In summary…
A sales representative responsible for developing export sales, residing in France, is exempt from income tax if they spend more than 120 days abroad over a 12-month period, actively engaged in prospecting international markets. Below this threshold, only salary supplements related to these stays are exempt, up to a limit of 40% of their base salary excluding supplements.
The 120-day threshold is a variation of the 183-day rule. It targets salespeople whose work involves international transactions. The BOFiP (Official Bulletin of Public Finances) details the expected profile, and the 2021 ministerial response outlines the supplementary allowance scheme.
1. Conditions for total exemption
- You have a commercial role related to export or international development.
- You are carrying out concrete prospecting activities outside of France.
- You spend more than 120 days abroad over 12 consecutive months.
The days are counted as in the 183-day rule: from the first departure to the last return, subtracting the days spent in France. Details are in the article on the employee posted abroad.
2. Within 120 days: partial exemption from surcharges
An employee who does not reach the threshold may be exempt from tax on salary supplements related to their stays. The conditions are cumulative:
- the stays are undertaken in the direct and exclusive interest of the employer;
- Each stay lasts at least 24 hours;
- The supplements are fixed in advance, in relation to the number, location and duration of stays;
- they do not exceed 40 % of the remuneration excluding supplements.
3. A numerical example
This is an illustrative example; it does not reflect the situation of any particular client.
Situation
An export manager spends 105 days abroad over 12 consecutive months. Their salary, excluding bonuses, is €60,000.
Issue
It does not reach 120 days. He is therefore ineligible for full exemption.
Strategy
He checks that his supplements meet the four conditions: employer interest, stays of at least 24 hours, amount fixed in advance, ceiling.
Result
The limit is 40 % × €60,000 = €24,000 of tax-exempt supplements. However, with 135 days abroad, the 120-day threshold would be exceeded by 15 days, and full exemption could apply.
4. To go further
Other situations involving mobile personnel are addressed in the articles on the Merchant mariner on a RIF ship and on the fisherman: exemption of 40 % or 60 %.
Frequently asked questions
How does this differ from the 183-day rule?
The 183-day rule applies to listed activities: construction sites, extraction, and RIF navigation. The 120-day threshold applies to international market prospecting.
How is the 12-month period calculated?
As with the 183-day rule: on a rolling basis, from the first departure to the last return, days spent in France are deducted.
Are there a limit on the tax-exempt supplements?
Yes. They do not exceed 40 % of the remuneration excluding supplements.
What should be kept?
Supporting documents for your stays abroad, to establish the calculation of days and the conditions for supplements, to be produced at the request of the administration.
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Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 27/10/2026.
