France · Tax regime
Impatriate tax regime (Régime des impatriés, Article 155 B CGI)
Open. It 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 instead elect a flat 30% of total remuneration in place of the actual bonus.
The portion of remuneration tied to duties performed abroad is exempt. This is 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, provided it is paid from a state that has an administrative assistance treaty with France.
Foreign real estate is excluded from the IFI base for 5 years from the year of arrival. This exclusion is automatic, but it runs shorter than the 8-year income shelter.
The facts
- Total landed cost
- There is no direct cost, but it requires pre-arrival structuring and a qualifying employment or corporate-officer relationship.
- Route type
- Tax regime, not a visa
- Physical presence
- Requires French tax residency and taking up duties in a French entity.
- Family
- Applies to the individual only. A spouse must independently qualify through their own employment
- Permanent residency
- Not applicable. This is a tax regime, not an immigration status.
- Citizenship
- Not applicable
- Language test
- Not applicable
- Dual citizenship
- Permitted
- Requirements
- You must not have been French tax resident in the 5 complete calendar years preceding the year duties commence.You must become French tax resident on taking up duties.You must be recruited from abroad by a French entity, or seconded intra-group to France.You must hold employee or corporate-officer (mandataire social) status.Your taxable 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. If you were, the regime is lost permanently.
- The 50% exemption on foreign passive income requires the paying state to have an administrative assistance agreement with France. Income from non-cooperative states does not qualify.
- The regime does not shelter you from French inheritance tax, and that is where the real money is for a dynastic family. The rate is 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, pushing the effective rate on investment income above the familiar 30%. Confirm the current combined rate before modelling.
- Self-employed people, and anyone who moved to France on their own initiative without an employer relationship, generally cannot access the regime.