Who qualifies for France's impatriate tax regime, and what does it exempt?

Checked on 2026-10-25

The impatriate regime (CGI art. 155 B) covers employees and some directors hired from abroad by a business established in France. You must not have been French tax resident in the five calendar years before starting, and must then be resident. It exempts the impatriation bonus and pay for work abroad, until 31 December of the eighth following year.

Key facts

What	The tax administration’s doctrine says	Source
Legal basis	Article 155 B of the General Tax Code (CGI)	BOI-RSA-GEO-40-10-10, intro
Who	Employees, and directors taxed like employees, hired to work in a business established in France, either sent by a foreign company or recruited directly abroad	BOI-RSA-GEO-40-10-10, § 10–70
Who is excluded	People who came to work in France on their own initiative, or had already moved their home to France when recruited	BOI-RSA-GEO-40-10-10, § 80
Past residence	Not French tax resident in the 5 calendar years before the year you start	BOI-RSA-GEO-40-10-10, § 130–140
Residence during the regime	French tax resident each year: household or main stay in France, and main job in France	BOI-RSA-GEO-40-10-10, § 160–170
How long	Until 31 December of the 8th year after you start (start from 6 July 2016); 5th year for earlier starts	BOI-RSA-GEO-40-10, § 20
What’s exempt	The impatriation bonus and pay for work done abroad; also certain passive income and capital gains	BOI-RSA-GEO-40-10, § 10–20
Flat-rate bonus option	Bonus taken as 30% of total net pay	BOI-RSA-GEO-40-10-20, § 90, 102
Cap (your choice each year)	Total exempt pay ≤ 50% of total pay, or exempt pay for work abroad ≤ 20% of taxable pay	BOI-RSA-GEO-40-10-20, § 280
Approval	None needed; it applies automatically	BOI-RSA-GEO-40-10-20, § 380

Who qualifies

The tax administration’s published doctrine (BOFiP) says the regime covers employees, and directors taxed like employees, who come to work for a business established in France in one of two ways:

Sent by a foreign company linked to the French one, for example an intra-group transfer from a parent company abroad.
Recruited directly abroad by the French business. You may have been employed elsewhere, self-employed or not working (a student taking a first job, for example).

It does not cover people who came to France to work on their own initiative or had already moved their home to France when they were recruited. But the doctrine counts someone who applied from abroad to a job offer in France as recruited abroad. You must be able to show that your real home was still abroad when you were hired, for example with your contacts with the company, proof of address and travel records.

The residence conditions

You must not have been tax resident in France in the five calendar years before the year you start the job, whatever your nationality. From the start, you must be French tax resident in each year you use the regime, specifically by having your household or main stay in France and your main professional activity there. Being resident only because your economic interests are in France does not qualify. If you miss these conditions in one year, you lose the regime for that year only.

What is exempt, and for how long

Article 155 B exempts the impatriation bonus (the extra pay linked to working in France) and the part of your pay for work carried out abroad for the French employer. The doctrine says the regime also exempts certain passive income and capital gains. The exemptions run until 31 December of the eighth year after the year you start if you started on or after 6 July 2016; for earlier starts it was the fifth year. Changing jobs within the same company or group does not extend this period.

If your contract doesn’t set a bonus, you can opt to have it counted as 30% of your total net pay. This option is open to people recruited directly abroad, and, for those who started from 16 November 2018, also to people sent by a foreign company.

Each year you choose a cap: either all exempt pay is limited to 50% of total pay, or only the exemption for work abroad is limited to 20% of taxable pay. No prior approval is needed: you state your options on the annual income tax return (form 2042).

An impatriate sent abroad by a French employer under article 81 A CGI cannot combine both regimes and must choose one, irrevocably, by the first tax return (BOI-RSA-GEO-40-10-20, § 270).

Sources

Change history

2026-10-25: Page created

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