Valley International / moving to france
French impatriate regime: decisions to make before you start
In this context, impatriation means moving to France to take up a job after living abroad. France’s impatriate tax regime provides relief for eligible employees and certain company directors who meet the conditions in Article 155 B of the French Tax Code. Part of the regime may depend on terms agreed before employment begins, so review the contract, eligible income and reporting position before the first French tax return.
Article 155 B provides income-tax relief for qualifying employees and certain directors recruited from abroad. It can cover part of remuneration and some foreign-source income and gains, for up to eight years under the applicable conditions. This page explains the documents and decisions to prepare. French impatriate tax regime: eligibility and exemptions sets out the eligibility rules.
What has to be settled before you sign
If you use the actual impatriation premium, its amount or calculation needs to be identifiable under the applicable rules. Ask the employer to address it in the employment or mobility documents at the appropriate time. Keep the agreed terms with the evidence supporting the exemption.
A flat-rate valuation option may also be available, including for qualifying intra-group arrivals under the rules applying to recent starts. Compare it with the actual premium and the remuneration limits. An absent premium clause is therefore not, by itself, enough to conclude that every form of relief is lost.
The remuneration file
Bring together the employment terms, premium calculation, relevant pay comparison and the option used. These explain the amount claimed on the return. If work has already begun, review the actual facts and available options instead of assuming that no claim is possible.
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 the supporting documents were not retained.
Relief for qualifying foreign-source income
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. For dividends and interest, the payer must be established outside France, in a state bound to France by a convention containing an administrative assistance clause aimed at combating tax fraud and evasion.
For gains on the sale of securities, the test moves to the custodian of the securities, or to the company whose shares are sold where there is no custodian, which must be established outside France in a state or territory meeting the same convention condition. In both cases the income or the sale proceeds must be received abroad, even if the money is later transferred to an account in France. The exemption applies to income tax only: social levies remain due in full, which changes the arithmetic materially.
Before moving investments between providers, identify the income or gain, the paying or depositary institution relevant to the rule, and the country involved. The conditions are not identical for every category. Keeping an account abroad does not by itself make all its income eligible, and moving money should not be assessed solely by the account’s address.
The separate restriction on real-estate wealth tax
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 the impatriate regime
A change of job can affect eligibility. Continuation within the same company or group has specific rules; it does not restart the original period. Before accepting a new role, compare the resulting net remuneration and confirm whether relief continues. Also plan for the statutory end date, rather than treating the current net pay as permanent.
References cited
Frequently asked questions
Can I claim the impatriate regime after I have started work?
Yes, the relief is claimed through the tax return after income is received. Eligibility rests on the recruitment and residence facts, with documentation and options that have their own requirements. If you have already started, have those facts reviewed. A missing premium clause does not automatically rule out every available option.
Does it apply to French nationals returning home?
Fully. 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, but where the accounts sit matters for part of the impatriate exemption. For gains on securities, the exemption depends on the custodian being established outside France in a state or territory bound to France by such a convention, so transferring the securities to a French custodian ends it for later gains; for dividends and interest, it depends on the payer being established in such a state. In both cases the income or sale proceeds must be received abroad, even if the money is later moved to France. Social levies remain due in full either way, and foreign accounts kept open must be reported each year with your French return.
What happens if I change jobs during the eight years?
Check whether the new role meets the continuation rules, notably for a change within the same company or group. A qualifying move does not extend the original end date. Compare the net result before accepting an offer; do not assume either automatic continuation or a fixed number of remaining years.
Is the wealth tax limitation part of the impatriate regime?
No. 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, London, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.
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Book a callWritten by Stéphane Molère, President of Éthique et Patrimoine — page last reviewed on 2026-09-15 — reference date for the rules: 2026-09-07.