French impatriate tax regime: who qualifies, what it is worth and how to claim it

You have been offered a senior position in Paris, your group is transferring you to its French subsidiary, or you plan to run a French company. Before you sign, check whether your move qualifies for the French impatriate tax regime. It can exempt a significant part of your salary and half of certain foreign investment income from French income tax until 31 December of the eighth year after the year you start work in France, but its conditions are strict and several must be met before you arrive. This guide explains who qualifies, what the regime is worth and the mistakes to avoid.

What is the French impatriate tax regime?

The French impatriate tax regime (régime des impatriés) is a temporary set of income tax exemptions for employees and certain company executives who come from abroad to work for a business established in France^[1][2]. It is laid down in article 155 B of the CGI, in a version in force since 31 December 2018^[1].

Employees and the persons mentioned in 1°, 2° and 3° of b of article 80 ter who are called from abroad to hold a position in an undertaking established in France for a limited period are not subject to tax on the elements of their remuneration directly linked to that situation or, on option, up to 30% of their remuneration.

Article 155 B, I, 1 of the French General Tax Code, first sentence, unofficial translation ^[1]

It offers three income tax advantages: an exemption for the impatriation premium, an exemption for the part of salary relating to work carried out abroad in the employer’s interest, and a 50% exemption on certain foreign passive income and capital gains^[1][7]. A separate rule of the CGI also protects new residents’ foreign real estate from the French real estate wealth tax (IFI) for five years^[8].

Two further rules concern pensions. First, contributions you keep paying abroad are deductible from your taxable salary: those to your home country’s compulsory social security scheme, where you remain affiliated under EU rules or a social security agreement, and, within limits and until 31 December of the eighth year after the year you take up your position, those to the supplementary pension and provident schemes you belonged to before arriving^[7][12][13]. Second, under article L767-2 of the Social Security Code, an employee called from abroad can ask, jointly with the employer, not to be affiliated to the French basic and complementary state pension schemes, provided they pay a minimum pension contribution elsewhere, set at €20,000 a year, and were not affiliated to a French pension scheme in the previous five calendar years^[7][14][15]. This exemption lasts three years, renewable once, and earns no French pension rights^[14].

Who qualifies for the French impatriate tax regime?

Impatriate regime: the three conditions to check before you move

• 1PastNo French tax domicile during the five calendar years before the year you take up your position
• 2RecruitmentCalled from abroad by a foreign group company, or recruited directly abroad by a company established in France
• 3Status and residenceEmployee or assimilated executive, with your home and main professional activity in France each year

The conditions are cumulative. Coming to France on your own initiative, or having already moved before being recruited, excludes the income tax regime.

The five-year non-residence condition

You must not have been domiciled in France for tax purposes during the five calendar years preceding the year in which you take up your position, whatever your nationality^[1][3]. French nationals returning after a long period abroad can therefore qualify. The date of taking up the position is the date on which performance of the employment contract or corporate mandate actually begins in France^[3].

Employees recruited abroad or moved within a group

Two routes are possible^[3][7]:

• intra-group mobility: you are called by a foreign company to work for a French company with which it has capital, legal or commercial links, for example a transfer from a foreign parent to its French subsidiary;
• direct recruitment from abroad: a company established in France hires you while you are still living abroad, including when you applied from abroad to a French job offer.

The contract does not need to be fixed-term, nor to state how long you will stay in France^[7]. By contrast, people who come to work in France on their own initiative, or who had already settled in France when they were recruited, cannot benefit from the regime^[3][7]. Keep evidence that your home was still abroad when you were hired^[3].

Company directors, entrepreneurs and the self-employed

Besides employees, the regime covers executives treated as employees for tax purposes: in particular the chair of the board, chief executive officer and deputy chief executive officers of an SA or SAS, members of the management board, and minority or equal managing partners (gérants) of an SARL^[3]. A director may qualify even when holding shares in the company that recruits them, provided the pay is taxed as salary and the director remains taxed at least on the reference remuneration described below^[7].

Self-employed professionals, majority managing partners of an SARL and founders who are not paid under the salary rules fall outside the income tax regime, since article 155 B only covers employees and assimilated executives^[1][3]. Where a foreign company sends someone to France precisely to create the French company, the administration accepts that the host company may not yet legally exist on the date the position is taken up^[3][7]. Our guide to setting up a company in France covers the corporate side of this choice.

How long does the France expat tax regime last?

