The Impatriate Regime (Article 155 B): A Practical Guide

French taxation includes some particularly favourable regimes. The impatriate regime can thus make it possible, subject to conditions, to exempt a significant part of remuneration from income tax: 30%, and up to 50% in some cases. This regime is aimed at employees and certain company executives who come to France from abroad to carry out their professional activity there (“impatriates”) and who benefit from temporary income tax exemption measures.

Who Can Benefit from the Impatriation Regime?

Impatriation to France: the impatriation regime is in principle 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 in principle be established 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 in principle 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?

The preferential regime in principle 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 Impatriation Bonus (Extra Pay Linked to Working in France)

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

Actual Amount

Impatriate employees and executives are, as a general rule, 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 in principle 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 in principle 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 bonus cannot be set in advance to the euro, the tax authorities accept, since the update of their guidelines of 11 August 2025, that it be determined on the basis of objective criteria set out in the employment contract or corporate mandate, for example a percentage of base pay or of its variable part alone. Previously, they indicated that it was sufficient for the bonus to be determinable from the contract.

In practice, it is rare for an impatriation bonus not to be clearly fixed in the employment contract but only determinable on the basis of various parameters. This situation may give the tax authorities room to challenge it, as they could take the view that the impatriation bonus is not sufficiently determinable. Depending on the case, it may therefore be preferable, when the employment contract is being negotiated, not to base the impatriation bonus on inherently subjective elements and to favour a clearly quantified bonus, ideally after taking a lawyer’s advice.

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 most common situation in practice: the solution is simple, and the 30% exemption is significant. It is not, however, immune from any discussion with the tax authorities, in particular as regards the reference remuneration condition.

Only the part of the remuneration exceeding the reference salary can in principle be exempt.

The idea is that at least the part of the remuneration corresponding to similar duties remains taxed.

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 in principle 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 €1,000,000, including an "impatriation bonus" of €300,000. In this case, the "additional salary linked to impatriation", i.e. €300,000, would be 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 (€700,000);
• or up to €250,000 if, for example, the comparable net salary in France is €750,000; 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 in principle 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, in principle, 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 Pay Relating to Work Abroad

For example, an employee makes business trips abroad as part of their job in France and has spent 30 days abroad during the year, which they are able to prove. Part of their salary may then be exempt, in addition to the impatriation bonus: if they are a manager on a 218-day annual working-days package, the exempt fraction may, under the practical rule accepted by the tax authorities, be 30/218 of their remuneration excluding the impatriation bonus, 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

The 50% exemption in principle requires the income to come from a State that has concluded with France a tax treaty containing an administrative assistance clause to combat tax fraud and evasion, which is common: France has concluded treaties with many countries, which very often contain such a clause.

4) 50% Exemption of Certain Foreign Intellectual Property Income

Here again, this exemption in principle requires the income to come from a State that has concluded with France a tax treaty containing an administrative assistance clause to combat tax fraud and evasion.

5) 50% Exemption of Capital Gains on Shares Sold Abroad

Capital gains on the sale of securities held abroad may, in the same way, be 50% exempt, under comparable conditions relating in particular to the State in which the securities are held; the other half in principle remains taxable.

6) Deduction of Contributions to Foreign Pension and Welfare Schemes

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

The 50% exemption, in principle even without an exempt bonus

• the 50% exemption on passive income and capital gains applies in particular where the impatriate bonus is not exempt because of the normal remuneration limit provided for in the last paragraph of 1 of I of Article 155 B;
• even where, during one of the years in which the special tax regime applies, the impatriate receives no remuneration element linked to their professional activity covered by I, they may nevertheless benefit, for that year, from the 50% exemption on their eligible passive income and capital gains.

This solution results from a 2020 Conseil d’État decision (CE, 21 October 2020, No. 442799), which put an end to the previous uncertainty whereby the benefit of II seemed to be conditional on actually benefiting from I.

How Long Does the Exemption Apply?

In principle 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 in principle 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 in principle 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 in principle 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.

For example, an employee who takes up their position in France in July 2024 and establishes their home there by 31 December 2025 at the latest may in principle benefit from the regime from 2024. If they only move in January 2026, the regime in principle only applies to income received from 1 January 2026, still until 31 December 2032: the exemption period is then reduced by about a year and a half. Moving to France at the same time as taking up the position is generally the simplest situation.

Must the Impatriation Bonus Appear 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 may, depending on the case, be possible to opt for the 30% flat-rate exemption.

