Assignments abroad, a job with a foreign employer with regular returns to France, cross-border work: many people reside in France while working, wholly or partly, outside France. This situation raises several tax questions: can France tax this salary? How should it be declared? How can it be prevented from being taxed twice?
This article presents the main French rules that apply, with a worked example. It supplements the page on foreign-source salaries. As each situation depends in particular on the applicable tax treaty, an analysis with a lawyer is generally useful.
In brief
- A French tax resident is in principle taxable in France on all their income, including the salary for work performed abroad, subject to tax treaties.
- The treaty between France and the country of work in principle designates the State that may tax the salary: most often the country where the work is performed, with exceptions (short assignments, cross-border workers, etc.).
- Where the salary is taxable in the country of work, France may, depending on the case, avoid double taxation through a tax credit or an exemption with the effective rate rule: the salary would then not be taxed a second time, but it could increase the rate applied to other income; only an analysis of the situation by a lawyer can determine whether or not the applicable treaty allows this.
- Article 81 A of the French General Tax Code may, under conditions, exempt the salary of certain employees sent abroad by their employer.
- The foreign salary is in principle declared every year, even where no tax is due in France; bank accounts opened abroad are also, in principle, to be declared.
Contents
Being a French tax resident: the starting point
A person is in principle a French tax resident if they meet at least one of the criteria of article 4 B of the French General Tax Code: their home (the place where their family usually lives) or main place of stay is in France, they carry on their main professional activity there, or the centre of their economic interests is there. A person who works abroad for most of the year but whose family lives in France may therefore, depending on the case, remain a French tax resident.
A French tax resident is in principle taxable in France on all their income, from French and foreign sources; a non-resident, only on French-source income. Where a person is regarded as resident by two States, the tax treaty in principle makes it possible to determine which of the two prevails (see the article can one be tax resident in two countries?). The rest of this article concerns people who remain French tax residents.
Which country may tax the salary?
Without a tax treaty, the salary of a French resident is in principle taxable in France, even if it remunerates work performed abroad, subject to the article 81 A exemption presented below. Where a treaty exists (see the table of tax treaties), it allocates the right to tax between the two States. Most treaties concluded by France follow the OECD model on this point; the most common situations are as follows:
| Situation | State that may in principle tax the salary | In France |
|---|---|---|
| Work performed in the other State, on a lasting basis or for an employer of that State | The State where the work is performed | Salary declared; double taxation may, depending on the case, be avoided through a tax credit or an exemption with the effective rate rule (to be analysed by a lawyer) |
| Short assignment: stay of no more than 183 days over the reference period set by the treaty, salary paid by an employer not established in the other State and not borne by a permanent establishment it has there | France, the State of residence | Salary in principle taxable in France under the usual rules |
| Cross-border worker, where the treaty provides for a special regime | France, the State of residence, under conditions | Salary in principle taxable in France |
| Days worked in France, for example teleworking, including for a foreign employer | In principle France, subject to certain special agreements | Corresponding part of the salary in principle taxable in France |
Some remuneration follows its own rules: public remuneration paid by a State, directors’ fees, crew members of international transport companies, artists and sportspeople, etc. The text of each treaty therefore deserves to be checked.
How France may avoid double taxation
Where the treaty allocates the taxation of the salary to the country of work, the salary must in principle still be declared in France. Depending on the treaty, France may, where applicable, apply one of the following methods:
| Method | Declaration in France | Effect |
|---|---|---|
| Tax credit equal to the French tax | Form no. 2047, then boxes 1AF et seq. of return no. 2042 C and box 8TK | The salary is taken into account to calculate the tax, then a tax credit may, if the treaty provides for it, cancel the French tax corresponding to this salary (to be checked by a lawyer) |
| Exemption with the effective rate rule | Directly in boxes 1AC et seq. of return no. 2042 C, without form no. 2047 | The salary may, depending on the treaty, not be taxed (to be analysed by a lawyer), but it is then used to calculate the rate applicable to the household’s other income |
| Tax credit equal to the foreign tax (provided for by certain treaties) | Form no. 2047, then boxes 1AG et seq., credit in boxes 8VM et seq. | The salary is in principle taxed in France; the tax paid abroad, within the limit set by the treaty and that of the French tax, may be deducted from the French tax: a lawyer’s analysis is needed |
With the first two methods, provided for by many treaties for salaries, the foreign salary might not be taxed in France as such, but it would then raise the rate applied to other income taxable in France; it is necessary to have the situation analysed by a lawyer to find out whether or not the applicable treaty leads to this result. Tax paid abroad is in principle not refunded by France. These mechanisms are explained in more detail, with other examples, in the article on boxes 8TK and 8VL.
