In summary…
An employee domiciled in France and seconded abroad by their employer may be exempt from income tax in two ways: either the tax paid abroad reaches at least two-thirds of the French tax on the same basis, or they work more than 183 days over 12 consecutive months in a listed activity (construction site, natural resource extraction, RIF navigation). Cross-border workers and civil servants are excluded from the second exemption.
Article 81 A of the French General Tax Code (CGI) governs the exemption of employees sent abroad. The BOFiP (Official Bulletin of Public Finances) describes this exemption in two ways. Two options are available to the employee.
1. First option: taxes paid abroad
Income tax paid abroad must be at least two-thirds of the French tax paid on the same basis. Proof of this is provided by a certificate from the employer and an official document from the foreign tax authorities.
For a posting of several years in the same country, French tax can be deferred until December 31 of the following year, provided that justification is given for the previous year.
2. Second option: an activity listed for more than 183 days
No proof of foreign tax payments is required. You must have worked abroad for more than 183 days over 12 consecutive months in one of the following activities:
- construction or assembly sites, installation and commissioning of industrial units, and related engineering;
- the search for or extraction of natural resources;
- navigation on board commercial vessels registered with the RIF or the Wallis and Futuna register.
Subcontractor staff are eligible if their work is directly related to the client's eligible activity, on the same site. Cross-border workers and civil servants are excluded.
3. How to count the days
The calculation runs from the first departure to the last return. Days spent in France, or in the employer's country of residence, are deducted. Weekly rest periods, paid leave, and sick leave related to the posting count as time spent abroad. The calculation is rolling when the period spans two years.
4. An example of a count
This is an illustrative example; it does not reflect the situation of any particular client.
Situation
A commissioning engineer is seconded to an industrial site abroad. From the first departure to the last return, 260 days elapse.
Issue
He returns to France between two rotations: 35 days in total.
Strategy
He deducts the days spent in France and keeps the supporting documents for his travel along with the certificate from his employer.
Result
260 − 35 = 225 days counted. The 183-day threshold is exceeded by 42 days: the second option applies, without proof of foreign tax.
5. If neither of the two paths applies
The employee may still be eligible for a partial exemption from salary supplements related to their stays. The case of a export sales details it. For flight crew, see the Merchant mariner on a RIF ship and the fisherman: exemption of 40 % or 60 %.
Frequently asked questions
Can cross-border workers invoke the 183-day rule?
No. The BOFiP excludes cross-border workers and civil servants from this option.
What documents prove the two-thirds rule?
A certificate from the employer and an official foreign document establishing the tax paid.
Does a secondment of several years pose a problem?
For a posting of several years in the same country, French tax can be deferred until December 31 of the following year, provided that justification is given for the previous year.
Can a self-employed person benefit from it?
The BOFiP excludes self-employed workers from the list of activities.
Are you an employee working abroad and want to structure your savings?
A detachment changes the taxation of your income. We will work with you to determine what to invest, where, and how.
Are you a tax lawyer, notary, or chartered accountant, and do some of your clients include seafarers, crew members, or employees seconded abroad? We can work in partnership with you on the investment and life insurance aspects, in conjunction with your tax analysis.
Book an appointment
A 30-minute exchange is enough to lay out your situation. Book a time slot.
Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 27/10/2026.