The Impatriation Certificate: an Example

In practice, the employer generally issues each year a reference salary certificate, often called an “impatriation certificate” (attestation impatriation), which makes it possible to show that the remuneration condition is met.

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.

In practice, it is generally the employer that determines the reference remuneration, using the data available to it.

The tax authorities state 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 tax authorities allow, 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. They specify that while the rule 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.

For the employee, the aim is therefore generally to obtain the impatriation certificate from their employer. It is, however, the employee who benefits from the exemption and who, in the event of an audit, may have to show that the remuneration condition is met.

How to Calculate the Impatriation Bonus

First Case: Bonus Set in the Employment Contract or Corporate Office Agreement

In this case, the bonus, which corresponds to the additional remuneration, is in principle 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 in principle 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 impatriation bonus cannot be set in advance for its actual amount to the euro, either by its nature or because of how it is calculated, the tax authorities accept that it be determined on the basis of objective criteria set out in the employment contract or corporate mandate; this may be the case for a bonus consisting of the provision of housing in France, or set as a percentage of base pay or of its variable part alone.

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 recruited abroad by a company established in France receives total annual net remuneration of €900,000, with no impatriation bonus quantified in their contract. If they opt for the flat-rate valuation, their impatriation bonus is deemed to be 30% of that remuneration, i.e. €270,000.

This deemed bonus of €270,000 would be 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 (€630,000);

or up to €250,000 if the comparable net salary in France is €650,000. Indeed, the taxable salary in France cannot in principle be lower than that paid for comparable duties by the French company or, failing that, by similar companies established in France.

Cap for Activity 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.

Impatriates must in principle be able to substantiate stays made in the direct and exclusive interest of their employer; this may be done by any means (hotel bills, expense reports, boarding passes or other travel documents, etc.).

Requirement of additional remuneration “linked to the relocation” and recent case law

Administrative court judgments handed down in 2022 and 2023 have adopted a strict interpretation, which remains debated:

• an employee must demonstrate additional remuneration directly linked to the relocation, even if they opt for the 30% flat-rate bonus; failing this, they cannot benefit from the regime;
• accordingly, a legal professional employed by a law firm was held ineligible, as their employment contract did not provide for any amount presented as linked to their impatriate situation, and the employer further stated that remuneration was determined according to merit-based criteria unrelated to the relocation.
• similarly, a systems and network engineer was unable to benefit from the 30% exemption for 2019, as her employment contract did not mention any remuneration element linked to the relocation (fixed salary + holiday bonus only).

In a 2024 judgment, an employee was unable to benefit from the 30% flat-rate exemption for 2021 because:

• their contract did not provide that part of their remuneration would be directly linked to the relocation;
• and they did not establish that the portion of remuneration remaining taxable after the 30% allowance would be at least equal to the remuneration paid to employees performing similar duties within the company or in similar companies in France (the “normal” remuneration condition discussed below).

Legal commentators note that these decisions appear to be at odds with the spirit of the text, which in principle offers an option between an actual regime and a flat-rate regime without the need, in the latter case, to identify precisely the elements linked to the relocation.

“Normal” remuneration condition (anti-abuse clause)

The last paragraph of 1 of I of Article 155 B of the CGI contains a normal remuneration clause: if the portion of remuneration subject to tax (excluding the impatriate bonus) is lower than the remuneration paid for similar duties within the company or, failing that, in similar companies in France, the difference is added back to the taxable base. An example illustrates this rule:

• total annual remuneration: €1,000,000;
• impatriate bonus (30% flat rate): €300,000;
• taxable remuneration before audit: €700,000.

If the “normal” remuneration for similar duties is:

• €750,000: the difference of €50,000 is added back, and the exemption then applies only to €250,000;
• €1,000,000 or more: no exemption is in principle possible, and the entire remuneration is regarded as “normal” and taxable.

Legal commentators point out that this anti-abuse clause may result in a “genuine” impatriate, whose remuneration is deemed too reasonable, being deprived both:

• of the exemption under I (on the impatriate bonus);
• and, as a knock-on effect, of the exemption under II on their passive income, if it were considered that the benefit of II requires actually benefiting from I.

Does the Regime Apply to Seconded Employees?

In principle yes, in the case of a secondment to a French subsidiary of the group.

Can You Change Employer and Keep the Regime?

In principle yes, where the change of employer takes place within the same group, to another group company established in France (for example from French subsidiary A to French subsidiary B).

In principle no in other cases, for example when leaving the French company for a company outside the group.

