Main professional activity and tax residence: when the activity establishes residence in France

You are considered a tax resident of France if you primarily carry out your professional activity there. Only one of the three criteria in Article 4 B is required: this is criterion b of paragraph 1 of that article. The primary activity is the one that occupies the most actual time. If time alone is insufficient to determine this, the BOFiP (French tax authority) considers the proportion of income.

This page addresses the criterion of professional activity as explained in the BOFiP (BOI-IR-CHAMP-10, version in effect since 28/07/2016). It does not discuss the household or the center of economic interests in detail, nor the text of Article 4 B of the French General Tax Code (CGI). It does not resolve any borderline cases beyond what is stated in the BOFiP.

The principle: one criterion out of three

The tax authorities use three alternative criteria: personal, professional, and economic. According to the BOFiP (Official Bulletin of Public Finances), "it is sufficient for one of the criteria to be met" (BOI-IR-CHAMP-10, paragraph 310). The professional criterion applies to individuals who carry out a professional activity in France, whether salaried or not, unless they can demonstrate that it is carried out there on an ancillary basis (paragraph 170).

Three official fact sheets from 2026 include this rule: impots.gouv.fr (page modified on 27/01/2026), service-public.gouv.fr (fact sheet F62, verified on 01/01/2026) and economie.gouv.fr (page of 24/04/2026).

How do we determine the main activity?

The actual time first

When you carry out several activities, or the same activity in several countries, your main activity is the one to which you devote the most actual time (BOI-IR-CHAMP-10, paragraph 220; formula used on impots.gouv.fr and service-public.gouv.fr). You are then considered domiciled in France if this activity is carried out in France.

Then, the income, failing that

If the time criterion cannot be applied, the BOFiP (French Official Tax Bulletin) considers the activity that generates the largest share of worldwide income (paragraph 220). For the BOFiP, income is therefore only taken into account when the time criterion cannot be applied. Fact sheet F62 on service-public.gouv.fr states the rule with an "or" between actual time spent and the majority of income: this difference in presentation between sources should be verified with the official source.

Do not confuse this point with the third criterion of Article 4 B, the center of economic interests. This refers in particular to the country from which you derive the majority of your income (BOI-IR-CHAMP-10, paragraphs 230 and 250). The impots.gouv.fr website presents it as follows: income from French sources exceeding income from foreign sources. Both criteria exist side by side, and only one is required.

Depending on your status

For seconded employees and state agents serving abroad, the BOFiP refers to another doctrine (BOI-RSA-GEO-10, 20 and 30), which this page does not detail.

The BOFiP also cites cases decided by the Council of State. A self-employed representative working exclusively outside France was not considered to be carrying out any activity in France. Similarly, a foreign national representing a foreign company, who only stayed in France for 65 to 70 days a year, was also not considered to be carrying out any activity in France (paragraph 210). These are specific rulings, not general thresholds. Do not apply them to your case without careful analysis.

If two countries consider you a resident

When a tax treaty applies, the treaty's definition of resident takes precedence over the definition of domestic tax domicile (BOI-INT-DG-20-10-10, paragraph 40, version of 12/09/2012). For dual domicile, the BOFiP (French Official Tax Bulletin) applies the following criteria in order: permanent home, closest personal and economic ties, habitual residence, and then nationality (paragraph 60). Paragraph 60 does not include professional activity. The rule is interpreted on a treaty-by-convention basis.

A non-resident for tax purposes is taxable in France only on their French-source income, subject to agreements (economie.gouv.fr).

Main activity and tax residence: numerical example (fictitious profile)

Situation. Nadia, a consultant, is based abroad. She provides the same consulting services to clients in France and to international clients. Over the course of a year, she dedicates 1,800 hours to her work. Assumption: the hours are counted according to the country where she actually works, not according to the location of her clients.

Issue. Is its main activity in France, within the meaning of paragraph 220 of the BOFiP?

Strategy. Compare the actual time spent by country, without looking at income as long as time allows for a conclusion.

Result.

In scenario A, the professional criterion is not met. In scenario B, it is: a single criterion is sufficient for Nadia to be considered domiciled in France. Even in scenario A, the home and center of economic interests still need to be examined. Furthermore, a convention could alter the outcome.

This profile is fictitious. The figures illustrate the mechanism of effective time. They are not valid for a real case (calculation: 800 / 1800 = 44.4 %; 1100 / 1800 = 61.1 %).

Main activity and tax residence: what changes depending on your situation

• The nature of your business : salaried employee, corporate mandate, self-employed activity.
• The actual place of exercise : where you actually work, not where the client or headquarters are located.
• How you allocate your time between France and abroad over the entire year.
• The existence of a detachment and the place where your family lives.
• Your two other criteria : home or main residence, center of economic interests.
• The convention between France and your host country.

The rule depends on your situation. No results are guaranteed.