The French Impatriate Regime (Article 155 B CGI): Who Qualifies and What It Saves

France's impatriate regime (article 155 B CGI) exempts from income tax an impatriation premium - either the real premium in your contract or, on election, a deemed premium of 30% of eligible net pay, subject to a reference-pay test and caps - plus pay for work abroad and half of certain foreign investment income. It lasts until 31 December of the eighth year after you start work in France.

Known in French as the régime des impatriés, it can significantly reduce income tax for international employees moving to France. No prior approval is needed, but you still have to claim the exemptions and options correctly - and payroll does not always apply them.

In short

• Who: employees and executives recruited directly from abroad by a French company, or sent to France by a foreign group, who were not French tax-resident in the five previous calendar years.
• What is exempt: the impatriation premium - either the real supplement linked to the move, set in the contract before you start (in cash or in kind, such as housing), or, on option, a flat 30% of total net pay - plus the share of pay for workdays abroad in your employer's direct and exclusive interest, within caps.
• Investment income: 50% exemption on foreign dividends, interest, royalties and capital gains on securities, under conditions. Social levies remain due.
• For how long: until 31 December of the eighth calendar year after the year you take up the post.
• What it is not: it does not reduce social security contributions on your salary, and it does not apply to the self-employed.
• If you missed it: past years can often be claimed back within the ordinary claim deadline - each 31 December, the oldest year usually drops out.

1. Who qualifies for the impatriate regime?

The regime covers employees and executives taxed like employees (for example the chairman or managing director of an SAS or SA, or a minority or equal manager of a SARL) who are "called from abroad" to work for a business established in France. Public bodies are not "businesses" for this purpose: the Conseil d'État confirmed that doctors recruited by public hospitals are excluded (CE, 20 May 2015, no. 388480). It is not open to the self-employed: the former regime for non-salaried impatriates only covered people who settled in France before 2012.

There are two routes in.

You must have been genuinely recruited from abroad. For direct recruitment, this means showing that you had not already moved your real home to France when you were recruited - so the timeline of the recruitment and of the move matters. The Paris administrative court of appeal held that applying from abroad to a job advertised in France, or actively looking for a job in France from abroad, does not exclude the regime - in that case the employee still lived in London when the negotiations started (CAA Paris, 10 June 2022, no. 20PA02279). The same court refused the regime to an employee of a French company who was already working mainly in France (CAA Paris, 6 March 2025, no. 23PA02864).

The five-year rule

You must not have been French tax-resident in any of the five calendar years before the year you take up the post - whatever your nationality. A French citizen returning after five full years abroad can qualify.

Tax residence during the regime

For each year of the regime, you must be French tax-resident under two specific tests of article 4 B CGI: your home or main place of stay is in France, and your main professional activity is in France. Being resident only because your economic interests are in France is not enough. If a tax treaty makes you non-resident in France, the regime does not apply for that year.

A year in which you fail these tests is lost on its own, without affecting other years - but it does not extend the overall period.

If your family joins you later (end of a trial period, a spouse's job, the school year), the administration is flexible: if the household settles in France during the year you start or the following year, the salary exemption applies from your first day of work. This tolerance does not cover investment income. If the family arrives even later, the regime starts from the year you meet the residence tests.

Changing job

Here "the same group" means companies linked by control within the meaning of article L. 233-3 of the Commercial Code - a commercial relationship is not enough. The regime is also kept when a foreign company ends your secondment and you sign a local contract with the French company where you already work. In every case, the end date stays fixed by your first start date in France.

2. What part of your salary is exempt?

The regime has two salary exemptions, and they add up: the impatriation premium and the pay for days worked abroad.

The impatriation premium: real amount or 30% flat rate

For intra-group transfers that started up to 15 November 2018, the flat rate was not available. The 2019 Finance Act opened it to them, and the administration's guidance was updated in August 2025.

The 30% is calculated on your total net pay, including taxable bonuses and allowances in the contract. Gains from employee savings and share plans are left out: stock-option exercise gains, qualifying free shares, profit-sharing (intéressement, participation). Do not confuse these with a later capital gain when you sell the shares - that gain may qualify for the investment-income exemption under separate conditions (section 3).