What About a Change of Position?

In principle, yes. The level of the reference salary may need to be reviewed to ensure that you still meet the conditions for the exemption.

Keeping the regime after a change of position or of employer within the group does not, in principle, extend its duration, which is still calculated from the date on which the person first took up a position in France. By contrast, the regime in principle ceases to apply if the employee leaves the host company before its term, other than for a move within the group, even if they remain a French tax resident.

What Are the Conditions for the Bonus Exemption?

To benefit from the exemption of the impatriation bonus, the employee taxpayer must in principle 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, as a general rule, 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.

To be exempt for its actual amount, the bonus must in principle appear separately in the employment contract or corporate office agreement, or possibly in an amendment to it, drawn up before taking up duties 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.

The overall exemption is in any event capped, depending on the option chosen (see below).

Reaching the 50% exemption cap generally requires, in addition to the impatriation bonus (actual or flat-rate), a significant share of professional activity abroad.

There are therefore two different flat-rate exemptions:

Either an election for an overall cap, the total exemption then not being able to exceed 50% of total remuneration; this cap is generally only reached where there is substantial business travel.

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 in principle also be added the exemption of the impatriation bonus itself.

How the Employer Reports the Impatriation Bonus (Payslip)

The employer reports separately the amount of salaries subject to income tax and of those that are exempt, in particular the impatriation bonus where it has been precisely valued in the employment contract or an amendment. It generally appears separately on the payslip, on a line usually entitled “prime d’impatriation” (impatriation bonus), “rémunération impatriation” or “impatriation”.

In this case, the employee has few formalities to complete (except for the exemption linked to business travel abroad, which may, at their request, allow them to benefit from additional exemptions). Their payslip generally shows two lines: the basic salary, which is taxable, and the impatriation bonus, which is exempt from tax. At the end of the year, the employer automatically sends this information to the tax authorities: the return is therefore pre-filled for the taxable salary, and the employee in principle states, for information, the amount of exempt salary.

On the other hand, the election for the 30% flat-rate valuation of the bonus is in principle made when filing the income tax return, by means of an express statement (for example a message at the end of the return).

What Must the Employee Declare?

For the Impatriation Bonus

Exempt salaries and bonuses are in principle reported on line 1DY or 1EY of supplementary return 2042 C; this entry is not intended to subject the income to income tax, but to allow the reference tax income to be calculated. Where the flat-rate valuation of the impatriation bonus and/or the exemption linked to business travel abroad is elected, the election is in principle made in the income tax return, by means of an express statement, i.e. a message at the end of the return.

For Foreign Dividends, Interest and Capital Gains

The taxpayer in principle attaches to their overall income tax return (form 2042) and to their supplementary income tax return (form 2042 C) a return of income received abroad (form 2047); this shows separately the amount of income, including tax credits, subject to income tax, the amount of income, including tax credits, 50% exempt from income tax, and the amount of creditable treaty tax credits, in full. These items are then carried over to income tax return 2042.

Foreign-source investment income: formalities

For investment income received abroad, the returns are in principle presented as follows:

• form 2047 distinguishes between:

• the taxable portion;
• the portion exempt up to 50%;
• expenses and tax credits;
• these amounts are then carried over to:

• return 2042 (investment income sections, for example line 2DC for dividends);
• return no. 2042‑C (line 2DM for the gross exempt amount, line 8VL for foreign tax credits).

As a result, in principle:

• social security contributions are calculated on a base equal to the sum of the taxable portion and the exempt portion (i.e. 100% of the gross income, including the tax credit);
• a foreign tax credit may, where the tax treaty provides for it, be granted up to the amount of French tax, creditable against income tax and, where applicable, against social security contributions, which needs to be checked by a lawyer, case by case.

For foreign accounts

Like any French tax resident, an impatriate in principle reports every year the accounts opened, held, used or closed abroad, including those in their home country and dormant ones: form 3916 attached to the income tax return, with box 8UU ticked (8TT for a life insurance policy taken out abroad). The obligation in principle applies from the first return filed in France. Failure to report is in principle penalised by a fine of €1,500 per account and per year (€10,000 if the account is in a State or territory that has not signed an administrative assistance agreement with France). For details, see which foreign accounts must be declared.

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.

The Impatriation Bonus: an Advantage 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 in principle exempt from tax.

It can also facilitate recruitment and the integration of employees in France.

In addition, the income tax exemption enjoyed by the employee may allow the company to offer an attractive net remuneration at a controlled cost, which may strengthen its competitiveness on the international market.

