Moving to Dubai while running a French company: is it possible?
Table of contents
Introduction
Yes, it is legally possible to move to Dubai while keeping a corporate office in a French company. Yet it is one of the arrangements most exposed to tax audits, because it leaves an activity, a source of income and decision-making power in France. The useful question is therefore not whether it is allowed, but under what conditions it holds up.
Two mistakes come up again and again with this arrangement. The first is believing that the director's departure moves the company's taxation, whereas the company remains taxable in France. The second is underestimating the weight of the corporate office in assessing personal tax residence, particularly under the centre of economic interests test.
A transfer of tax residence to Dubai must therefore be prepared alongside the reorganisation of the French governance. The two workstreams move forward together, and the order in which they are carried out changes the final level of risk. This article describes the applicable rules, the friction points and the realistic trade-offs.
Opting for tax expatriation is a lawful step when it is based on a genuine move of one's centre of life and on solid documentation. The thresholds and rates quoted here are publicly available orders of magnitude to be checked case by case, as the answer always depends on the director's personal situation and the structure of their income.
The short answer: yes, but the corporate office does not move with you
Nothing in French law prevents a non-resident from being the chairman, manager or chief executive officer of a French company. Corporate offices are not reserved for residents, and the office holder is under no obligation to have a personal address in France. The difficulty lies elsewhere: the corporate office follows the company, not the director.
Settling in the UAE moves your personal residence, provided it is genuine and documented. It moves neither the French company's registered office, nor its registration, nor its tax regime. You therefore end up with a situation on two distinct tax levels, which must be analysed separately before any decision is made.
Two tax residences to be carefully distinguished
The tax residence of an individual is assessed under Article 4 B of the French Tax Code (CGI), through four alternative criteria: the home, the place of principal stay, the principal professional activity and the centre of economic interests. A company's residence follows a different logic, based on the registered office and the place of effective management. Confusing the two almost always leads to a poor wealth-planning decision.
This distinction has an immediate practical consequence. You can perfectly well become a French tax non-resident and remain chairman of a simplified joint-stock company (SAS) which, for its part, remains fully taxable in France. The reverse also exists and is the most costly trap: a UAE entity managed from France can be caught by French tax.
What your departure does not change for the French company
French corporate tax applies to the profits of businesses operated in France. The director's departure changes neither the tax base, nor the rate, nor the entity's filing obligations. The company continues to file its tax return, pay its tax and meet its usual deadlines.
Ancillary obligations also survive the departure. Bookkeeping, approval of the accounts, filing with the commercial court registry, VAT returns and employee social security returns remain due according to the French calendar, and monitoring them remotely requires more rigorous organisation than before.
Territoriality of corporate tax
The territoriality principle looks at where the business is carried on, not where the shareholder or office holder lives. A company whose teams, customers, inventory and premises are located in France remains a business operated in France. At this stage, the chairman's place of residence is only a secondary factor.
It becomes central in only one scenario: when effective management genuinely leaves the country and the business follows suit. A genuine business relocation to Dubai then requires transferring the functions, assets and risks, not just a postal address. This operation has its own tax consequences and should not be confused with the director's mere departure.
The corporate office and the centre of economic interests
This is where the arrangement becomes tricky. Among the four criteria of Article 4 B, the centre of economic interests refers to the place from which the taxpayer derives most of their income and holds their main investments. A director who keeps a significant French company therefore, by definition, leaves a substantial part of their wealth there.
The French tax authorities reason in terms of volume and proportion. They compare French-source income with foreign-source income, then the value of French assets with that of assets held elsewhere. When the French company accounts for the bulk of both, this criterion alone may be enough to maintain French tax residence, even with a very limited physical presence in France.
A single criterion is enough, and this is the point most misunderstood by directors preparing their departure. The 183-day rule is neither necessary nor sufficient on its own, so an impeccable day count offers no protection against a reclassification based on economic interests remaining in France.
Paid or unpaid office: the nuance
An unpaid office carries less weight than one that constitutes the director's main source of income. Waiving remuneration removes one indicator without eliminating the others, since share ownership, decision-making power and the value of the shares remain. It is therefore a useful but insufficient adjustment on its own.
The most robust approach is to reduce several indicators at the same time. Handing over operational management, diversifying income sources outside France and having part of the business carried by the UAE structure lower the exposure in a consistent and verifiable way. Each situation remains specific and deserves an individual review before any commitment.
Where your director's remuneration is taxed
Remuneration paid by a French company to a non-resident director remains taxed in France. The French Tax Code (CGI) provides for withholding tax on amounts paid to non-resident corporate officers and employees, and the France–UAE tax treaty signed in 1989 does not neutralise this taxation for directors' remuneration.
