Contrary to what one might think, French taxation is full of very favourable tax gems. The impatriation regime means a 30% or even 50% tax exemption! This regime is aimed at employees and certain company executives who come from abroad to France to carry on their professional activity there (the “impatriates”) and who benefit from temporary income tax exemption measures.

Who Can Benefit from the Impatriation Regime?

Impatriation to France: the impatriation regime is aimed at persons who were domiciled for tax purposes outside France during the five calendar years preceding the year in which they take up their position in the company established in France that recruits them, AND who establish their tax domicile in France from the date on which they take up their position in France.

In practice, the two most typical cases are:

A former tax resident of France who left France to work abroad, and who returns to work in France more than 5 years later.

A person who has never been resident in France, very often of foreign nationality, and who comes to work in France for the first time.

The company employing the employee must, of course, be domiciled in France.

In principle, the employee must have been approached by the French company while abroad. It also appears that the employee may simply have responded to a French job offer while abroad: this was the ruling of the Paris Administrative Court of Appeal (CAA Paris, 10 June 2022, no. 20PA02279), and the tax authorities (administration fiscale) now expressly accept this in their doctrine (BOI-RSA-GEO-40-10-10, § 80, updated on 11 August 2025).

In summary: impatriates are staff members called from abroad to hold, for a limited period, a position in a company established in France. This transfer must take place either within the framework of the internal mobility of an international group with a subsidiary in France, or because these persons were recruited directly from abroad by a French company.

In principle, the scheme applies neither to persons who come to settle in France on their own initiative before looking for a job there, nor to self-employed workers (persons who applied from abroad for a job offer in France are, however, eligible).

Can Company Executives Also Benefit from the Impatriation Regime?

The preferential regime concerns not only employees in the strict sense but also

corporate officers treated as employees for tax purposes. They may be of

French or foreign nationality, and the nature of their duties is irrelevant.

More specifically, this covers:

– in sociétés anonymes (SA) and SAS, the chairman of the board of directors, the chief executive officer (directeur général), the deputy chief executive officer (directeur général délégué), the director temporarily delegated, the members of the management board (directoire), as well as any director or member of the supervisory board entrusted with special duties;

– in SARLs, minority or equal managers (gérants);

– in other companies or establishments liable to corporate income tax, executives subject to the tax regime applicable to employees.

The 6 Tax Advantages of the Impatriation Regime

1) Exemption of the additional remuneration directly linked to carrying on a professional activity in France (impatriation bonus)

This impatriation bonus, which is therefore exempt, may be assessed on an actual or a flat-rate basis.

Actual amount:

Impatriate employees and executives are exempt from tax on the components of their remuneration directly linked to their impatriation, that is, in practice, their impatriation bonus.

In this case, the bonus, which corresponds to the additional remuneration directly linked to the temporary exercise of the professional activity in France, is exempt from income tax for its actual amount.

Of course, only the additional remuneration directly linked to impatriation is eligible for exemption; the exemption does not extend to the other components of the remuneration provided for in the contract.

The actual amount of the bonus must appear separately in the employment contract or corporate office agreement of the persons concerned or, where applicable, in an amendment thereto, drawn up before taking up the position in France.

Where the actual amount of the impatriation bonus cannot be set in advance to the exact euro, it is sufficient for it to be determinable on the basis of the employment contract or the corporate office agreement. This means that if the amount of this impatriation bonus is not clearly set in the employment contract, it is accepted that it may simply be determinable.

CAUTION: I only very rarely come across the scenario of an impatriation bonus that is not clearly set in the employment contract but is simply determinable according to various parameters. In my view, this scenario should be avoided as far as possible, as it gives the tax authorities room to challenge it, by arguing that the impatriation bonus is not sufficiently determinable, that it is too vague, too uncertain to quantify, etc. So, upstream, at the time of negotiating the employment contract, avoid basing the impatriation bonus on factors that are inevitably always subjective, and favour a bonus with a clearly stated amount in the employment contract.

30% flat-rate bonus:

Impatriates may opt for the flat-rate assessment of their impatriation bonus, including where the amount of this bonus is specified in their employment contract or corporate office agreement.

If this option is chosen, the impatriation bonus is deemed to be equal to 30% of total net remuneration.

This is the scenario I come across most often. It is indeed a simple and effective solution, since the exemption is high, 30%, and not open to challenge or even to mere discussions with the tax authorities, which are rarely pleasant.

CAUTION: only the portion of salary exceeding the reference salary can be exempt!