If you have a real premium instead, it must appear separately in the contract or an amendment signed before you start work in France.

The reference-pay test

Whatever option you pick, the pay that remains taxable must be at least equal to what someone in a similar role at the same company - or at a similar French company - would earn. If it is lower, the premium is reduced to restore that level.

The comparison is made function by function, on net annual taxable pay. It has to be documented, usually with the employer's help, and it should be checked every year. In practice, the evidence of reference pay is the most frequent source of disputes with the tax administration.

Pay for days worked abroad

The part of your pay for work carried out outside France, on trips made in the direct and exclusive interest of your employer (trips of less than 24 hours count too), is also exempt. The amount can be set in the contract or calculated on the basis of the trips actually made, and the administration can challenge an amount clearly out of proportion with them. This part of the exemption stands or falls on the evidence of each trip.

Note that the reference-pay test limits the premium exemption only. It does not prevent the foreign-days exemption from reducing your taxable pay further.

The caps

The two exemptions together cannot exceed a cap. You choose each year which cap applies:

With the 30% flat rate, the separate 20% cap can never beat the 50% overall cap: at most 30% + 20% of the remaining 70%, i.e. 44% in total. The separate cap is mainly of interest when you have a large real premium.

Things that change the result

• No combination with the expatriate exemption (article 81 A). The law states that impatriates cannot rely on article 81 A. The administration's guidance describes it as an irrevocable choice between the foreign-days exemption and the 81 A supplements, made in the first year's return. Either way, you cannot claim both.
• Social contributions are a separate question. Article 155 B does not itself reduce social security contributions. Where French contributions apply, the premium is not excluded from their base just because it is exempt from income tax.
• Withholding tax. The exempt premium (or 30% under the flat rate) is left out of withholding at source (prélèvement à la source), but the pay subject to withholding cannot fall below the reference pay. If your employer does not apply it, you recover the difference in your annual tax return.
• The exempt amount is still reported. It is added back to your reference tax income (revenu fiscal de référence), which is used for many thresholds - see section 4.
• Relocation costs. Reimbursed relocation expenses used for their purpose (move, temporary housing, agency fees, French lessons, school fees for a foreign-language curriculum, one trip home a year) are exempt under the ordinary rules for business expenses, outside the caps. Housing allowances and tax equalisation, on the other hand, count as part of the impatriation premium.
• A saving for the employer too. For people who started on or after 6 July 2016, the impatriation premium (or 30% of pay under the flat rate) - not the foreign-days pay - is also excluded from the payroll tax (taxe sur les salaires) that some employers pay, under the same residence and time conditions.

3. Your foreign investment income: 50% exempt

The regime also covers part of your passive income - if it is paid from abroad. Half of it is exempt from income tax.

What counts is who pays, not the nationality of the company. Dividends from French shares held on a brokerage account abroad can qualify, while foreign shares held with a French bank in France do not. Only income received after you become French-resident is covered.

It is personal. Only the impatriate's own income qualifies - not a spouse's, even in the same tax household.

It is not a general exemption of foreign income. Rental income, gains on real estate and other categories not listed above are taxed normally.

The payer's country must have a tax treaty with France that allows the exchange of tax information. The administration's guidance also accepts countries that have only a tax information exchange agreement.

You do not need to benefit from the salary exemption to claim this one. In 2020 the Conseil d'État struck down the administration's position that the 50% exemption required an exempt impatriation premium (CE, 21 October 2020, no. 442799). The administration has since accepted that it applies even in a year when the caps cancel your premium, or when you receive no qualifying pay. You must still meet the personal conditions of the regime: this is not an exemption for every newcomer to France.