Impatriation and Social Security Contributions (Urssaf)

Is the impatriation bonus subject to Urssaf contributions? In principle, yes. The exemption under article 155 B of the CGI concerns income tax; it does not extend to social security contributions and levies. For social security purposes, the impatriation bonus remains part of the remuneration paid in return for work: it is in principle included in the base for employee and employer social security contributions, as well as for the CSG and CRDS, like the rest of the salary (article L. 242-1 of the French Social Security Code). As a general rule, a bonus exempt from income tax is therefore not, for all that, exempt from contributions.

On the employer’s side, however, the impatriation bonus is in principle exempt from payroll tax (taxe sur les salaires), up to the amount exempt from income tax.

The main social security measure specific to impatriates concerns old-age insurance. On request, they may be exempted from affiliation to the compulsory basic and supplementary old-age insurance schemes, and therefore from the corresponding contributions (article L. 767-2 of the French Social Security Code), provided they can prove that a minimum contribution is paid elsewhere, for example to a foreign pension fund or retirement scheme. They then in principle acquire no French pension rights during the exemption period.

They must in principle show a minimum contribution of €20,000 per year to one or more pension schemes, and must not have been affiliated, during the five calendar years preceding the year in which they took up their duties, to a compulsory French old-age insurance scheme. The exemption is in principle granted on request, for three years, renewable once.

Impatriate employees and executives may also deduct contributions paid to foreign welfare and pension schemes, subject to conditions.

Exemption from Property Wealth Tax (IFI)

People who settle in France without having been domiciled there for tax purposes during the previous five calendar years are in principle liable to property wealth tax (impôt sur la fortune immobilière, IFI) only on their real estate located in France: their real estate located outside France is exempt (article 964 of the CGI).

This exemption applies, as a general rule, until 31 December of the fifth year following the year in which they settle in France, and covers real estate held directly or through a company.

It does not depend on the article 155 B impatriate regime: it in principle benefits any new resident who has not been domiciled in France for tax purposes during the five calendar years preceding their arrival.

The exemption in principle lasts a maximum of 5 years.

What I see in my cases

The impatriate regime remains a little-known niche, including for the tax authorities, which tend to refuse it as soon as an element is not rigorous and sometimes follow erroneous reasoning that leads to disputes. As the exemption often reaches 30%, or even 50%, of high remuneration, the stakes are very high.

In my cases, everything is decided upstream: employment contract, certificate of the reference salary, substantive conditions — each element is analysed and, where necessary, corrected before any dispute. When the tax authorities then ask questions, the file is ready and the answers are solid.

The profile I come across most often is that of an employee aged 28 to 45, working in tech, often a foreign national, sometimes a French national returning to France. Beyond the bonus, I seek to make full use of everything the regime allows: the partial exemption of certain income from foreign assets and certain capital gains, or the exemption of the portion of remuneration relating to business trips abroad, subject to conditions. When the regime ends, or in the event of early departure, it ceases to apply, without past benefits being called into question in my cases.

Conclusion

The impatriate regime can be very advantageous.

Its conditions of application and filing requirements nevertheless remain technical and, as it is a favourable regime, the tax authorities may check closely that they are met; a challenge may be accompanied by late-payment interest and, depending on the case, penalties.

The assistance of a tax lawyer experienced in this regime may therefore be useful: they can in particular help check the conditions for applying the regime and assist the taxpayer in the event of later questions from the tax authorities.

To Find Out More: the 2025 BOFiP Clarifications

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).

FAQ

Official Sources

• BOFiP - BOI-RSA-GEO-40-10-10: impatriate regime, scope (update of 11 August 2025) (in French)
• BOFiP - BOI-RSA-GEO-40-10-20: impatriate regime, exemptions and caps (update of 11 August 2025) (in French)
• impots.gouv.fr - The impatriate regime (in French)
• Interministerial instruction No. DSS/5B/DGTrésor/2019/150 of 28 June 2019: exemption from old-age insurance affiliation for impatriate employees (in French)
• impots.gouv.fr - 2026 practical guide: wages and salaries (impatriates, lines 1DY and 1EY) (in French)
• impots.gouv.fr - 2026 IFI practical guide: who is liable (in French)

Read more

• How to Declare the Impatriation Bonus?
• French impatriate regime: how is the exemption calculated? Three worked examples
• Tax Impatriation
• Tax Exemption After Returning to France
• First Tax Return in France