly the points we re-derive against primary text before they go into a paid Dossier.

  • The codifying article for a PEA surviving emigration, reportedly CMF art. L221-30 as amended, was not opened against the primary text. The rule itself is stated on impots.gouv.fr.
  • Whether a Geneva-resident holder still owes French social levies on a PEA withdrawal, and at 18.6% or 7.5%. The reduced rate is confirmed in official text for property gains only.
  • The current in-force monetary threshold for the exit tax under CGI art. 167 bis. The 1% holding test and the €800,000 aggregate value are practitioner literature describing an earlier version of the law.
  • The 2026 Geneva déduction sociale on wealth. CHF 87'632 and CHF 175'264 are the 2025 tax-year figures published by AFC-GE and are indexed annually.
  • The current Geneva cantonal and communal centimes additionnels, which is why the annual wealth-tax cost above is a range and not a number.
  • The 18.6% French social-levy rate for 2026 is corroborated by tax press citing the LFSS 2026; impots.gouv.fr still displays 17.2% on its own pages.
  • LHID art. 7 al. 4 let. b, the cantonal mirror of the capital-gains exemption, is cited from a secondary source. LIFD art. 16 al. 3 itself was read directly on fedlex.admin.ch.
  • The professional-securities-trader test that would remove the Swiss capital-gains exemption was not re-read from an ESTV circular.

Sources

Rule base last updated 26 August 2026

This is the general rule.

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