For anyone who took up their position on or after 6 July 2016, the exemptions apply until 31 December of the eighth calendar year following the year the position was taken up, for each year of French tax domicile within the meaning of article 4 B, 1, a and b^[1][2]. A move in 2026 therefore opens the regime until 31 December 2034^[7].

Arriving in France in 2026: the key dates

1. 2021 to 2025No French tax domicile during these five calendar years
2. 2026Taking up the position in France: start of the regime
3. By end of 2027Family home settled in France, for the salary exemption to run from 2026
4. 31 Dec. 2031End of the IFI protection for foreign real estate
5. 31 Dec. 2034End of the income tax exemptions under article 155 B

Assumes a French tax domicile established in 2026. Each year is assessed separately: a year without French domicile is lost, without extending the regime.

If your family home is settled in France by the end of the calendar year following the year you started, the salary exemption applies from the start^[3][7]. This tolerance does not extend to the passive income exemption^[3].

The regime survives a change of position within the same company or a move to another company of the same group, without extending its total duration. It ends, however, if you leave the host company or group before the end of the period, even if you remain resident in France^[3][7].

Moving to France tax benefits: the impatriation premium

Actual premium or 30% flat-rate option

The impatriation premium is the extra remuneration, in cash or in kind, directly linked to working in France. In principle it is exempt for its actual amount, which must appear distinctly in the employment contract, the corporate mandate or an amendment drawn up before you take up your position, or be determinable from objective criteria stated in it^[4][7].

Alternatively, you may opt for a flat-rate valuation: the premium is then deemed equal to 30% of your total net remuneration, even if the contract provides for no premium^[1][4]. Originally reserved for direct hires, the option was extended by the 2019 Finance Act to group transfers who took up their position from 16 November 2018, so it is now open to both^[4].

The reference salary rule

The exemption has a floor: the remuneration that remains taxable must be at least equal to the pay for similar functions in the same company or, failing that, in similar companies established in France. If it is lower, the difference is added back to your taxable income^[1][4].

Days worked abroad and the two exemption caps

The part of your salary relating to stays abroad made in the direct and exclusive interest of your employer is also exempt. Failing a contractual allocation, it can be calculated by reference to the number of days of activity abroad over the total days of actual activity, travel time excluded^[4]. Each year, you then choose one of two caps^[1][4]:

• a global cap: the premium and the foreign-work salary together cannot exceed 50% of total remuneration;
• or a cap on the foreign-work part only: limited to 20% of taxable remuneration, net of the exempt premium.

50% exemption on foreign passive income and capital gains

For the same period, the impatriate is exempt from income tax on 50% of: investment income (dividends, interest) paid by a person established outside France; certain intellectual or industrial property income paid from abroad; and gains on the sale of securities where the custodian or, failing that, the company is established abroad^[1][5]. The paying country must have a tax treaty with France containing an administrative assistance clause; the official list includes, for example, the United Kingdom and the United States^[11]. Correspondingly, capital losses on such securities are only recognised for 50% of their amount^[5].

The exemption only benefits the impatriate personally, not their spouse^[5]. French social levies remain due on the full amount, before the 50% exemption^[6]. If you remain affiliated to the social security scheme of another EU or EEA State, Switzerland or the United Kingdom and are not covered by a French compulsory scheme, CSG and CRDS are not due on this investment income: only the 7.5% solidarity levy applies, still on the full amount^[16][17][18]. Finally, all exempt income is still counted in your reference tax income (revenu fiscal de référence)^[6].

IFI relief for impatriates

French residents are normally liable to the real estate wealth tax (IFI) on their real estate worldwide when its net value exceeds €1.3 million^[8][9]. Under article 964 of the CGI, someone who was not domiciled in France during the five previous calendar years is taxed only on their French real estate, until 31 December of the fifth year following the year in which they became domiciled in France^[8].

However, the natural persons mentioned in the first paragraph of this 1° who have not been domiciled in France for tax purposes during the five calendar years preceding the year in which they have their tax domicile in France are only taxable on the assets mentioned in 2°. This provision applies for each year in which the taxpayer retains their tax domicile in France, until 31 December of the fifth year following the year in which the tax domicile was established in France.

Article 964, 1° of the French General Tax Code, unofficial translation ^[8]

Unlike the income tax regime, this IFI rule requires no employment condition, so it also benefits entrepreneurs, investors and retirees^[7]. Our guide to the French wealth tax explains this five-year IFI relief for new residents in more detail.

When does the impatriate regime start? Becoming resident in France

The regime only applies for years in which you are domiciled in France under the first two criteria of article 4 B of the CGI: you must have your home or main place of stay in France and carry on your main professional activity there^[3][10]. Being French resident only because your centre of economic interests is in France is not enough^[3].