The idea is that at least the portion of remuneration corresponding to comparable duties must remain taxable.

If the portion of remuneration subject to income tax is lower than the remuneration paid for comparable duties within the company or, failing that, in similar companies established in France, the difference must be taxed.

Focus on the key provisions relating to the reference salary:

The last paragraph of Article 155 B, I-1 of the French General Tax Code (Code général des impôts, CGI) makes the exemption of the impatriation bonus, or of the fraction of remuneration deemed to represent it, conditional on the impatriate’s remuneration subject to income tax being at least equal to that received for comparable duties within the same company or, failing that, in similar companies established in France.

The persons concerned must be able to prove this by any means. To this end, they may produce a certificate from their employer.
Example

An executive employed by an American company is seconded by that company to a French company to carry on their activity in France under a contract providing for annual net remuneration of €200,000, including an “impatriation bonus” of €60,000. In this case, the “additional salary linked to impatriation”, i.e. €60,000, is exempt:

– either in full if the impatriate demonstrates that the “reference remuneration” in France is equal to or lower than their net remuneration excluding the bonus (€140,000);

– or up to €50,000 if, for example, the comparable net salary in France is €150,000; indeed, the taxable salary in France cannot be lower than that paid for comparable duties by the French company or, failing that, by similar companies established in France.

If this option is chosen, the impatriation bonus is deemed to be equal to 30% of total net remuneration, meaning remuneration net of social security contributions and of the deductible portion of the generalised social contribution (contribution sociale généralisée, CSG), but before application of the 10% flat-rate deduction for professional expenses or, where applicable, the deduction of actual expenses. This remuneration includes all bonuses and allowances provided for in the contract, with the exception, in particular, of sums paid or gains realised under employee savings or employee share ownership schemes.

CLARIFICATIONS

Sums paid under collective employee profit-sharing schemes (intéressement) and gains from the exercise of share options (“stock options“) do not constitute remuneration for the purposes of the flat-rate assessment of the impatriation bonus. The same applies to benefits resulting from the allocation of free shares.

2) Exemption of the portion of remuneration relating to the activity carried on abroad

Take, for example, the case of an employee who makes business trips abroad in the course of their employment in France. Let us imagine that in 2024 they spent 30 days abroad and can, of course, prove it. In addition to the exemption of the impatriation bonus, part of their salary can be exempted. If they are an executive on an annual flat-rate agreement of 218 days per year, 30/218 of their salary can be exempted, in addition to the exemption of the impatriation bonus.

As an option, the exemption of this portion of remuneration linked to the activity abroad may be capped at 20% of taxable remuneration (instead of an overall cap of 50%), in addition to the exemption of the impatriation bonus; it is with the option for the overall cap that the total exemption can reach 50% of salary!

3) 50% exemption of foreign-source interest and dividends

To benefit from this 50% exemption, the country concerned must have concluded with France a tax treaty containing an administrative assistance clause aimed at combating tax fraud or evasion, which is very often the case. France has treaties with many countries, which very often contain this clause.

4) 50% exemption of certain foreign-source income from intellectual or industrial property

Here again, the country concerned must have concluded with France a tax treaty containing an administrative assistance clause aimed at combating tax fraud or evasion.

5) 50% exemption of capital gains on sales of shares abroad

6) Deduction from taxable income of contributions paid to supplementary pension and supplementary welfare schemes to which the impatriate was affiliated before arriving in France

Impatriates may deduct from their taxable remuneration, within certain limits:

– as for those who are not impatriates, all contributions paid to mandatory social security schemes in their country of origin (CGI art. 83, 1-0-bis), namely those paid in accordance with the rules applicable within the European Union as well as those paid pursuant to an international convention or agreement relating to the application of social security schemes

– a fraction of the contributions paid to supplementary pension and welfare schemes in their country of origin

How Long Does the Impatriation Exemption Apply?

Until 31 December of the eighth year.

So in fact for 8 to 9 years.

Example: taking up a position in France on 3 September 2024. The regime will apply to income for the years 2024, 2025, 2026, 2027, 2028, 2029, 2030, 2031 and 2032. So for more than 8 years. Here, for 8 years and 4 months.

When Does the Exemption Start?

The date of taking up the position means the date on which performance of the contract actually begins within the company located in France.

Impatriates can only benefit from the scheme for the years in respect of which they are domiciled in France for tax purposes.