Withholding tax and minimum tax rate
Withholding tax follows a bracket-based scale specific to non-residents, and French-source income is also subject to a minimum tax rate of 20% on the first portion of net taxable income. This minimum rate can be set aside if the taxpayer demonstrates that their average worldwide rate would be lower, which requires them to declare all of their income. The brackets and amounts change regularly and should be checked every year.
On top of this comes the 7.5% solidarity levy, which replaces the CSG and CRDS social contributions on certain income of non-residents covered by a social security system outside France. The exact interplay depends on the applicable social security regime and the nature of the income, making it a matter to handle with a practitioner.
The strategic consequence is clear. Continuing to draw remuneration from France after moving to Dubai amounts to deliberately keeping a tax base in France while feeding the centre of economic interests criterion. For this reason, many directors prefer to restructure their remuneration before actually leaving.
Dividends from the French company after you leave
Dividends paid by a French company to a non-resident shareholder are subject to the withholding tax provided for in Article 119 bis of the French Tax Code (CGI). The domestic rate is high, but tax treaties frequently reduce it, and the France–UAE tax treaty provides favourable treatment for distributions to the UAE. However, benefiting from the treaty requires proof of UAE residence.
This is precisely one of the uses of the tax residency certificate issued by the Federal Tax Authority. Without this document, the paying institution applies the domestic rate, and recovering the overpayment becomes a long and uncertain process. The certificate should therefore be requested ahead of any significant distribution.
On the UAE side, dividends received by an individual bear no income tax, since the UAE does not levy any. The question of how a director's dividends are taxed in Dubai therefore comes down, in practice, to the withholding tax applied in the country of the distributing company. The reasoning remains the same for other jurisdictions with no income tax.
Comparisons can be instructive. Dividend taxation for a company director in the Bahamas follows the same French withholding logic, and the differences between destinations stem mainly from the treaty network rather than from local taxation. Choosing a jurisdiction therefore depends as much on the quality of the treaties it has signed as on a headline rate of zero.
The reverse risk: shifting the place of effective management
The mirror-image danger exists and is often overlooked. If you set up a structure in the UAE while continuing to run your French company from Dubai, you are building two entities whose places of decision-making overlap. The French tax authorities may then seek to attach one or the other to the jurisdiction where decisions are actually taken.
Place of effective management and tie-breaker rules
A company is in principle resident in the State where its place of effective management is located, that is, the place where strategic decisions are taken. When two States claim the residence of the same entity, tax treaties provide hierarchical tie-breaker rules. These rules rely on material facts, never on stated intentions.
From France to the UAE, the risk is that a UAE entity managed from France will be treated as French. In the opposite direction, a French company whose chairman decides everything from Dubai may have its residence challenged, creating a legal uncertainty that is rarely desirable. In our article on the economic substance actually expected in the UAE, we detailed the concrete elements that make it possible to demonstrate where decision-making power lies.
Added to this is the question of permanent establishment. If your French company has a fixed place of business in Dubai or an agent authorised to conclude contracts, part of its profit may become taxable in the UAE, where corporate tax has stood at 9% since June 2023. The situation then becomes doubly complex to document.
Organising remote governance in practice
The most common solution is to clearly separate legal authority from operational management. The expatriate director keeps a chairman's office with defined powers, while a chief executive officer or senior executive based in France handles the day-to-day management of the business. Delegations of authority are formalised in writing, dated and kept up to date.
Minutes, videoconferencing and written records
A governance arrangement is only as good as its evidence. Minutes of shareholder and board meetings must state the actual place where the meeting was held, the participants and the method of participation, and meetings held by videoconference from Dubai should be documented consistently. A regular practice is always better than a file reconstructed after the fact.
The same requirements apply to major operational decisions: approval of commercial proposals, hiring, banking commitments and signing of framework agreements. Keeping a dated record of who decides what, and from which country, is the best protection in the event of a tax audit several years later.
Finally, the director must ensure their own consistency. Frequent trips to France, a personal office still available at headquarters and systematic attendance at French business meetings send a signal contrary to that of a genuine departure, and weaken the entire wealth and tax structure.
Social security, pension and departure timeline
The social security aspect is all too often dealt with last. A director who stops being paid by their French company in principle loses affiliation with the corresponding French scheme, with effects on health coverage and on the accrual of pension rights. The UAE does not offer foreign residents an equivalent public scheme, which makes it necessary to take out suitable private coverage.