How it combines with the rest of the tax

• Dividends, interest and securities gains under the flat-rate rules: the flat-rate income tax (the "flat tax") applies to the half that remains taxable. Copyright, patent and life-insurance income follow their own rules.
• Capital losses count only for half, in the same proportion.
• Not covered: deemed distributions, crypto-assets (the administration confirmed in December 2025 that they are not "securities" for this purpose), and carried-interest gains taxed under the special regime for executives who moved to France between July 2018 and 2022 - the two benefits cannot be combined.
• Social charges are due on 100% of this income. The exemption does not reduce them.
• Foreign withholding tax. The exemption does not simply halve your total worldwide tax: the treaty tax credit follows its own rules.
• Reporting. The exemption is not automatic. It has to be reported every year, and depending on the income an advance payment during the year may also be required. Foreign bank accounts and life-insurance contracts must still be declared every year.

4. How long it lasts - and what it does to other taxes

When the regime ends

The regime applies until 31 December of the eighth year after the year you took up your post in France - for anyone who started on or after 6 July 2016. Start in March 2026, and the last year covered is 2034. The same period applies to the 50% exemption on investment income.

Wealth tax on real estate (IFI): a separate five-year rule

French wealth tax now only taxes real estate, when net taxable real-estate wealth exceeds €1.3 million (including real-estate value held through companies). A separate rule (article 964 CGI) protects new arrivals: if you were not French tax-resident in the previous five calendar years, only your real estate in France is taxed - not your property abroad - until 31 December of the fifth year after you became resident.

This rule is often mixed up with the impatriate regime, but it is different:

High-income taxes

• Reference tax income. Exempt income is added back to your reference tax income (revenu fiscal de référence), which is used for many thresholds.
• Exceptional contribution on high incomes (CEHR). It is based on reference tax income, so exempt amounts are included.
• Differential contribution on high incomes (CDHR, introduced for 2025 income and extended by the 2026 Finance Act). The law specifically excludes income exempt under article 155 B from its calculation.

Pension contributions

The regime gives no relief from social security contributions. A separate rule in the Social Security Code (articles L. 767-2 and D. 767-1) allows employees called from abroad to opt out of the French basic and supplementary pension schemes, if:

• they were not affiliated to a French pension scheme in the five calendar years before the year they start;
• at least €20,000 a year is paid by the employer and the employee into qualifying French or foreign retirement products;
• the employer applies to URSSAF, with the employee's agreement, normally before French affiliation.

The opt-out is granted only once per employee, for three years, renewable once. It covers pension only: health, family and CSG/CRDS remain due, and no French pension rights build up during that time. If the conditions are not met, the employer owes a penalty of 1.5 times the contributions avoided.

Which country's social security applies is a separate question from the tax regime: under EU rules or a bilateral agreement, you may remain covered by your home system for a time.

5. A worked example

Anna lived in London and was recruited directly by a Paris company. She starts work in France in March 2026. Her contract has no impatriation premium, so she uses the 30% flat rate. Figures below are for a full year, 2027.

About €54,500 of salary is removed from the taxable base, before the 10% professional expenses deduction, and the regime can run until the end of 2034. The actual effect depends on the whole household's tax, calculated with and without the regime.

If Anna also keeps a brokerage account in London that pays her €10,000 of gross dividends a year, then - assuming the dividends qualify, and before any foreign withholding tax and treaty-credit adjustments - only €5,000 is subject to French income tax. Social charges remain due on the full €10,000.

This example is simplified. The result for a given person depends on the household, other income and the exact contract.

6. How to claim it - including for past years

No prior approval is needed. The regime applies by law if you meet the conditions, but the exemptions and options still have to be claimed correctly at three levels: the employment contract (a real premium must be written in before you start), payroll (the employer reports the exempt amounts and leaves them out of withholding tax - which is not always done correctly) and the annual tax return, where the options chosen must be stated.

If you want certainty before you sign - for example on your residence when recruited - you can ask the tax administration for a formal ruling under the general procedure (rescrit, article L. 80 B, 1° of the tax procedure code). There is no special ruling procedure for impatriates. Silence does not amount to approval; an express favourable ruling can protect you if your request fully and accurately describes the facts.