If the residence condition in France is not met for a given year, the scheme does not apply for that year. However, failure to meet these conditions for one year does not call into question the benefit of the regime for previous or subsequent years, provided the conditions are met.

The duration of the exemption is always determined from the date of taking up the position.

Tolerance for the year of taking up the position:

A reasonable period is allowed between the impatriate taking up their position and the settling of their household in France: where the household settles in France in the calendar year in which the position is taken up or in the following year. In this case, the impatriate may benefit from the regime as soon as they take up their position, even though the domicile condition is not yet met.

Where the settling of the household in France is delayed beyond the end of the calendar year following that in which the position was taken up, the impatriate does not permanently lose the benefit of the regime, but may, provided all other conditions are met, claim its application from the year in which the condition of domicile in France is met.

Must the Impatriation Bonus Be Mentioned in the Employment Contract?

In principle yes, but it is not a blocking condition. Indeed, even if the impatriation bonus is not mentioned in the employment contract, it is always possible to opt for the 30% flat-rate exemption.

Impatriation Certificate Example

If you wish to benefit from the regime, your employer will need to issue you, each year, a reference salary certificate, often called an “Impatriation Certificate” (Attestation Impatriation).

There is no mandatory form prescribed by law. It is a document drawn up by the employer certifying that your salary does indeed exceed the reference salary, either by at least the amount of the impatriation bonus if it has been precisely quantified in the contract, or by at least the 30% flat-rate amount.

The reference salary is, broadly speaking, the average salary that a person with the same position as you, with the same experience as you, etc. would earn. It is therefore – roughly – the average salary for a position such as yours with a profile such as yours.

All of this is therefore quite subjective.

But it is for the employer – and not for you – to determine the reference remuneration using its own data.

The law tells us that the definition of the reference remuneration is a question of fact specific to each company, which must have information enabling it to justify the method used.
In order to make it possible to broaden the scope of comparisons, the law allows, even where there are comparable employees within the company, the remuneration paid for comparable duties in similar companies established in France to be used as a reference. The law specifies that while it requires the professional experience of the impatriate to be taken into account, the expression “comparable duties” even allows the use of internal or external comparables for duties that are not strictly identical.

The determination of the reference salary is therefore quite subjective and potentially complex.

However, from the employee’s point of view, the goal is simple: obtain the impatriation certificate from their employer. The calculation methods are not the employee’s concern and are not their responsibility, but that of their employer.

How to Calculate the Impatriation Bonus?

First case: bonus provided for in advance in the employment contract or corporate office agreement

In this case, the bonus, which corresponds to the additional remuneration, is exempt from income tax for its actual amount.

Of course, only the additional remuneration directly linked to impatriation is eligible for exemption; the exemption does not extend to the other components of the remuneration provided for in the contract.

The actual amount of the bonus must appear separately in the employment contract or corporate office agreement of the persons concerned or, where applicable, in an amendment thereto, drawn up before taking up the position in France.

CLARIFICATIONS

Where the actual amount of the “impatriation bonus” cannot be set in advance to the exact euro, either by its nature or in view of its calculation methods, it is sufficient for it to be determinable on the basis of the employment contract or the corporate office agreement; this would be the case of an “impatriation bonus” consisting of the provision of accommodation in France or set as a percentage of the impatriate’s base remuneration, which itself includes a variable component.

Second case: 30% flat-rate bonus

The bonus is equal to 30% of total net remuneration, at the employee’s option, provided the condition relating to the reference salary is met.

Example: An executive employed by a Canadian company is seconded by that company to a French company to carry on their activity in France under a contract providing for annual net remuneration of €300,000, including an “impatriation bonus” of €90,000.

The “additional salary linked to impatriation”, i.e. €90,000, is exempt:

either in full if the person concerned demonstrates that the “reference remuneration” in France is equal to or lower than the impatriate employee’s net remuneration excluding the bonus (€210,000);

or up to €70,000 if the comparable net salary in France is €230,000. Indeed, the taxable salary in France cannot be lower than that paid for comparable duties by the French company or, failing that, by similar companies established in France.

Cap where an activity is carried on both in France and abroad

Each year, impatriates have a choice to make regarding the application of the capping mechanism provided for by law; at their option:

– the fraction of remuneration exempted, in respect of both French and

foreign activities, is limited to 50% of total remuneration;

– or the fraction of remuneration exempted in respect of their activity abroad is

limited to 20% of taxable remuneration in respect of the activity carried on in France, net of the impatriation bonus.