Timing matters as much as substance. Preparing the departure six months in advance makes it possible to reorganise governance, open the necessary accounts, obtain the residence visa and then the tax certificate, and decide on distributions before the change of status. An improvised departure almost always leaves contradictory indicators behind it.
This is a useful stage for comparing destinations. Some directors look at dividend taxation in Andorra to stay in continental Europe, while others examine the treatment of dividends in Portugal for its proximity and its treaty network. The right choice depends on the income mix, the location of customers and each person's family constraints.
Other choices favour administrative simplicity. Dividend taxation for a director in Georgia attracts highly mobile profiles, while dividend taxation in Mauritius appeals to those looking for a French-speaking environment. In all cases, the question of the French corporate office remains open and must be addressed.
Comparison table of management configurations
The table below summarises five configurations seen among directors who have moved to Dubai. It describes general trends, not guarantees, as the outcome depends on the facts specific to each case. The statutory rates mentioned elsewhere in the article are public data to be confirmed at the time of the decision.
Configuration chosen | Taxation of the company | Director's remuneration | Main risk |
Chairmanship retained, unpaid office | Remains fully French | No amounts paid | Centre of economic interests |
Chairmanship retained, paid office | Remains fully French | French withholding tax | French residence maintained |
Salaried CEO in France | Remains fully French | Local salary taxed in France | Loss of operational control |
French holding company and UAE subsidiary | Two separate tax liabilities | Dividends after withholding tax | Transfer pricing and economic substance |
Sale of the company before departure | Taxation of the capital gain | Not applicable afterwards | Exit tax and abuse of law |
None of these configurations is good or bad in itself. The last row simply points out that a sale planned after the departure raises its own issues, notably the taxation of unrealised capital gains, and that it must be prepared well before signing.
Testimonial from an expatriate company director
Guillaume, 44, is chairman of an engineering consultancy based in Lyon that employs around a dozen people. He moved to Dubai with his family and agreed to look back on the first two years after his departure.
“I left keeping the chairmanship and continuing to pay myself a French salary, because it seemed simpler. My adviser showed me that I ticked almost every box for maintained French tax residence, and I took it rather badly at the time.”
“We reorganised everything in six months: appointing a CEO in Lyon, written delegations, stopping my French remuneration and developing a business of my own from the UAE. The minutes now state the actual place where decisions are made, and I only return to France for specific meetings. The arrangement is more demanding to maintain, but it is finally consistent with my actual situation.”
Frequently asked questions
Can you remain chairman of a French company while living in Dubai?
Yes, corporate offices are not reserved for French residents and no rule requires the chairman to live in France. The real question concerns the tax consequences of the office, which affect both your personal residence and the treatment of your income.
Should you give up your remuneration as a French company director?
It is not an obligation, but French remuneration remains taxed in France and feeds the centre of economic interests criterion. Many directors prefer to reduce or stop it, after checking the effects on their social security coverage and pension rights.
Is the corporate office enough to maintain my French tax residence?
Not on its own, but it is never neutral. Combined with French remuneration, a majority shareholding and regular stays in France, it may be enough to tip the analysis, as the four criteria of Article 4 B are alternative.
Can my French company become a UAE company if I manage it from Dubai?
A change in the company's tax residence cannot be improvised and requires a genuine transfer of effective management, with immediate tax consequences in France. In practice, the risk is rather that of an ambiguous situation in which two States claim the same entity.
How much time should be allowed to reorganise governance before leaving?
A six-month timeframe generally makes it possible to appoint an operational manager, draft the delegations, adjust remuneration and obtain the UAE documents. More complex cases, particularly those preceding a sale, require a considerably longer horizon.
Is a French chartered accountant enough to secure this arrangement?
One is essential for the company, but the question combines international tax law, company law, the France–UAE tax treaty and local UAE rules. A cross-review from both sides is preferable, and only an individual review can settle your case.
Conclusion
Moving to Dubai while running a French company is therefore possible, provided you accept that it is the arrangement with the most demanding burden of proof. The company remains French, the remuneration remains taxed in France and the corporate office feeds a residence criterion, which calls for a documented reorganisation of governance.
The guiding principle comes down to three words: compliance, genuine substance and documentation. A departure built on these foundations withstands scrutiny, whereas a Dubai address placed on top of an organisation that has remained French is a lasting and costly weakness.
Let us stress one last time that every situation is different. The number of employees, the share of French customers, the composition of assets and where the family lives completely change the conclusions, and only an individual review can settle the matter.
You run a French company and are considering settling in Dubai. You can request a personalised review from Coreway Consulting to examine your corporate office, your remuneration and your departure timeline.