You did not claim it? You can still go back

Many impatriates find out about the regime one or two years late. Income tax can be corrected by a claim (réclamation) filed until 31 December of the second year after the tax was assessed. In the usual case, where the tax is assessed the year after the income: for 2024 income, the deadline is 31 December 2027; for 2023 income, 31 December 2026.

Late claims can succeed - the 2022 Paris case above was a claim made after assessment. But the burden of proof is then on the taxpayer, and a claim was rejected in Bordeaux because the reference pay could not be proven (CAA Bordeaux, 24 November 2020, no. 18BX04507). The regime still ends at the same date: claiming late does not extend it.

7. Common traps

• Moving before recruitment. If you settle in France first and look for a job afterwards, you are not "called from abroad".
• An intra-group move dressed up as a new hire. Resigning from the London entity and signing a new contract with the Paris entity of the same group is still a group mobility. For start dates up to 15 November 2018, this excluded the 30% flat rate; today both routes give access to it, but the label still affects how the file is documented.
• A bonus is not a premium. A performance bonus or retention bonus is not a real impatriation premium just because it was paid after the move. That does not necessarily exclude it from the pay used to calculate the 30% flat rate.
• No proof of reference pay. This is a recurring source of disputes. A vague employer letter is not enough.
• No travel log. Days abroad without supporting evidence are hard to defend.
• Payroll ignores the regime. Your employer's failure to apply it does not take away your right to it - but you then have to claim it back yourself.
• Assuming social charges are reduced. They are not - neither on salary nor on investment income.

8. What the courts have decided

9. When advice is useful

The regime applies by law, but most disputes turn on facts fixed long before the first tax return: how and when the recruitment took place, the wording of the contract, and the evidence of reference pay. That is why the questions are best looked at before signing or moving, and in particular when:

• you moved to France before the job offer was finalised;
• you are a founder, or an executive of a company you set up yourself;
• your employer is reluctant to certify the reference pay;
• you want to claim the regime for past years;
• you change employer outside the group;
• you hold investments abroad and want the 50% exemption applied correctly;
• you split your time with another country and a tax treaty may apply.

My work on the regime ranges from reviewing an offer or contract before signature to preparing claims for past years.

FAQ

Can I benefit if I am French?

Yes. Nationality does not matter. You must not have been French tax-resident in the five previous calendar years.

Does the regime apply to freelancers or company founders?

Not to the self-employed. It does cover executives taxed like employees: the chairman, CEO or deputy CEO of an SA or SAS, and a minority or equal manager (gérant) of a SARL. A majority manager of a SARL is not covered. A founder who creates their own French company and appoints themselves is in a very uncertain position - this needs case-by-case analysis.

Do I need a fixed-term contract?

Not according to the tax administration, which expressly accepts both fixed-term and indefinite-term employment. The law itself still refers to a job "for a limited period", and one appeal court refused the regime to a manager on a permanent contract (CAA Versailles, 21 November 2017, no. 16VE01414). The administration's guidance protects you most clearly when you have relied on it from the start.

I left France four years ago. Can I wait out the five years?

The test is five full calendar years before the year you start work in France. If you were French tax-resident at any point in any of those five calendar years, you do not qualify - the government confirmed this in a ministerial answer in December 2025. Residence under a tax treaty counts too.

Does it count towards the cap on tax breaks?

No. The government has confirmed that the regime is outside the overall cap on certain tax advantages (article 200-0 A CGI).

What happens if I leave France before the regime ends?

The conditions are checked year by year. Leaving France does not, by itself, trigger repayment of exemptions correctly claimed for earlier years. For the year you leave, your residence that year has to be analysed.

Is the 50% investment-income exemption automatic?

No. It has to be claimed in the tax return each year.

Can I combine it with the expatriate exemption (article 81 A)?

No. The law excludes it; the administration treats it as an irrevocable choice made in your first return.

Related reading

• Impatriate regime - how I work on these questions
• France's 20% tax on homes, yachts and cars held through companies
• Cross-border tax

If you are about to sign, or think you may have missed past years, a review of your situation is the first step. Book a consultation.

This article is general information under French law as at 25 October 2026. It is not legal or tax advice for your situation.