Exit tax, French tax residence, inbound regime

The firm’s work

Three situations

Arriving

Moving to France

Tax residence

Determining residence under French domestic law and under the applicable treaty, and securing the date from which you are taxed here.

The impatriate regime

Conditions of access to article 155 B of the French Tax Code, the scope of the exemption, and how it fits the compensation negotiated on hiring.

Foreign income and assets

Treatment of foreign-source income, of accounts, life insurance policies and trusts, and of the reporting obligations that come with them.

Leaving

Leaving France

Exit tax

Shareholdings within the scope of the charge, deferral of payment, guarantees, and the reporting that follows in each subsequent year.

Deferred compensation

Options, free shares, BSPCE and carried interest granted in France and realised from abroad, and the share France continues to tax.

Assets remaining in France

French real estate, shareholdings and rental income remain taxable in France: the move changes the rules that apply to them, not the connection itself.

Over a career

International careers and retirement

Cross-border compensation

Splitting compensation between the countries in which it was earned, for options, RSUs and carried interest held across several funds.

Foreign pensions

Anticipating retirement after an international career, and drawing down foreign pension arrangements, lump sums.

Reporting and past years

Foreign accounts, policies and structures that were never reported, and the terms on which past years can be regularised.

Global mobility, within the firm’s practices→

Client cases

Situations handled by the firm

Going further

Case studies

Frequently asked questions

When do I become a French tax resident?

As soon as one of the tests of article 4 B of the French tax code is met: home or main place of stay in France, main professional activity in France, or centre of economic interests in France. The tax treaty with your country of origin then settles cases of dual residence.

What is the inbound regime and who qualifies for it?

Article 155 B exempts, until the end of the eighth year following arrival, the inbound bonus and the share of remuneration corresponding to duties performed abroad, subject to conditions, for employees and directors called from abroad who were not resident in France during the five preceding years. It also exempts half of certain foreign-source investment income and capital gains.

How does France tax my US pension or 401(k)?

Under the France–US treaty, US-source pensions received by a French resident are in principle taxable in the United States and reported in France with a tax credit equal to the French tax. The treatment of withdrawals from a 401(k) or an IRA depends on the characterisation retained and is checked case by case.

Do I pay French real estate wealth tax on property held abroad?

A French resident is subject to the real estate wealth tax on worldwide real estate from €1.3m of net taxable assets, subject to treaties. Those who were not resident in France during the five preceding years are taxed on their French property only, until 31 December of the fifth year following their arrival.

What do I have to file in my first year?

The income tax return in the spring following arrival, covering income received from the date of residence, the return of accounts and contracts held abroad (forms 3916 and 3916 bis), and where applicable the real estate wealth tax return. The timetable for that first year is set with the firm on arrival.

Answers current as at 9 September 2026