Caution: impatriates must be able to prove the trips made in the direct and exclusive interest of their employer; such proof may be provided by any means (hotel bills, expense reports, boarding passes or other travel tickets, etc.).

In the Event of a Secondment, Does the Impatriation Regime Apply?

Yes, in the event of a secondment to a French subsidiary of the group.

Can You Change Companies and Continue to Benefit from the Regime? In Other Words, Can I Continue to Benefit from the Impatriation Regime If I Change Employer?

Yes, if you remain within the same group, and of course in a French subsidiary of the group (not a foreign one): moving from French subsidiary A to French subsidiary B of the group.

No in other cases: moving from the French company to a company outside the group.

And What Happens in the Event of a Change of Position? Can I Continue to Benefit from the Impatriation Regime?

Yes. The level of the reference salary will simply need to be reviewed to ensure that you still meet the conditions for the exemption.

What Is the Duration of the Impatriation Regime?

The exemption scheme applies only for the years during which the impatriate has their household or their principal place of residence in France and carries on a professional activity there as their main activity.

Failure to meet one of these cumulative conditions for a given year does not exclude the benefit of the regime for the other years, previous or subsequent, for which they are met.

Furthermore, in view of the professional or family constraints that may arise, the preferential regime applies, as a matter of tolerance, for the year in which the position in France is taken up, even if the household settles in France at the latest before the end of the calendar year following that in which the position was taken up.

For example, an employee taking up their position in France in January 2024 may claim the benefit of the preferential scheme immediately from 2024 if they establish their household in France no later than 31 December 2025.

Of course, in order to avoid any discussion with the tax authorities, I recommend settling in France ideally at the same time as taking up the position in France.

In tax matters, the clearest situations are indeed always the best, even more so when claiming the benefit of preferential regimes!

Nevertheless, even if you settle after 31 December 2025, you would not be permanently excluded from the benefit of this regime. But you could only claim it for income received from the year in which you settle. More specifically, if you take up your position in July 2024 but only settle in France from January 2026, you could only benefit from the impatriation tax regime for income received from 1 January 2026 until 31 December 2032. A year and a half of the exemption regime would therefore be lost (7 years of exemption instead of 8 and a half years).

But in any event, since 6 July 2016, the period of application has been set at a maximum until 31 December of the eighth calendar year following the taking up of the position in the host company. This period allows, for example, a person who took up their post in France on 1 January 2021 to benefit from the scheme until 31 December 2029, i.e. ultimately for nine years in total.

Of course, the preferential regime ceases to apply if the employee leaves the host company before that term, even if they remain tax resident in France.

However, the employee retains the tax advantage in the event of a change, on the one hand, of position within the host company and, on the other hand, of employer within the same group, whether or not to perform duties similar to the initial ones.

On the other hand, maintaining the scheme in the event of a change of position does not have the effect of extending its total duration, which continues to be assessed by reference to the date on which the original position was taken up.

What Are the Conditions for Obtaining the Impatriation Bonus?

To benefit from the exemption of the impatriation bonus, the employee taxpayer must remain taxed in France on an amount at least equivalent to the remuneration received in the same company by a non-impatriate employee.

In practice, the impatriate’s taxable salary must, after exemption of the impatriation bonus, remain at least equal to a reference remuneration corresponding to that paid for comparable duties within the company or, where applicable, in similar companies established in France. This condition may be assessed for the year of settling in alone if the amount of the bonus is fixed and the employee’s duties do not change during the impatriation period.

But to be exempt, the bonus must appear separately in the employment contract or corporate office agreement or, where applicable, in an amendment thereto, drawn up before taking up the position in France.

The option for the flat-rate assessment of the bonus has been extended to employees called by a company located in another State to work for another company established in France.

In any event, the exemption is capped at 50%, which is already enormous.

To benefit from this 50% exemption, in addition to receiving an impatriation bonus (actual or flat-rate), you must make numerous business trips abroad.

There are therefore two different flat-rate exemptions:

Either an option for an overall cap, which therefore cannot exceed 50% of total taxable remuneration. This implies that numerous business trips are made.

Or an option for a cap on the exemption of the remuneration linked to the activity carried on abroad only. In this second case, the amount of this portion of the exemption cannot exceed 20% of the taxable remuneration in respect of the activity carried on in France (net of the impatriation bonus). To this will of course also be added the exemption of the impatriation bonus itself.

