However, this deduction must not exceed the part of the income tax or capital tax calculated before the preference, due to income or capital that can be taxed in France. (c) the remuneration is not borne by a permanent establishment or registered office of the employer in the other State. If you do not pursue financial emigration or if you do not explain the change in status by paying the capital gains upon emigration, your executor in South Africa will have to declare the CGT on the day of death and inheritance tax. 72.617 153.783 41 (0.41 x T) – (EUR 13.694.61 x N) In most bilateral tax agreements with France, the tax domicile is first determined according to the law of the country that enforces the tax decisions. If the person is considered a resident under the law of two countries, the contract includes “Tie Breaker” provisions to determine the country of residence. These tie-breaker tests usually include, as criteria in descending order, permanent residence, personal and economic relationships (vital interests), habitual residence, nationality and, if none of the above tests are inextinguir, the decision of the competent authorities. The French social security system is made up of different schemes offering a wide range of benefits. This scheme includes basic social security (sickness, maternity, invalidity, death, accident benefits at work and State old-age pension), unemployment benefits, compulsory supplementary pension schemes, supplementary death/disability cover and supplementary sickness insurance. If you decide to apply for financial expatriation through the SARB and SARS, you will have to pay an additional tax, a “departure tax”. .