Guide to France’s inpatriates regime

Article 23 of the law n° 2003-1312 of 30 December 2003 introduced the inpatriates regime in French legislation.

The regime was then modified by article 121 of the law n° 2008-776 of 4 August 2008.

The inpatriates regime is a favourable tax scheme designed to help attract foreign employees and corporate executives to France by providing partial income tax exemption on employment income and investment income and capital gains.

Scope

Article 155 B of the French Tax Code (FTC) provides that the inpatriates tax exemptions are available to employees and executive officers who are recruited from abroad either through a company established abroad or directly by a company established in France.

The inpatriate’s tax exemptions apply automatically when the relevant conditions are met and are not subject to prior approval.

a) French residency

The inpatriates regime applies to individuals who were not residents of France for...