How the Employer Must Declare the Impatriation Bonus: Impatriation Bonus and Payslip

The employer is required to declare separately the amount of salaries subject to income tax and those that are exempt: the impatriation bonus, where it has been precisely valued in the employment contract or an amendment. It must appear separately at the top of the payslip. At the top of the payslip there will therefore be a line generally entitled “impatriation bonus” (prime d’impatriation), “impatriation remuneration” or “impatriation”.

In this case, the employee has almost nothing left to do (except with regard to the exemption for trips abroad, for which they may, upon request, benefit from additional exemptions). When the employee looks at their payslip, they see two lines: one line corresponds to the basic salary, which is taxable, and another will be entitled impatriation bonus, which will be exempt from tax. At the end of the year, the employer will automatically send this information to the tax authorities: the amount of taxable salary and the amount of exempt salary; the return is therefore pre-filled as regards the taxable salary, and the employee will simply have to indicate, for information purposes, the amount of exempt salary.

However, if the employee wishes to opt for a flat-rate assessment of the bonus at 30%, they will have to make an express statement when filing their income tax return (write a message at the end of the return).

What Declarations Must the Employee Make?

For the impatriation bonus

The impatriate must report the exempt salaries and bonuses on line 1DY or 1EY of their supplementary return 2042 C; the purpose of this entry is not to subject the income in question to income tax, but to allow the reference tax income (revenu fiscal de référence) to be calculated. If opting for the flat-rate assessment of the impatriation bonus and/or the exemption for trips abroad, the impatriate must state this option in their income tax return, by making an express statement, i.e. a message at the end of the return.

For foreign dividends, interest, capital gains…

The taxpayer must attach to their overall income tax return (form no. 2042) and to their supplementary income tax return (form no. 2042 C) a declaration of income received abroad (form no. 2047); this must state separately the amount of income, including tax credits, subject to income tax, as well as the amount of income, including tax credits, exempt from income tax up to 50%, and the amount of creditable treaty tax credits, for their full amount. These items are then carried over to income tax return 2042.

What Exactly Is the Reference Salary?

The reference remuneration is, in principle, that paid for comparable duties in the calendar year in which the impatriate took up their position in France (where applicable, it is adjusted pro rata temporis). The comparison is made on the basis of net annual taxable remuneration. In practice, this means the remuneration reported by the employer in the declaration of wages and salaries, corresponding to the net amount of remuneration taxable under the rules applicable to wages and salaries, with the exception, in particular, of sums paid or gains realised under employee savings or employee share ownership schemes.

In addition, in order to take account of the practical difficulty of choosing relevant points of comparison, particularly where remuneration is highly individualised, the tax authorities have allowed several relaxation measures:

– even where duties comparable to those of the impatriate are performed within

the company, the “reference remuneration” may be that paid for performing such duties in similar companies established in France to an employee with comparable professional experience;

– this “reference remuneration” may be equal to the lowest of the remunerations

received by an employee with experience comparable to that of the impatriate and performing comparable duties within the company or a similar company established in France, during the year in question or the three previous years;

– where the amount of the impatriation bonus is determined and fixed (and not where the bonus is assessed on a flat-rate basis), subject to the application of indexation clauses based on the cost of living or on the index of the impatriate employee’s base remuneration, the tax authorities accept that the comparison of the employee’s remuneration with that received for comparable duties by another employee of the company or of a similar company may be assessed for the impatriate’s year of settling in alone. In this case, the cap condition is deemed to be met for the entire period if it is met for the year of settling in, provided that the duties of the person concerned do not change during the impatriation period.

If the portion of remuneration subject to income tax is lower than the remuneration paid for comparable duties within the company or, failing that, in similar companies established in France, the difference must be added back to taxable income.

Impatriation Bonus: Advantages for the Employer

The impatriation bonus offers tax advantages for employers. First of all, it enables them to attract qualified foreign talent by offering more attractive remuneration, since a significant part of that remuneration is exempt from tax.

Secondly, it facilitates the recruitment and integration of employees in France by offering them financial assistance for their relocation, which is also exempt.

In addition, the tax exemption of the impatriation bonus allows companies to achieve tax and social security savings. By benefiting from this exemption, the company can reduce the cost of the employee’s remuneration and thus increase its competitiveness on the international market.

Impatriation Bonus and Urssaf. Social Security Aspects of Impatriation.

Impatriates may also be exempt from pension contributions (basic and supplementary schemes) provided they can prove that a minimum contribution is paid elsewhere (for example to a foreign pension fund or retirement scheme). However, they do not acquire any rights during the exemption period.

