In summary…
Article 15 of Protocol No. 7 refers to regulations that will define the categories of officials concerned, and the names will be communicated to governments. The French tax administration website describes the officials in question as permanent staff employed full-time for at least one year, and excludes trainees, temporary staff, and experts on assignment. Your precise status will therefore be confirmed in writing with your institution.
Civil servant, temporary agent, contract agent, agency agent, seconded expert: the titles vary from one institution to another. For tax purposes, only one point matters: do you belong to a category covered by Protocol No. 7?
Here is the text, the reading from the French administration, and the list of checks to be carried out.
1. What the Protocol provides
Article 15 of Protocol No. 7 provides that the categories of officials and other agents to whom the articles of the Protocol apply shall be determined by regulation. The names of the persons concerned shall be communicated to the governments of the Member States.
Tax privileges, including the retention of domicile under Article 13 (see our article), therefore, only apply to the categories thus defined.
2. Reading the French tax administration
Its page dedicated to staff of international organizations and European institutions describes the staff concerned as permanent staff employed full-time for at least one year. It excludes trainees, temporary staff and experts on assignment.
3. Why a status is not enough
The same word does not mean the same thing everywhere: "temporary agent" refers to one type of contract within one institution, and "contractual agent" to another. We were unable to find, in the official sources consulted, a detailed list of the categories covered by the regulations issued pursuant to Article 15. This is why we never state "you are covered" based solely on a job title.
One point to keep in mind: the ruling of October 15, 2026 (see the article on the decision) concerned an agent of the European Investment Bank, which shows that the scope of Article 13 is not limited to the main institutions. This does not constitute a general rule for all agencies.
4. Fictional example: Léa, a contract worker
Situation. Léa, a French national, is a contract agent in a Union agency in Luxembourg. Her contract lasts three years, full time.
Issue. Her family tells her that only "real civil servants" keep their homes in France. She doesn't know if that applies to her.
Strategy. She requests four written confirmations from her institution: her agent category, the date of commencement of duties, the duration of her contract and the applicable regulations.
Result. Four written answers. They determine whether she organizes her assets as a person domiciled in France (article 13) or otherwise.
This is an illustrative example; it does not reflect the situation of any particular client.
5. The four questions to ask your institution
- Which category of agents do I belong to?
- On what date did I take office?
- What is the duration of my commitment and my activity rate?
- Is my name among the agents disclosed to governments under Article 15?
Frequently asked questions
Can an intern maintain their tax residence in France?
The administration page excludes trainees. Their address is then determined by the ordinary rules.
Is a seconded expert covered?
The administration's page excludes experts on assignment. Their case is handled according to the ordinary rules and the applicable tax treaty.
My status changes during my career: what happens?
Each change of contract or category must be confirmed again with the institution. Keep all successive confirmations.
You don't know which category you're in.
We start with your contract and the written response from your institution, then we organize your assets accordingly.
Are you a tax lawyer, notary, or chartered accountant, and do some of your clients work for a European institution? We can work in partnership on the investment and life insurance aspects, in conjunction with your tax analysis.
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Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 27/10/2026.
