Duration of the regime: 8 years, mobility and loss events

The principle: until 31 December of the eighth year

For duties taken up on or after 6 July 2016, the exemptions of the impatriate regime apply for each year of tax domicile in France (art. 4 B, 1-a and b of the CGI), until 31 December of the eighth calendar year following that of the start of duties in France (BOI-RSA-GEO-40-10, § 20).

For duties taken up before 6 July 2016, the period was limited to 31 December of the fifth year following the start of duties. The extension to eight years results from article 71 of law no. 2016-1917 of 29 December 2016 (the 2017 Finance Act) — those situations have all now expired, but the pivot date remains useful for reading older litigation.

The start-of-duties date is the date on which performance of the employment contract or corporate office in France actually begins (BOI-RSA-GEO-40-10-10, § 150). Mechanically, taking up duties in January maximizes the actual coverage period: starting on 1 January 2027 rather than 15 December 2026 pushes the end of the regime from 31 December 2034 to 31 December 2035, for a fifteen-day difference.

A year-by-year assessment

Compliance with the domicile conditions is assessed for each year of application. A year in which the impatriate does not have their home (or main place of stay) in France, or does not carry on their main activity there, is a lost year — but it calls into question neither earlier nor later years, and the end date of the regime keeps running: the period continues to be counted from the first start of duties, without extension (BOI-RSA-GEO-40-10-10, § 230).

When the regime is preserved

Since law no. 2015-990 of 6 August 2015 (art. 263), applicable to changes occurring from 7 August 2015, the regime is preserved in three situations (CGI, art. 155 B, I-1; BOI-RSA-GEO-40-10-10, § 250 to 280):

1. Change of position within the same company

Promotion, change of role or scope within the host company: the regime continues. The same applies where the foreign company ends the secondment and the employee signs a local contract with the French company where they were already working (§ 270, remark).

2. Change of company within the same group

Mobility to another group company established in France, whether the functions are similar or different. The group means the whole formed by a company (French or foreign) and the companies it controls within the meaning of article L. 233-3 of the French Commercial Code: majority of voting rights (direct, indirect or in concert), power to appoint corporate bodies, or presumption of control above 40% of voting rights with no larger shareholder (§ 280).

3. Transfer of the employment contract (art. L. 1224-1 of the French Labor Code)

Where the employer's legal situation changes (merger, sale, transformation of the business), the automatic transfer of the contract preserves the benefit of the regime until its normal end (BOI-RSA-GEO-40-10-20, § 170).

The new bonus on a change of position

On a change of position, the rules for determining the bonus apply as at the date of the change. Accepted practical rule: if the salary resulting from the change is at least equal to the previous one, the new impatriation bonus is presumed at least equal to that of the previous role (BOI-RSA-GEO-40-10-20, § 105).

When the regime is lost

• Moving to a company outside the group: the regime ends, even if the employee remains a French tax resident. The new recruitment, made from France, cannot reopen the regime (the five-year non-residence condition is not met).
• Break in French domicile (departure abroad, loss of the home or main activity in France): the year concerned is lost; the end date keeps running.
• Reaching the end date: beyond 31 December of the eighth year, all remuneration becomes taxable under ordinary rules — including the impatriation bonus if it continues to be paid — and foreign passive income is taxed in full (BOI-RSA-GEO-40-10, § 20).

Summary table