French impatriate regime: secure your return to France before signing

Why this pack exists

In most cases, the risk does not come only from the tax rules themselves. It comes from their practical implementation: employment contract, impatriation bonus clause, benchmark remuneration, payroll, DSN reporting and income tax return. These topics are often handled by HR or global mobility teams that may not be familiar with the French impatriate regime. The pack gives the employee, the executive and the employer a clear, sourced and directly usable roadmap.

You are not buying a note. You are securing an important tax decision.

The French impatriate regime may represent a significant tax benefit over several years. But it requires the right chronology, solid documentation and rigorous HR execution. This pack was designed to address these points before they become problems.

Mistakes that can be costly

A missing, late or poorly drafted clause can cost far more than the price of the pack. The approximations that, in practice, forfeit all or part of the regime:

What the Impatriate HR Pack includes

Who is it for?

This pack is intended in particular for the following profiles:

• an employee returning to France after at least five years abroad;
• an executive or senior manager recruited from abroad;
• an intra-group transfer to a French company;
• a return from Dubai, London, Singapore, Switzerland, the United States, Luxembourg, Belgium, Portugal or another international location;
• profiles with high compensation, bonuses, RSUs, stock options, carried interest, a foreign portfolio or foreign accounts;
• an employer, HR department or global mobility team seeking to secure an impatriate case.

The offer

Immediate download: waiver of the right of withdrawal (Art. L. 221-28 of the French Consumer Code).

Understand the regime before you sign

The rest of this page details the regime, its obligations and its timeline — the very material the pack puts into shape, source by source, for you and for your employer.

The French impatriate regime, from an HR standpoint

The French impatriate regime (Article 155 B of the Tax Code) lets an employee coming — or returning — from abroad exempt part of their pay from income tax until 31 December of the eighth year following the start of duties. For an HR or global-mobility team, it comes down to three concrete acts: an impatriation-bonus clause set in the contract before duties begin, a documented reference remuneration, and a payroll/DSN setup that isolates the exempt amounts (outside withholding at source). This note delivers those three acts, in French and English, ready to use.

Why HR teams — especially foreign ones — get lost

The impatriate regime is a French tax mechanism whose implementation rests largely on HR and payroll acts: a contract drafted before the start of duties, a documented reference remuneration, a correctly completed DSN filing. Yet in an international mobility, these acts are often driven by a global mobility team based in Dubai, London or Singapore that knows neither article 155 B of the CGI, nor the case law on contractual timing, nor the boxes of the French tax return.

The classic result: a generous package, but no identified « impatriation bonus »; an addendum signed three months after arrival; a French payroll that subjects the bonus to withholding at source. Each of these approximations costs part of the benefit — sometimes all of it for pre-2019 situations. This page serves as a roadmap; the complete, bilingual version that can be sent directly to your employer is included in the Impatriate HR Pack above.

Step 1 — Before the start of duties: the contract

• Insert the impatriation bonus clause in the employment contract, the corporate office agreement or an addendum drawn up before the start of duties in France (BOI-RSA-GEO-40-10-20, § 60). A quantified actual amount or, failing that, objective determination criteria (percentage of remuneration, housing benefit, etc.).
• Distinguish the bonus from the base salary: an undifferentiated overall envelope does not constitute an impatriation bonus. The DGFiP requires that an additional element of remuneration be expressly linked to settling in France.
• Date and keep: the timeline (signature before the move and before the first day of performance in France) must be provable — it also conditions the eligibility of an employee recruited abroad (see the eligibility page).
• Qualify the channel: intra-group transfer (document the links between entities within the meaning of article L. 233-3 of the French Commercial Code) or external recruitment (document the application and the residence abroad).

Step 2 — Determining the reference remuneration

This is an obligation specific to the employer: it must determine the reference remuneration — that paid for comparable functions within the company or in similar companies established in France — inform the employee of it, and be able to justify the method to the tax authority (BOI-RSA-GEO-40-10-20, § 110 to 160; DGFiP fact sheet). In practice:

• build a comparables file (internal salary grids, sector pay studies) from hiring;
• give the employee a certificate stating the method used — without it, the doctrinal accommodations (external comparables, lowest comparable remuneration, assessment for the settling-in year alone) are inapplicable;
• update the analysis on any change of position.

Step 3 — Payroll, DSN and withholding at source

• DSN: report separately the amount of salaries subject to income tax and the amount of exempt sums, in the « sums exempt under the impatriate regime » field — the total of the impatriation bonus and of the portion of remuneration relating to the activity performed abroad (BOI-RSA-GEO-40-10-20, § 360).
• Withholding at source: the exempt impatriation bonus is outside the basis of the withholding (BOI-RSA-GEO-40-10-20, § 360, remark). A default set-up that subjects it to French withholding creates an undue cash advance for the employee.
• Informing the employee: the employer communicates these amounts to the person concerned (§ 370), who will need them for boxes 1AJ/1DY.

Step 4 — The benefits on the employer side

Payroll tax (art. 231 bis Q of the CGI)

For employers liable to payroll tax (banking, insurance, medical and non-profit sectors, among others), the remuneration exempt under article 155 B is exempt from payroll tax: up to the bonus exempt from income tax or, where the employee elects the flat-rate valuation, up to a 30% fraction of remuneration. The exemption applies under the same domicile and duration conditions as the main regime (CGI, art. 231 bis Q; DGFiP fact sheet « Le régime des impatriés »).

Old-age contributions (art. L. 767-2 of the French Social Security Code)

The impatriate employee can request, under conditions, an exemption from affiliation to the compulsory French old-age insurance schemes (basic and supplementary), which reduces the corresponding contributions — both employee and employer. The request is the employee's to make, but its implementation runs through payroll; the procedure is described by Urssaf. This choice affects pension rights and must be weighed.

Package attractiveness

Properly structured, the regime increases the employee's after-tax net at constant employer cost — a decisive negotiating lever to bring back an executive based in Dubai or Singapore, or to attract an international profile.

What the employee does themselves (and the employer cannot do for them)

• Exercise the annual elections (30% flat-rate valuation, choice of the 50% / 20% cap) by express statement on the income tax return;
• check the pre-filled amount and report the taxable salary in 1AJ/1BJ, and the exempt salaries and bonuses in 1DY/1EY of form 2042 C;
• report foreign-source income (form 2047) and accounts held abroad (forms 3916/3916 bis);
• keep the supporting documents for workdays abroad.

The detail is on the tax returns page.

Typical timeline of a successful return

From rule to practice: why a turnkey note

The impatriate regime is decided in documents you do not draft yourself: the employment contract, the transfer addendum, the payroll. And the people who draft them — an overstretched Paris HR department, a global mobility team in Dubai or London — generally know neither article 155 B of the CGI, nor the requirement of a clause drawn up before the start of duties, nor the expected DSN set-up.

Explaining all of this yourself, in English, to three successive contacts, in the middle of a return negotiation: that is the surest way to see the subject buried. The Impatriate HR Pack does that work for you: a professional, sourced, bilingual document that you forward as is, paired with a video call to frame your case.

What the HR note contains (included in the pack) — ~20 pages, FR/EN

Why GEOTAX

GEOTAX is the tax consulting firm founded in Dubai by Jonathan Sémon, a tax attorney admitted to the Paris Bar, dedicated to French-Emirati matters: expatriation, exit tax, tax residence — and now the return corridor. The Impatriate HR Pack distills the firm's practice on returns of executives and company officers from the Emirates and Singapore, with up-to-date official references (BOFiP of 11 August 2025, DGFiP fact sheet of 8 April 2026).

Frequently asked questions about the Impatriate HR Pack