An employee who resides in France and is sent to work abroad by their employer in principle remains taxable in France on all their income, including their salary. However, article 81 A of the French General Tax Code provides, under conditions, for a full exemption of that salary or a partial exemption of bonuses linked to stays abroad.
This article presents these two exemptions, with worked examples. The tax treaty rules applicable to salaries are presented in the article living in France and working abroad: what taxes apply? and on the page on foreign salaries. Each situation deserves to be analysed, ideally with a lawyer.
In brief
- Article 81 A concerns employees who are tax-domiciled in France and sent abroad by an employer established in France or in another State of the European Union or the European Economic Area.
- Full exemption of the salary is in principle possible if the tax paid in the country of work reaches at least two thirds of the French tax, or if the assignment lasts more than 183 days over twelve months in certain sectors, or more than 120 days for commercial prospecting.
- Failing that, salary supplements linked to stays abroad may be exempt, under conditions and up to 40% of the remuneration.
- Exempt amounts are in principle declared (boxes 1AC et seq. of return no. 2042 C) and taken into account to calculate the rate applicable to other income.
- The conditions are strict and must in principle be capable of being proven: assignment orders, length of stays, tax paid abroad.
Contents
Who can benefit from article 81 A?
The exemption is in principle reserved for persons who meet all of the following conditions:
- being tax-domiciled in France within the meaning of article 4 B of the French General Tax Code;
- carrying on a salaried activity: corporate officers (executives) are in principle excluded, unless they perform separate technical functions abroad under an employment contract;
- being sent abroad by an employer established in France or in another State of the European Union or the European Economic Area that has concluded an administrative assistance agreement with France;
- carrying on the activity in a State other than France and other than the State where the employer is established.
Full exemption of the salary
The salary relating to the activity carried on abroad is in principle fully exempt from income tax in France in one of the following three cases:
| Case | Main condition | Details |
|---|---|---|
| Tax paid abroad | The salary has actually been subject, in the country of work, to an income tax at least equal to two thirds of the tax it would have borne in France | No sector or duration condition; for the comparison, the French tax is calculated on that salary alone, with the tax base and family quotient applicable in France, disregarding the household’s other income |
| Assignment of more than 183 days in certain sectors | Activity abroad of more than 183 days over a period of twelve consecutive months | Construction or assembly sites, installation and start-up of industrial facilities and related engineering; prospecting, research or extraction of natural resources; navigation on board merchant ships registered in the French International Register and, since 2026, in Wallis and Futuna |
| Commercial prospecting of more than 120 days | Commercial prospecting activity abroad of more than 120 days over a period of twelve consecutive months | The activity is devoted to developing exports or the company’s business abroad, through concrete actions (customer visits, meetings, trade fairs, etc.) |
The length of the assignment is in principle assessed from the first departure to the final return, including travel time. Weekly rest days, compensatory leave and paid leave relating to the activity abroad, as well as leave for work accidents or illness resulting from that activity, are, as a general rule, treated as activity abroad, even when taken in France. Where the assignment straddles two calendar years, the twelve-month period is assessed on a rolling basis.
In the sectors concerned, the exemption may also benefit administrative staff accompanying the technical teams, as well as employees of subcontractors who perform, on the same site, functions directly connected with the eligible activity.
Example: an assignment on a construction site
Marc, an engineer with a French company, lives in France with his family. He is sent from March to October 2026, i.e. about 240 days including travel and rest days, to the construction site of a factory in an African country. As the assignment exceeds 183 days over twelve months in an eligible sector, the salary relating to this assignment may in principle be exempt in France, whatever the level of tax paid in the country of work. This salary is in principle still declared and taken into account to calculate the rate applicable to his other income.
Partial exemption of salary supplements
Where the conditions for full exemption are not met, salary supplements paid in respect of stays abroad (salary increases, bonuses or allowances linked to distance or working conditions) may in principle be exempt, under the same conditions as to domicile and the employer’s establishment, if:
- the stays are made in the direct and exclusive interest of the employer;
- each stay lasts at least 24 hours in another State;
- the amount of the supplements is determined before the stays, in the employment contract, an amendment or the assignment order, according to the number, length and place of the stays;
- the exempt amount does not exceed 40% of the annual remuneration, excluding supplements.
Example: short assignments
Sophie is an employee of a French company and lives in France. In 2026, she makes several business trips abroad, totalling 80 days, which is, in principle, not enough for full exemption. Her contract provides for a bonus of €3,500 per day of assignment abroad. Her annual remuneration excluding bonuses is €750,000.
| Step | Calculation | Amount |
|---|---|---|
| Assignment bonuses paid | 80 days × €3,500 | €280,000 |
| Exemption ceiling | 40% × €750,000 | €300,000 |
| Exempt bonuses | €280,000, below the ceiling | €280,000 |
| Taxable salary | €750,000 (before the 10% deduction for professional expenses, which is capped) | €750,000 |
Effective rate, declaration and supporting documents
Amounts exempt under article 81 A are not taxed, but they are in principle taken into account to calculate the tax rate applicable to the household’s other income (effective rate rule) and to determine the reference tax income. They are in principle declared in boxes 1AC et seq. of supplementary return no. 2042 C; the employer also reports them in its social security returns.
The exemption is not automatic: it is in principle for the employee to be able to prove that the conditions are met (assignment orders, dates and places of stays, nature of the activity, tax actually paid abroad). These documents may be requested during a tax audit.
How it fits with tax treaties
Article 81 A is a rule of French domestic law. Where the tax treaty concluded with the country of work allocates the taxation of the salary to that country, France may already, depending on the case, avoid double taxation through a tax credit or an exemption with the effective rate rule, which only an analysis of the situation by a lawyer can confirm or rule out. Article 81 A is therefore mainly useful where the treaty leaves taxation to France, for example for a short assignment, or where there is no treaty.
The conditions of article 81 A are precise and their application depends on the facts of each assignment. An analysis with a lawyer, preferably before departure, generally makes it possible to check which exemption may apply and which documents to keep.
FAQ
Can executives benefit from article 81 A?
In principle not in respect of their corporate office. An executive who performs separate technical functions abroad under a genuine employment contract may, however, depending on the case, benefit from it for the remuneration of those functions.
How are the 183 or 120 days counted?
The length is in principle assessed from the first departure to the final return, including travel time; rest days, paid leave and sick leave linked to the assignment are treated as activity abroad, even if taken in France. The period of twelve consecutive months may straddle two calendar years.
Do days teleworking from France count?
In principle no: only days of activity abroad, and days treated as such, are taken into account. The salary relating to work performed in France is not, as a general rule, covered by the exemption.
Are expatriation bonuses always exempt?
No. They are in principle only exempt if the conditions for partial exemption are met: stays of at least 24 hours in the employer’s interest, an amount set in advance and a ceiling of 40% of remuneration excluding supplements.
Is the exemption automatic?
No. It requires all the conditions to be met and capable of being proven. During an audit, the tax authorities may request the assignment orders, the dates and places of the stays or proof of the tax paid abroad.
Must exempt salaries be declared?
In principle yes, in boxes 1AC et seq. of return no. 2042 C. They are not taxed, but they are, as a general rule, used to calculate the rate applicable to other income and the reference tax income.
