French impatriate tax regime: eligibility and exemptions

Employees recruited from abroad or transferred to France may qualify for the impatriate regime if its conditions are met. Eligibility, employment terms and each category of exempt income must be documented separately.

Article 155 B provides income-tax relief for qualifying employees and certain directors arriving from abroad. Recruitment, previous non-residence and the role in France determine eligibility, alongside the continuing conditions. Nationality alone is not decisive. The relief is claimed through the return, with supporting evidence for each category of exempt income.

The impatriate regime, from eligibility to its limits

01 · Eligibility
Who qualifies for the impatriate regime
Employees and certain directors recruited from abroad or transferred to a company in France, who were not French tax residents during the five calendar years before taking up the role; nationality is irrelevant.
02 · Exemptions
What the impatriate regime exempts
The impatriation premium is exempt within statutory ceilings, and certain foreign-source investment income and gains are partly exempt; article 964 separately limits wealth tax (IFI) to your French real estate.
03 · Duration
How long the regime runs, and the separate wealth-tax limit
The regime can run until 31 December of the eighth year following the start of duties (eight years), while its conditions remain met. The wealth-tax limit is a separate provision, article 964, and ends on 31 December of the fifth year following the year you become French-resident.
04 · Limits
Who the regime does not cover
Moving to France does not by itself open the regime: someone arriving only to retire, or working independently without an eligible employment or director role, cannot infer eligibility from the move.

Who qualifies

The regime (article 155 B of the French tax code) applies to employees and assimilated directors taking up duties in France (direct hire from abroad or intra-group transfer), who were not French tax residents during the five calendar years before taking up the role. Nationality is irrelevant: it works the same way for a British executive joining a Paris firm as for a French national returning with a contract.

What is exempt, and for how long each relief runs

The impatriation premium (the part of your package linked to coming to France), exempt at its real amount or under a flat option, within statutory ceilings;
A partial exemption for certain foreign-source investment income and gains, subject to the conditions applying to each category.
and, under a separate provision (Article 964 of the French tax code, not Article 155 B, and open to anyone who was not a French tax resident in the five calendar years before settling), only your French real estate falls within the scope of wealth tax (IFI) until 31 December of the fifth year following the year you become French-resident; foreign property stays outside it.

For qualifying starts, the regime can run until 31 December of the eighth year following the start of duties (eight years), while its conditions remain met. Compare the actual-premium and flat-rate options where available. A change of role or employer needs a continuation review and does not restart the original period.

Ceilings, options and edge cases (directors, split contracts, combining with treaty rules) require a precise reading of the law and administrative doctrine at the date you take up your role. The firm prepares the figures before you sign.

Who the regime does not cover

The employment-based route described here is not obtained simply by moving to France. A person arriving solely to retire, or working independently without an eligible employment or director role, cannot infer eligibility from the move. Recruitment timing needs to be assessed from the real facts. Other specific statutory provisions, if relevant, require a separate review.

French impatriate regime: decisions to make before you start explains how to prepare the remuneration documents and review foreign-source income. If work has already begun, examine the existing facts and options before assuming that no claim can be made.

References cited

CGI, art. 155 B · CGI, art. 964

Frequently asked questions

Does the impatriate regime apply if I negotiate my own move?

Arranging your own move does not alone decide the answer. Establish when and how you were recruited, where you were resident and whether the other conditions are met. Moving first and only then seeking a job can lead to a different result from recruitment while abroad.

How long does the French impatriate regime last?

Until 31 December of the eighth year following the start of your duties in France, as long as the conditions remain met.

Is my foreign investment income 50% exempt?

Partly, and for income tax only: 50% of foreign-source investment income is exempt: dividends and interest whose payer is established outside France, in a state bound to France by a convention with an administrative assistance clause, and gains on securities whose custodian, or the company itself where there is no custodian, is established outside France in a state or territory meeting the same convention condition. The income or sale proceeds must be received abroad, even if later transferred to France; other income is taxed normally, and social levies remain due in full on all of it.

Does the impatriate regime apply to self-employed professionals?

Independent activity alone does not qualify for the employment-based route described on this page. Establish the exact role and whether any separate statutory provision is relevant. Do not treat a residence permit or an overseas client as proof of eligibility.

Can I combine the impatriate regime with relief under my home country’s tax treaty?

The treaty and domestic exemption must be read together for the income concerned. A French exemption does not automatically prevent another country from taxing the same income, especially where citizenship or other special rules apply. Calculate the interaction rather than adding the reliefs mechanically.

ÉTHIQUE ET PATRIMOINE, a French simplified joint-stock company (SAS), registered office at 41 rue Saint-Ferdinand, 75017 Paris, France, Paris Trade Register no. 803 414 796, VAT no. FR 40 803 414 796, registered with ORIAS under number no. 24001817 (www.orias.fr) — Financial investment adviser (CIF) no. 18002418, member of ANACOFI-CIF, a professional association approved by the Autorité des marchés financiers, and Anacofi-Courtage for its brokerage activity. Presence: Paris, Montpellier, London, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.

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