They must be able to prove a minimum contribution of €20,000 per year to a foreign pension scheme, and must not have been affiliated, during the 5 calendar years preceding the year in which they took up their position, to a mandatory French old-age insurance scheme.

Impatriate employees and executives may also deduct contributions to foreign welfare and pension schemes.

Exemption from Real Estate Wealth Tax (IFI)

Impatriates benefiting from the special tax regime in France are also exempt from real estate wealth tax (impôt sur la fortune immobilière, IFI) on their real estate located outside France.

This exemption applies for a maximum period of five years from the year of arrival in France, and covers real estate held directly by the impatriate or through a company.

To be eligible for this exemption, the impatriate simply has to meet one condition: not having been domiciled in France for tax purposes during the five years preceding their taking up of the position.

The exemption lasts a maximum of 5 years.

Conclusion

The impatriation regime is very advantageous.

However, it is important to have a thorough command of all its conditions of application as well as how to declare it, which is rather complex technically.

As it is a preferential regime, the tax authorities may subsequently go looking for flaws in the taxpayer’s position.

It is therefore crucial, from the outset, to have a perfect command of all aspects of this regime, in order to protect yourself against any challenge by the tax authorities, which entails, in addition to the hassle of the audit itself, penalties.

The assistance of a tax lawyer with extensive experience of this regime therefore seems advisable. An experienced tax lawyer will be able to help you secure the application of the regime, and assist you effectively in the event of any subsequent questions from the tax authorities.

IMPORTANT: the information provided above is general. For an analysis of your specific situation, consult a tax lawyer.

TO FIND OUT MORE:

In a Bofip update of 10 April 2025, the tax authorities put out for public consultation – until 10 May 2025 – a Bofip (comments finally published on 11 August 2025) amending their previous comments on the impatriation regime in order to take account of the generalisation of the flat-rate assessment of the impatriation bonus.

On this occasion, they provide an interesting clarification regarding the scope of the impatriate regime.

The impatriation scheme provided for in Article 155 B of the CGI is aimed at employees or executives previously employed by a company established outside France and called upon to carry on an activity in a company established in France. The employees may previously have been employed by the company established in France. The tax authorities specify that this covers expatriates who return to carry on their activity in the company established in France that employed them before their departure abroad, provided that all the conditions for applying the scheme are met, in particular the condition relating to not having previously been domiciled in France. They also accept that the termination, suspension or modification of the employment contract concluded with that company established in France during or at the end of their period of expatriation does not call into question the benefit of the tax regime for impatriates (BOI-RSA-GEO-40-10-10 no. 40).

1. Impatriation bonus provided for in the employment contract or corporate office agreement. Where the actual amount of the impatriation bonus cannot be set in advance to the exact euro, the tax authorities accept that the bonus may be determined on the basis of objective criteria mentioned in the employment contract. In their previous comments, the tax authorities indicated that it was sufficient for the bonus to be determinable according to those same criteria.

Furthermore, with regard to the objective criteria cited, the tax authorities also allow the impatriation bonus to be determined as a percentage of the variable portion of remuneration alone (BOI-RSA-GEO-40-10-20 no. 70).

2. Option for the flat-rate assessment of the bonus. With regard to the limit on the exemption of the impatriation bonus by reference to the remuneration paid for comparable duties, there is a tolerance measure – not applicable where the bonus is assessed on a flat-rate basis – allowing the impatriate employee’s remuneration to be compared with that received for comparable duties by another employee of the company (or of a similar company) for the impatriate employee’s year of settling in alone. In the update of 10 April 2025, the tax authorities exclude from the benefit of this tolerance employees whose impatriation bonus is determined as a percentage of base remuneration. (aforementioned BOI no. 150).

Article 155 B, I-2 of the CGI indeed allows impatriates to be exempt from income tax on the portion of their remuneration relating to their activity carried on abroad while they are “impatriates” in France, if the stays abroad are made in the direct and exclusive interest of the company in which they carry on their activity. As a practical rule, and in the absence of information making it possible to identify it, the fraction of remuneration corresponding to the activity carried on abroad may be determined by taking into account the number of days of activity abroad in relation to the total number of days of actual activity in the year.

For the application of this practical rule, the tax authorities indicate that the remuneration to which the pro rata thus determined applies corresponds to the total net annual remuneration taxable under the rules for salaries under ordinary law conditions, less the amount of the impatriation bonus, capped where applicable by reference to the remuneration paid for comparable duties (BOI-RSA-GEO-40-10-20 no. 240).