A worked example
Julien, single, is a French tax resident. In 2025, he worked in France from January to May (€300,000 of taxable income, after the 10% deduction for professional expenses, which is capped), then in a country whose treaty allocates taxation to the country of work and provides for a tax credit equal to the French tax (€450,000 of taxable income). The amounts are calculated with the scale applicable to 2025 income (one share, with no tax reduction or credit, excluding the exceptional and differential contributions on high incomes).
| Step | Calculation | Amount |
|---|---|---|
| Total taxable income | €300,000 + €450,000 | €750,000 |
| Tax calculated on €750,000 | 11% from €11,600 to €29,579 + 30% from €29,579 to €84,577 + 41% from €84,577 to €181,917 + 45% from €181,917 to €750,000 | €314,024 |
| Tax credit (box 8TK) | €314,024 × 450,000 ÷ 750,000 | − €188,414 |
| Tax due in France | €314,024 − €188,414 | €125,610 |
| For comparison: tax on the French salary alone | on €300,000 | €111,524 |
Assuming that a lawyer’s analysis of the situation confirms that this tax credit applies, the foreign salary would not be taxed in France as such, but would raise the rate applied to the French salary: Julien would pay €14,086 more than if he had received only his French salary. With the exemption with the effective rate rule, the result would in practice be the same; only the way of declaring changes.
The article 81 A exemption for certain employees sent abroad
Even where the treaty does not allocate taxation to the country of work, or where there is no treaty, the salary may, under conditions, be exempt in France under article 81 A of the French General Tax Code. This scheme concerns employees domiciled in France who are 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. Full exemption is in principle possible in two cases:
- the salary has borne, in the country of work, an income tax at least equal to two thirds of the tax it would have borne in France;
- the activity abroad lasted more than 183 days over a period of twelve consecutive months in certain sectors (construction or assembly sites, installation of industrial facilities, research or extraction of natural resources, navigation on board certain ships), or more than 120 days for commercial prospecting.
Failing that, salary supplements linked to stays abroad may, under conditions, be exempt up to 40% of the remuneration. The exempt amounts are in principle taken into account to calculate the rate applicable to other income. The detailed conditions are presented in the article on employees who travel abroad.
Cross-border workers
Some treaties provide for a cross-border workers’ regime: the salary is then taxable in the State of residence, i.e. in France, provided that the person lives and works in the border areas defined by the treaty and meets its conditions, in particular regarding returns home. This is the case, under conditions, with Germany, Spain, Italy and, for eight cantons, Switzerland. Cross-border workers employed in the canton of Geneva are not covered: their salary is declared in France in accordance with the rules presented above and might, in some cases, not be taxed there, which needs to be checked by a lawyer.
The returns to plan for
In principle, a French tax resident must declare all their income every year, including where no tax is ultimately due in France. For a foreign salary, several items are generally concerned:
- income tax return no. 2042 and supplementary return no. 2042 C, with the salary entered in the boxes corresponding to the method provided for by the treaty;
- form no. 2047 (foreign-source income), except where the salary is exempt with the effective rate rule and declared directly in boxes 1AC et seq.;
- bank accounts opened abroad, including the one into which the salary is paid, on form no. 3916;
- withholding at source: depending on the case, any French tax due on a salary paid by a foreign employer is collected by withholding or by instalments, and taking the foreign salary into account may change the withholding rate applied to other income.
Each situation deserves to be analysed, ideally with a lawyer, before completing the returns: applicable treaty, method for eliminating double taxation, possible application of article 81 A, position regarding social security contributions. This analysis also makes it possible, where appropriate, to examine the situation for past years.
What I see in my cases
Teleworking from France for a foreign employer often causes difficulties, particularly as regards payroll, and the consequences for the employee then have to be untangled. Dual tax residence is also fairly common; it is generally resolved through the tax treaty, provided the situation is properly framed.
FAQ
I work abroad but my family lives in France: am I a French tax resident?
In principle yes: the home, i.e. the place where the family usually lives, is enough to make a person a French tax resident within the meaning of article 4 B of the French General Tax Code, even if they spend most of the year abroad. If the country of work also regards them as resident, the tax treaty in principle makes it possible to decide between the two States.
My foreign salary is not taxed in France: must it still be declared?
In principle yes. The salary is, as a general rule, used to calculate the rate applicable to other income and the reference tax income, on which certain advantages depend. An omission may, depending on the case, lead to reassessments and penalties.
What is the 183-day rule?
The expression refers to several different rules. In tax treaties, it in principle allows the salary for a short assignment in the other State to remain taxable in France, the State of residence (stay of no more than 183 days over the reference period, employer not established in the other State, salary not borne by a permanent establishment it has there). It is distinct from the stay criterion of article 4 B and from the 183-day duration required for certain article 81 A exemptions.
I telework from France for a foreign employer: where am I taxed?
In principle in France: a salary is in principle taxable in the State where the work is physically performed, and a French resident who works there is taxable in France, even if their employer is foreign. Some treaties or special agreements provide for adjustments, in particular for cross-border workers; only an analysis of the situation by a lawyer can determine whether or not they apply.
Is the foreign salary subject to CSG and CRDS?
CSG and CRDS on employment income are in principle due from persons domiciled in France who are covered by a compulsory French health insurance scheme. An employee affiliated to the social security system of the country of work is therefore in principle not subject to them on that salary. This point depends on each person’s situation and deserves to be checked.
Is the tax paid abroad refunded by France?
In principle no. The tax credit or the exemption provided for, where applicable, by the treaty may prevent the salary from being taxed a second time in France, which only an analysis of the situation by a lawyer can confirm or rule out; France does not, however, refund the tax paid in the country of work, even if it is higher than the French tax.
