France · Tax regime
Impatriate tax regime (Régime des impatriés, Article 155 B CGI)
Open. Runs to 31 December of the eighth calendar year following the year duties are taken up — so duties commencing in 2026 shelter income through 31 December 2034.
The two clocks run at different speeds and this is where advisers get caught: the income exemptions last eight years but the IFI shelter on foreign real estate lasts only five. A family with a EUR 20m foreign property portfolio walks into full French IFI in year six while still believing they are inside the regime.
Qualifying routes
The impatriation premium is exempt from income tax; recruits hired directly from abroad may elect a flat 30% of total remuneration instead of the actual bonus
The portion of remuneration relating to duties performed abroad is exempt, subject to a cap (either 50% of total remuneration, or 20% of the taxable non-foreign remuneration)
Half of foreign-source dividends, interest, capital gains on securities and certain IP income is exempt, where paid from a state with an administrative assistance treaty with France
Foreign real estate is excluded from the IFI base for 5 years from the year of arrival — automatic, but shorter than the 8-year income shelter
The facts
- Total landed cost
- no direct cost; requires pre-arrival structuring and a qualifying employment or corporate-officer relationship
- Physical presence
- requires French tax residency and the taking up of duties in a French entity
- Family
- applies to the individual; a spouse must independently qualify on their own employment
- Permanent residency
- not applicable — a tax regime, not an immigration status
- Citizenship
- not applicable
- Language test
- not applicable
- Dual citizenship
- Permitted
- Requirements
- not have been French tax resident in the 5 complete calendar years preceding the year duties commencebecome French tax resident on taking up dutiesbe recruited from abroad by a French entity, or seconded intra-group to Francehold employee or corporate-officer (mandataire social) statustaxable remuneration must not fall below that of comparable roles
- The IFI exclusion on foreign real estate runs 5 years; the income exemptions run 8. Model the year-six cliff at the outset.
- You must not have been French tax resident during the 5 complete calendar years preceding the year you take up duties — and the regime is lost permanently if you were.
- The 50% exemption on foreign passive income requires the paying state to have an administrative assistance agreement with France; income from non-cooperative states is excluded.
- The regime does not shelter you from French inheritance tax, which is where the real money is for a dynastic family — 45% in the direct line, and France taxes worldwide assets on residents who have been resident 6 of the last 10 years.
- Social levies rose in 2026, taking the effective rate on investment income above the familiar 30% — confirm the current combined rate before modelling.
- Self-employed persons and people who moved to France on their own initiative without an employer relationship generally cannot access the regime.