Many French nationals go to work abroad and then return to France a few years later. This return raises two tax questions: from when and on which income does France tax again, and are there exemptions for those who come back to take up a job in France?
This article explains the principle of taxation on return, then the impatriate regime (article 155 B of the French General Tax Code), which may also benefit French nationals returning after a long period abroad. As the conditions are precise, how they apply to a given situation generally deserves to be checked with a lawyer.
In brief
- As soon as the tax domicile is again located in France, the taxpayer is in principle taxable in France on all their income, from French and foreign sources, subject to tax treaties.
- In the year of return, income received before the return is in principle taxable in France only if it is French-source.
- The impatriate regime may benefit a French national returning to work in France, if they were not tax-domiciled in France during the five calendar years preceding their taking up of the position.
- This regime in principle exempts the impatriation bonus (actual amount or 30% flat rate), the remuneration relating to activity carried out abroad, within certain limits, and 50% of certain foreign-source passive income.
- It in principle applies until 31 December of the eighth year following the year in which the position was taken up.
Contents
The principle: all income is taxed from the return
Tax domicile is assessed according to the criteria of article 4 B of the French General Tax Code: home or main place of stay, main professional activity, centre of economic interests. As soon as one of these criteria is met in France, the taxpayer is in principle taxable in France on all their income, whether it comes from France or abroad, subject to tax treaties.
In the year of return, income received before the return is in principle taxable in France only if it is French-source, whereas all income received after the return is in principle taxable. The article on changing tax residence during the year details these rules.
The impatriate regime: who can benefit?
The impatriate regime, as a general rule, covers employees, and certain executives, who take up a job with a business established in France, either because they are called there by a foreign company of their group (intra-group mobility) or because they are recruited directly from abroad. They must in principle not have been tax-domiciled in France during the five calendar years preceding their taking up of the position, and must be so for the duration of the regime. Nationality is irrelevant: a French national returning after a long period abroad may therefore, in principle, benefit from it.
An example
Sophie, a French national, lived and worked in Singapore from 2019 to 2025. In 2026, she is recruited directly from abroad by a company established in Paris and returns to live in France. As she was not tax-domiciled in France between 2021 and 2025, she may in principle benefit from the impatriate regime until 31 December 2034, if the other conditions are met.
What the regime provides
The regime provides several advantages, which concern income tax only:
| Item | Treatment in principle | Provision |
|---|---|---|
| Impatriation bonus | In principle exempt for its actual amount or, on option, valued at a flat 30% of total net remuneration | Article 155 B, I of the CGI |
| Remuneration relating to activity carried out abroad | Exempt where the trips are made in the direct and exclusive interest of the employer, within ceilings | Article 155 B, I of the CGI |
| Certain foreign-source passive income (investment income, intellectual property rights, capital gains on securities) | 50% exempt; social contributions in principle remain due | Article 155 B, II of the CGI |
| Contributions to foreign pension schemes the impatriate belonged to before arriving | Deductible, under conditions and within certain limits | Article 83, 2°-0 ter of the CGI |
The impatriate’s taxable remuneration must in principle be at least equal to that paid for similar duties in the business or in similar businesses established in France. This condition may be evidenced by any means, in particular by a certificate from the employer (BOI-RSA-GEO-40-10-20).
Duration of the regime and tax return
The regime in principle applies until 31 December of the eighth calendar year following the year in which the position in France was taken up.
In the income tax return, the net taxable salary, after deduction of the exempt part, in principle appears in boxes 1AJ or 1BJ of return no. 2042, and exempt salaries and bonuses in boxes 1DY or 1EY of return no. 2042 C. The article how to declare the impatriation bonus and the guide to calculating the exemption detail these steps.
What I see in my cases
Those who return to France are often surprised by the weight of taxation and the complexity of the system. The impatriates I advise are generally employees aged 28 to 45 working in tech, often foreign nationals, sometimes French nationals returning to France. The most serious errors are often the simplest: an employment contract that does not mention impatriation, a clumsily drafted certificate of the reference salary. The tax authorities may then reject the regime, reassess over three years and ask that it no longer be applied in subsequent years.
FAQ
Can a French national returning to France benefit from the impatriate regime?
Yes, in principle: nationality is irrelevant. What matters in particular is not having been tax-domiciled in France during the five calendar years preceding the taking up of the position, and being recruited from abroad or called by a foreign company of one’s group.
Is income received abroad before the return taxable in France?
In principle no, unless it is French-source income; income received after the return is in principle taxable in France, whatever its source, subject to tax treaties.
Does the regime apply to the self-employed?
The article 155 B regime covers employees and certain executives; the situation of non-employees follows other rules and deserves to be analysed case by case.
How long does the regime last?
In principle until 31 December of the eighth calendar year following the year in which the position in France was taken up, i.e. between eight and nine years depending on the date of arrival.
Are social contributions exempt?
In principle no: the 50% exemption of foreign-source passive income concerns income tax only; social contributions in principle remain due.