Tax treaties also play a role. If a treaty’s tie-breaker rules make you a resident of the other country, the regime does not apply for that year, even if you meet the French domestic criteria^[3]. Our article on the French tax residency tests explains how these criteria are assessed.

How to claim the French impatriate tax regime

No prior approval is required, but several formalities must be completed^[4][7]:

• before arrival: provide for the impatriation premium in the contract or an amendment, or plan to use the 30% option;
• the employer reports the exempt amounts separately in the monthly social declaration (DSN) and determines the reference remuneration;
• each spring, in the income tax return for the previous year, you check the pre-filled taxable salary, report the exempt salary on form 2042 C, and state your options (flat-rate premium, choice of cap) in the « other information » section;
• for certainty, you or your employer may request a formal ruling (rescrit) from the administration.

Claiming the impatriate regime: the formalities

1. Before arrivalImpatriation premium provided for in the contract or an amendment, or plan to use the 30% option
2. EmployerExempt amounts reported separately in the DSN; reference remuneration determined
3. Each springPre-filled salary checked, exempt salary reported on form 2042 C, options stated in the return
4. OptionalFormal ruling (rescrit) requested from the administration, for certainty

No prior approval is required, but each of these formalities must be completed^[4][7].

Common mistakes with the impatriate regime

• Moving before being hired: settling in France and then looking for a job excludes the regime.
• Signing the contract too late: an actual premium written into an amendment after the start date cannot be exempt as such; only the 30% option remains.
• Ignoring the reference salary: an overly generous premium is partly added back to taxable income.
• Undocumented days abroad: without evidence, the foreign-work exemption can be challenged on audit.
• Changing employer outside the group: leaving the host company or group ends the regime.
• Forgetting the treaty: a treaty residence in another country neutralises the regime for that year.

Why take legal advice before moving to France?

The contract, the premium option, your status as employee or director and the coordination with your former country’s tax rules are all decided before or on arrival. Our tax support for executives moving to France covers each condition, models the different options and secures your first French tax return.

About to relocate to France, or already negotiating your contract? Prepare your relocation with Alexis Germe and bring your draft contract or offer letter and a summary of your residence history over the last five years: they are enough to assess your eligibility and options.

Sources and reference texts

1. Article 155 B of the French General Tax Code, version in force (Légifrance)
2. BOFiP, BOI-RSA-GEO-40-10, RSA, impatriate employees, special tax regime (published 21 June 2017)
3. BOFiP, BOI-RSA-GEO-40-10-10, RSA, impatriate employees, scope (published 11 August 2025)
4. BOFiP, BOI-RSA-GEO-40-10-20, RSA, impatriate employees, exemption of remuneration (published 11 August 2025)
5. BOFiP, BOI-RSA-GEO-40-10-30-10, RSA, impatriate employees, exemption of passive income and capital gains (published 16 February 2023)
6. BOFiP, BOI-RSA-GEO-40-10-40, RSA, impatriate employees, consequences of the exemptions (published 21 June 2017)
7. Le régime des impatriés (impots.gouv.fr) (updated 8 April 2026)
8. Article 964 of the French General Tax Code, version in force (Légifrance)
9. BOFiP, BOI-PAT-IFI-10-20, PAT, IFI, taxable persons (published 8 June 2018)
10. Article 4 B of the French General Tax Code, version in force (Légifrance)
11. BOFiP, BOI-ANNX-000508, INT, list of countries with an exchange of information or assistance clause (published 8 October 2025)
12. BOFiP, BOI-RSA-GEO-40-20, RSA, impatriate employees, deduction of contributions to foreign social protection schemes (published 21 June 2017)
13. Article 83 of the French General Tax Code, 1° 0 bis and 2°-0 ter, version in force (Légifrance)
14. Article L767-2 of the French Social Security Code, pension affiliation exemption for employees called from abroad, version in force (Légifrance)
15. Article D767-1 of the French Social Security Code, exemption request and minimum contribution of €20,000 a year, version in force (Légifrance)
16. Article L136-6 of the French Social Security Code, CSG on investment income, I, 4° (income exempt under article 155 B, II) and I ter (persons affiliated in another EEA State or Switzerland), version in force (Légifrance)
17. Article 235 ter of the French General Tax Code, 7.5% solidarity levy, version in force (Légifrance)
18. Brochure pratique impôt sur le revenu 2026, chapter Divers, boxes 8SH and 8SI, note on persons affiliated to the British social security scheme (impots.gouv.fr, in French)