Expat Tax Residency in France

France operates a domicile fiscal system governed by Article 4B of the Code General des Impots (CGI). Satisfying any single criterion in that article during a tax year establishes full French tax residency for that year, with worldwide income becoming subject to French progressive income tax.

What makes you a French tax resident under Article 4B CGI?

Article 4B CGI sets out four alternative tests. Meeting any one is sufficient; you do not need to satisfy more than one [C1].

Criterion 1 - Foyer (family home): Your principal household is in France, meaning the place where your spouse or civil-partner (PACS) and your minor children habitually live. A person who works abroad for most of the year may still be treated as French resident if the family unit remains established in France. The foyer test focuses on the stability of the family home, not on the individual's own physical presence [C1].

Criterion 2 - Lieu de sejour principal (principal place of stay): France is the country where you spend the most time during the calendar year. The DGFiP treats presence exceeding 183 days as indicative of principal stay, but the test is comparative: if you spend more days in France than in any other single country, France may still qualify even if you do not cross 183 days [C1].

Criterion 3 - Activite professionnelle principale (principal professional activity): You exercise your main professional activity in France, whether salaried or self-employed. Only activities that are ancillary - subsidiary to a primary activity carried out elsewhere - are excluded from this criterion [C1].

Criterion 4 - Centre des interets economiques (centre of economic interests): Your principal investments, business management functions, or income sources are located in France. A retired individual deriving the majority of their income from French-source pensions or French securities may satisfy this criterion even without a physical presence in France [C1].

2025 treaty override amendment: The Finance Act 2025 added an express provision to Article 4B: a person who is not treated as a French resident under an applicable bilateral tax treaty cannot be regarded as fiscally domiciled in France for domestic-law purposes, even if one or more of the four criteria above are satisfied. In practice this means a dual-residency analysis now follows a three-step sequence: (i) test Article 4B criteria, (ii) apply the treaty tie-breaker, (iii) accept treaty residence as determinative [C2].

How are French tax residents taxed on income?

French tax residents are subject to income tax (impot sur le revenu) on their worldwide income under Article 4A CGI. Tax is computed on the foyer fiscal as a whole using the quotient familial system - total household income divided by the number of household shares - before progressive rates are applied [C3].

For the 2025 tax year (income declared in 2026), the progressive rate schedule per household share is as follows [C3]:

Beyond the progressive scale, two additional levies apply to higher incomes. The Contribution Exceptionnelle sur les Hauts Revenus (CEHR) adds 3% on reference taxable income between EUR 250,001 and EUR 500,000 for a single filer (EUR 500,001 to EUR 1,000,000 for couples) and 4% on income above EUR 500,000 for a single filer (above EUR 1,000,000 for couples) [C3]. A Contribution Differentielle sur les Hauts Revenus (CDHR), introduced from 2025, ensures that resident taxpayers with adjusted taxable income above EUR 250,000 (single) or EUR 500,000 (couple) face a minimum effective rate of 20% across all applicable levies [C3].

Social levies (prelevements sociaux) apply on top of income tax. Employment income carries a combined rate of 9.7% (CSG 9.2% plus CRDS 0.5%). Capital income - dividends, interest, capital gains - carries a higher combined rate of 17.2%, making the flat tax (prelevement forfaitaire unique) on financial income 30% overall (12.8% income tax plus 17.2% social levies); effective January 2026 the flat tax rate has risen to 31.4% following a social-levy increase [C3].

What exemptions apply to inbound expats under Article 155B CGI?

The regime des impatries, codified in Article 155B CGI, provides a partial income tax exemption for individuals who take up employment in France after a period of non-residence. To qualify, a person must (a) have been tax resident outside France for at least five full calendar years immediately preceding the year in which they begin French duties, and (b) take up the position through direct recruitment from abroad by a French-resident entity, or through intra-group secondment from a non-French entity within the same corporate group [C4].

Three exemptions are available. The prime d'impatriation - the additional compensation attributable to the French posting - is fully exempt from income tax; where no explicit prime is paid, a lump-sum forfait of 30% of total gross compensation may be substituted. Compensation for work days physically performed outside France for the employer is also exempt. Finally, 50% of qualifying foreign-source passive income (dividends, interest, royalties, and capital gains on foreign securities) is excluded from the French tax base for the duration of the regime [C4].

The benefit runs from the year duties begin until 31 December of the eighth calendar year following that year and cannot be reused after a departure and return. For further context see the France country overview.

How are non-residents taxed on French-source income?

Non-residents remain subject to French income tax solely on French-source income under Article 4A CGI. Taxable French-source income includes property income, professional activity income from work carried out in France, capital gains on French property, and pensions from French-based funds [C5].

A minimum rate of 20% applies on French-mainland-source income up to EUR 29,579; income above that threshold carries a minimum rate of 30% (2025 figures). The taxpayer may elect the average rate - computed by reference to worldwide income - where that produces a lower result [C5]. Salaried income is withheld at source by the employer at 0%, 12%, or 20% depending on the income band; an annual Form 2042-NR reconciles the final liability. Social levies of 17.2% apply to investment income from French sources.

Tax treaties may reduce or eliminate these rates on specific income categories. A qualified professional should verify whether a bilateral convention modifies the domestic treatment before filing. To find a vetted practitioner, browse the France tax-pros directory.