The French impatriate regime: preparing the tax side of your return to France

How article 155 B of the CGI works

The impatriate regime is the inbound counterpart of the rules that govern departures (the exit tax of article 167 bis of the CGI). Introduced by article 121 of the law of 4 August 2008 on the modernization of the economy, it is designed to attract to France — or bring back — executives, managers and talent based abroad, by temporarily neutralizing part of the additional tax cost of settling in France.

The principle: over a period running until 31 December of the eighth calendar year following the start of duties, certain items of income escape income tax, in whole or in part. The regime applies as of right, without prior approval: there is no application to file with the tax authority. But it is not presumed — it takes form in the employment contract, in payroll, then in the income tax return.

The three pillars of the exemption

• Employment income: the impatriation bonus (actual amount or a flat 30%) and the portion of remuneration relating to workdays abroad are exempt from income tax, subject to a dual cap at the taxpayer's choice (50% overall or 20% on the « foreign » portion). See the impatriation bonus page.
• Foreign-source passive income: dividends, interest, capital gains on disposals of securities and certain intellectual property income received abroad are exempt up to 50%, where the payer or custodian is established in a State bound to France by an exchange-of-information clause. See the exemptions page.
• Wealth: the real estate wealth tax (IFI) applies only to real property and property rights located in France until 31 December of the fifth year following the move (art. 964, 1° of the CGI) — this component benefits any new resident after five years of non-residence, with no employment requirement.

Who is the regime for?

Two groups are covered, under the same condition of not having been a French tax resident during the five calendar years preceding the start of duties:

1. Employees and executives on intra-group mobility

Persons employed by a foreign entity and called to work in a company established in France that is related to the home company (capital, legal or commercial links). This is the channel of the return from expatriation organized with the employer: the administrative guidance expressly accepts that expatriates who return to the French company that employed them before their departure — or to another group company — qualify for the regime, even if their French contract was terminated, suspended or amended during the expatriation (BOI-RSA-GEO-40-10-10, § 40, version of 11 August 2025).

2. Persons recruited directly from abroad

Persons recruited from abroad by a company established in France, whether they were employed by another employer, self-employed or not working. Since the guidance update of 11 August 2025, persons who apply from abroad for a job in France are expressly treated as recruited directly from abroad. Conversely, those who come to France on their own initiative before being recruited, or who have already established their home there at the time of recruitment, are excluded.

Eligible persons are employees and executives treated as employees for tax purposes (1°, 2° and 3° of b of art. 80 ter of the CGI: chairman of the board, chief executive officer, deputy chief executive officers, management board members of SA/SAS companies, minority or equal-share managers of SARL companies, executives subject to the tax regime of employees). The liberal professions and the self-employed are not — the « non-salaried » component of the regime was repealed from 2017. Full detail on the eligibility conditions page.

What the regime delivers: orders of magnitude

The benefit depends on the level of remuneration, the structure of the package and the assets kept abroad. By way of illustration, and without any commitment:

Each line assumes specific conditions are met (reference remuneration, source State covered by an exchange-of-information clause, caps). No saving is guaranteed: only an individualized analysis of the package and the assets can quantify the actual benefit.

How to activate the regime — timing is everything

1. Before signing: verify the five years of non-residence, negotiate the impatriation bonus and have it stated separately in the contract or an addendum drawn up before the start of duties (BOI-RSA-GEO-40-10-20, § 60), and document the recruitment or transfer from abroad.
2. On taking up duties: transfer your tax domicile to France (home or main place of stay + main occupation, art. 4 B, 1-a and b). An administrative tolerance allows the household to settle in France up to the end of the calendar year following the start of duties without losing the salary exemption.
3. In payroll: the employer reports separately, in the DSN payroll filing, the taxable salaries and the amounts exempt under the regime; the exempt bonus is outside the basis of French withholding at source.
4. Each year: exercise the elections (30% flat-rate option, choice of cap) by express statement on the tax return, report the taxable salary in boxes 1AJ/1BJ and the exempt amounts in boxes 1DY/1EY of form 2042 C, and report foreign income (form 2047) and accounts held abroad (forms 3916/3916 bis). Detail on the tax returns page.

An 8-year window — neither extendable nor retroactive

For duties taken up since 6 July 2016, the exemptions apply until 31 December of the eighth calendar year following that of the start of duties (five years for earlier start dates). The regime is preserved in the event of a change of position within the company or mobility to another company of the same group (control within the meaning of article L. 233-3 of the French Commercial Code), but the period continues to run from the first start of duties. Leaving the host company for an employer outside the group, or losing French tax domicile, forfeits the benefit for the year concerned. See the 8-year period page.

The GEOTAX case: returning from Dubai

For an executive or company officer based in the Emirates for at least five calendar years, the return to France can be structured around the impatriate regime: negotiating the package before signing, qualifying the move as intra-group mobility or external recruitment, handling income from the portfolio kept in the UAE (the Emirates are bound to France by the treaty of 19 July 1989, which contains an exchange-of-information clause: UAE-source passive income qualifies for the 50% exemption), switching tax residence and coordinating with any exit tax deferral obtained on leaving France. We have devoted a full page to this journey: returning from Dubai under the impatriate regime.

Official sources

References current as of 11 June 2026. Applying them to any specific situation requires individualized analysis.