Valley International / moving to france
The impatriate regime: what gets decided, and when
This is the only French tax advantage decided in a human resources office, months before anyone files a return, by people whose job it is not.
Article 155 B of the French tax code exempts from income tax part of the remuneration of people taking up duties in France, together with half of certain foreign-source investment income and gains, until 31 December of the eighth year following the start of those duties (eight years). It is open whatever your nationality. Its binding constraint is a single sentence: entitlement is assessed at the moment you take up duties, and it cannot be reconstructed later. Everything that follows on this page is a consequence of that sentence. The page France's impatriate regime: up to eight years of exemptions sets out the conditions themselves; this one is about what to do about them.
What has to be settled before you sign
The impatriation premium is the part of your package attributable to coming to work in France, and to be exempt it must be identifiable. In a well-prepared file it appears in the employment contract or in the mobility addendum, named, quantified or determinable by a stated formula. In an ordinary file it does not appear at all, because nobody thought to ask: the team drafting the contract is handling a hire, not a tax position, and will not raise it on your behalf.
A flat-rate valuation option exists for people recruited directly from abroad, and it rescues part of the badly drafted files. It does not rescue all of them, and it does not always produce the better outcome. Choosing it means accepting a default figure instead of a negotiated one.
The sentence to have written into the contract
The clause itself is not sophisticated: it states, before signature, what portion of the remuneration corresponds to coming to work in France, and the method by which that portion is determined. Five lines drafted at that moment are worth more, over eight years, than most of the wealth decisions that will follow.
The prior non-residence condition is a documentary exercise
The regime requires that you were not a French tax resident during the five calendar years preceding the start of your duties. The condition sounds simple and turns out to be evidential: it is proved with residence certificates, foreign tax assessments, leases, school registrations. The files that become difficult are those with a broken pattern, a year spent in France in the middle of a posting, a temporary assignment, a return for family reasons, and those are precisely the files where the problem is discovered too late because nobody kept the documents.
The second half of the regime, which almost nobody claims
The exemption on the premium is well known. The exemption of half of certain foreign-source investment income is not, and that is where the unclaimed value sits: dividends, interest and certain gains on foreign securities. Two conditions govern it. The payer must be established in a state bound to France by a convention containing an administrative assistance clause aimed at combating tax fraud and evasion, so it is the payer's location that counts rather than where the account happens to be held. And the exemption applies to income tax only: social levies remain due in full, which changes the arithmetic materially.
The consequence is one that arriving executives rarely draw. For eight years, a portfolio left with an eligible payer abroad is not treated like the same portfolio moved to France. Consolidating everything on arrival feels like tidying up, and it has a measurable cost.
Wealth tax, and the article everyone attributes wrongly
Someone who was not a French tax resident during the five calendar years before settling in France is liable to French wealth tax on French real estate only, until 31 December of the fifth year following the year of arrival. This limitation is useful and is constantly misattributed: it comes from article 964 of the French tax code, not from article 155 B. The distinction is practical rather than academic. The two regimes have different conditions and different durations, five years against eight years, so either can apply on its own.
What ends it
Changing employer ends the regime in most cases, intra-group mobility excepted. An impatriate considering a competing offer in France should therefore compare that offer not with their current gross salary but with their net position including the regime over the years still to run; someone in year three who moves gives up five years of it, which is frequently more than the increase on the table. The other ending is simply the term, on 31 December of the eighth year, and it deserves to be planned for, because net income changes in a single step.
Frequently asked questions
Can I claim the impatriate regime after I have started work?
No. That is what separates it from most tax reliefs. Entitlement is assessed when you take up duties in France, and the elements that support it, principally the identification of the impatriation premium and the evidence of prior non-residence, are assembled before or at the point of hiring. An amended return the following year cannot create a clause that is absent from the contract. This is why the subject belongs with the human resources team rather than with an accountant.
Does it apply to French nationals returning home?
Fully, and many of them do not know it. Article 155 B of the French tax code imposes no nationality condition: it covers employees and assimilated directors taking up duties in France who were not French tax residents during the required period. A French national returning after a long enough posting abroad is treated on exactly the same terms as a foreign executive being recruited. The word impatriation describes the movement towards France, not the origin of the person making it.
Should I move my foreign accounts to France when I arrive?
Not automatically, and the question is worth asking before doing it, because consolidating is easy and undoing it is not free. While the regime runs, half of certain foreign-source investment income is exempt from income tax, provided the payer is established in a state bound to France by an administrative assistance clause. Moving everything to France for the sake of simplicity forfeits that. Social levies, it should be said, remain due in full either way.
What happens if I change jobs during the eight years?
The regime generally ends, with intra-group mobility as the exception. The practical consequence is that a competing offer in France has to be compared against your net position including the regime for the years still to run, rather than against your gross salary. Someone in the third year who moves gives up five remaining years of relief, and that is frequently worth more than the increase being offered. The comparison should be made before negotiations conclude, not after.
Is the wealth tax limitation part of the impatriate regime?
No, though the error is common. That limitation comes from article 964 of the French tax code and benefits anyone who was not a French tax resident during the five calendar years preceding their arrival, whether or not they qualify under article 155 B. It runs until 31 December of the fifth year following the year of arrival, a different duration from the eight years of the impatriate regime. The two overlap in many cases, get confused in others, and each can apply without the other.
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, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.
Review my package before signing
Book a callWritten by Stéphane Molère, Président d'Éthique et Patrimoine — page last reviewed on 2026-08-30 — rules quoted are those in force at that date.