French retirement: taxation of a non-resident, from withholding tax to the minimum rate

When a pension fund established in France pays you a pension while you live abroad, France may withhold tax at source on pensions taxable in France, in accordance with international tax treaties. According to impots.gouv.fr (page updated on 26/02/2026), the withholding tax applies to pensions of French origin taxable in France "in accordance with international tax treaties." The determining factor is the payer: a pension or life annuity whose payer is established in France. For 2025 income, the tax brackets are 0% up to €17,122, 12% from €17,122 to €49,667, and 20% above that amount, after a 10% allowance.

This page deals with pensions paid by a payer established in France to a person domiciled outside France. It does not specify in which countries pensions are taxed in France: the sources consulted refer to the applicable tax treaty, without country-specific rules. It does not address the distinction between private and public pensions, social security contributions or health insurance contributions, the pension scale for 2026, or the life certificate procedure (see the dedicated page).

Who is affected: the payer criterion

To determine whether a pension is of French origin, the location where the services were rendered is irrelevant. Tax doctrine states: "The country or territory where the services for which the pension is remunerated were rendered is irrelevant" (BOI-IR-DOMIC-10-10, version of 27/02/2019). What matters is the payer. According to the same BOFiP (Official Bulletin of Public Finances), income is of French origin when "the payer is domiciled in France or established in France.".

The withholding tax under Article 182 A of the French General Tax Code (CGI) applies, according to BOI-IR-DOMIC-10-20-20-10 (version of 28/12/2018), to "pensions, life annuities, and retirement benefits paid by a payer who is domiciled or established in France" to persons domiciled outside France. The March 2026 issue of the impots.gouv.fr website reiterates this wording: pensions or life annuities "when the payer is established in France.".

Two limitations to be aware of:

• The tax treaty. According to impots.gouv.fr, the withholding tax applies to pensions taxable in France under international tax treaties. This page does not specify the rules for each country.
• Non-residents "Schumacker"« (those who derive the bulk of their income in France) are exempt from these deductions, according to BOI-IR-DOMIC-10-20-20 (version of 13/06/2023).

Calculating the withholding tax for 2025 income

The withholding tax for non-residents is separate from the withholding tax for residents. It is collected by the pension fund.

This tax schedule is for 2025 income. The rates are different for income from the French overseas departments and regions (DOM), which is not covered here. The 2026 tax schedule is not included here: please check it before making any projections.

What happens to the three slices

• The tranches at 0 % and 12 % are dischargeable. The page states: "Income subject to the 0 % and 12 % brackets is a final tax." According to the BOFiP (French Official Tax Bulletin), the corresponding portion is not taxed according to the scale and the withholding is not creditable.
• The tranche at 20 % is charged. The withholding tax at the rate of 20 % "is directly deducted from your income tax." Only the portion subject to this rate is taxed according to the income tax scale.

The minimum rate and the average rate

Non-residents are taxed according to the progressive scale, with a minimum rate. The impots.gouv.fr page of 26/02/2026 and the fact sheet from the Directorate of Non-Resident Taxes (undated) set it as follows, excluding DOM: 20 % for a net taxable income up to €29,579 (income received in 2025), and 30 % above that.

One option exists: the average tax rate. The information sheet states that "it is possible to avoid the application of minimum tax rates by opting for the average tax rate." According to the page "How do I understand my tax notice?", this rate "will only apply to your French-source income taxable in France." The average tax rate is calculated on all your income, both French and foreign. You must be able to substantiate the income you declare. This option is only advantageous if the average tax rate is lower than the minimum tax rate, which depends on your worldwide income.

The boxes to know on the declaration

The impots.gouv.fr website indicates that pensions are declared in sections 1AL and following of form 2042. Withholding tax for non-residents is generally pre-filled in box 8TA ("Withholding tax for non-residents levied in France"). This should not be confused with the boxes for withholding tax for residents.

Several pension funds: regularization

Each payer applies the tax scale to their own payments, without taking others into account. The page states: "Each payer applies withholding tax to the income they pay, without taking other income into account." An adjustment is then made in accordance with Article 197 B of the French General Tax Code (CGI).

The example on the page: two debtors pay €10,000 and €14,000 in pensions, after deductions. Each applies 0 % and deducts €0. The total of €24,000 exceeds €17,122 by €6,878; at 12 %, the deduction amounts to approximately €825, which is adjusted. If you receive pensions from several funds, the total is considered, not each individual payment.

If the withholding exceeds the tax calculated at the average rate, the page "How to understand my tax notice?" states: "You can request a refund of the excess withholding tax taken from your wages or pensions".

French pension for a non-resident: a numerical example (fictitious profile)

Situation. Hélène, a hypothetical retiree, resides outside of France. A pension fund established in France pays her a gross pension of €40,000 for the year 2025. Assumptions: the applicable tax treaty allows France the right to tax this pension; the pension is paid by a single payer throughout the year; Hélène has no other income from French sources.

Issue. What deduction does the fund make, and is it final?

Strategy. Apply the 10% % allowance, then the withholding tax scale. Compare with a pension of €70,000 to see the 20% % bracket.

Result.

For €40,000, the withholding of €2,265.36 is entirely final: no portion reaches the 20 % tax bracket. For €70,000, the withholding of €2,666.60 on the portion reaching the 20 % tax bracket is credited against income tax.

This profile is fictitious. It illustrates the mechanism of the 2025 tax scale. It says nothing about the country of residence, the tax due in that country, or the applicable tax treaty.

French pension for a non-resident: what changes depending on your case

• The agreement between France and your country of residence : it decides whether the pension is taxable in France.
• The payer's identity : a debtor established in France or not.
• The number of cash registers : the deductions are calculated cash register by cash register, then adjusted.
• Your global income level : it determines the attractiveness of the option for the average rate.
• Your non-resident status «Schumacker», if the majority of your income is in France.
• The year of perception : the scale consulted is that of 2025 income.

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