Impatriates: conditions of the article 155 B regime

The expatriate tax regime under Article 155 B of the French General Tax Code (CGI) applies to employees, or equivalent managers, who come to work for a company established in France after five calendar years without a tax residence in France. It runs until December 31st of the eighth calendar year following the start of employment. The start date is the date the contract begins to be performed, not the date of signature. The eligibility requirements are verified before arrival.

This page follows the BOFiP (BOI-RSA-GEO-40-10-10, version of 11/08/2025, and BOI-RSA-GEO-40-10) and the administration's page updated on 08/04/2026. It does not state whether a recent finance law has amended article 155 B: this must be verified at the source.

The four conditions to be met

The five-calendar-year rule

The BOFiP (Official Bulletin of Public Finances) targets individuals who were not domiciled in France "during the five calendar years preceding the year they took up their duties." Nationality is irrelevant: a French citizen can benefit. If a tax treaty applies, the relevant factor becomes residence as defined by the treaty.

Two practical points. The window starts from the year of taking up duties: for taking up duties in 2027, the years to be examined are from 2022 to 2026. And taking up duties is the effective execution of the employment contract or corporate mandate: signing in December does not start the window.

Who can come: four possible entrances

The employee was hired by a foreign company. He was working outside of France and is coming to France to work for a French company linked to his original employer (through capital, legal, or commercial ties), for example, the secondment of a foreign parent company to its French subsidiary. The host company must be established in France and, on the date of his appointment, constitute an existing legal entity: a permanent establishment, branch, or liaison office. It may not yet exist if the move to France is for the purpose of its creation.

The employee recruited directly from abroad. At the time of hiring, the individual may be employed abroad, self-employed, or unemployed, such as a student entering their first job. The contract may be fixed-term or open-ended.

The assimilated leader. The BOFiP treats as employees the managers of article 80 ter of the CGI, in particular: chairman, chief executive officer, deputy chief executive officer and members of the management board for a SA or a SAS; minority or equal managers for a SARL; managers subject to the tax regime of employees in other companies subject to IS.

The one who returns to his former employer. Individuals returning to work for the French company that employed them before their departure, or for another French company within the group, are eligible for the scheme. All conditions apply, including the requirement of five years without a residence in France. Termination, suspension, or modification of the contract during the expatriation period does not affect eligibility for the scheme.

Coming of one's own initiative: the case that excludes

The scheme does not apply to individuals who came to work in France of their own volition, nor to those already residing in France at the time of recruitment. A candidate who applied for a job in France from abroad is still considered to have been recruited from abroad, provided the other conditions are met.

The employee must be able to demonstrate that their actual residence was abroad at the time of recruitment. The BOFiP (French Official Tax Bulletin) specifically mentions supporting documents for contacts with the company; the complete list of required documents can be found in paragraph 90.

Home or main residence, and main activity in France

The scheme applies to those who have their home or principal residence in France and who primarily carry out their professional activity there. If the individual resides in more than two countries during a year, France is considered their principal residence when the duration of their stay in France exceeds that of each of the other countries. In the case of multiple activities, the principal activity is the one to which the individual devotes the most actual time; failing that, the one that generates the largest share of their worldwide income (BOFiP, paragraph 190).

Excluded are: employees who work in France without having a home or main residence there; those whose tax domicile is based on other criteria of domestic law, such as the sole center of economic interests; state agents serving abroad; those whom a tax treaty does not consider to be residents of France.

Every year counts, but a missed year doesn't erase the others.

The conditions of primary residence or place of residence and primary activity are assessed each year of application. If these conditions are not met in a given year, the scheme does not apply that year. Prior and subsequent years are not affected. The duration is still calculated from the initial start date of employment.

The BOFiP (French Official Tax Bulletin) allows a reasonable period of a few months between taking up a position and setting up a household. If the household is set up in the same year as taking up a position or the following year, the exemption from income tax applies from the date of taking up the position (excluding passive income and capital gains). If it is later, the benefit is claimed from the year in which the condition is met.

Duration of the scheme: until December 31 of the eighth year

Example from the administration: taking up a position on January 1, 2025, opens the scheme until December 31, 2033. Beyond that date, the exemptions already obtained remain valid. Salary and passive income become subject to standard tax rules, including income received outside of France.

Changing jobs or employers. A change of duties does not extend the duration of the scheme. The scheme remains in effect in the event of a change of duties within the company, and a change of company within the same group. The group is defined by control as defined in Article L. 233-3 of the French Commercial Code: control is presumed when one person holds more than 40% of the voting rights and no other shareholder holds more. The government website indicates that the scheme ceases upon departure from the host company.

What the regime grants, in short

Each benefit has its own page. According to the administration: exemption from the expatriation bonus and the portion of remuneration linked to activity abroad; exemption of 50% of certain passive income and capital gains from foreign sources, subject to conditions relating to the tax treaty (details on the administration's page); deduction of certain pension and insurance contributions taken out before arrival; taxation of assets located in France limited to assets until December 31 of the fifth year following installation; the possibility of requesting not to be affiliated with French pension schemes (article L767-2 of the social security code).

No prior request

The regime applies automatically, without approval. A formal ruling can be requested from the tax authorities (ruling, articles L.80 A and L.80 B of the tax procedures book).

Five-year window and eight-year term: numerical example (fictitious profile)

Situation. Marc, a fictitious engineer of French nationality, had his last tax residence in France in 2021. A company in Lyon recruited him from abroad, contract signed at the end of 2025. Two effective start dates are envisaged: 2026 or 2027.

Issue. Is Marc within the five-year calendar year window, and until when would the regime run?

Strategy. Start from the effective date of the contract, not the date of signature. List the five preceding calendar years, find the last year of residence in France, and calculate the term. The other conditions still need to be verified.

Result.

With a start date in 2027, the scheme could apply to 9 calendar years, From 2027 to 2035 (including the year of appointment), if the annual conditions are met. This calculation is based on dates only. The profile is fictitious.

What changes depending on your specific circumstances of repatriation

• Your status: employee called in by a group, recruited from abroad, assimilated manager, former employee returning.
• Your last year of tax residence in France and the effective date of the contract.
• A tax treaty that defines your residence.
• The date of your family's move.
• A change of employer or duties during the period.
• The date of your appointment in relation to July 6, 2016.

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