FlagSageKey facts
| Tax basis | Residence-based |
|---|---|
| Tax year | 1 January to 31 December |
| Taxes citizens abroad | Not as a general rule |
| Residence tests recorded | 3 |
| Region | Europe |
How France decides tax residence
Each test is recorded separately with its own ID. Meeting or missing one test does not settle residence on its own.
Home (foyer) or principal place of stay
The foyer is the place where a person normally lives, provided it is permanent; professional travel does not necessarily change it if the family keeps living there. The principal place of stay looks at physical presence. Tax guidance says people who stay in France more than six months in a year are normally treated as having their principal stay there, but the six-month rule is not an absolute criterion and the overall circumstances are considered.
Professional activity in France
A person who carries on a professional activity in France, employed or self-employed, has a French tax domicile unless that activity is ancillary. Where a person has several activities, guidance looks first at where they spend the most actual time, and if that does not decide, at where most of their worldwide income comes from.
Centre of economic interests
A person also has a French tax domicile if the centre of their economic interests is in France. Guidance places it where the person made their main investments, has the seat of their affairs or manages their assets, or where they have the centre of their professional activity or earn most of their income.
Arriving, leaving and part years
On departure, article 167 bis of the General Tax Code (exit tax) can tax unrealized gains for a person who was a French tax resident for at least six of the ten years before the transfer and holds shares, securities or rights worth at least €800,000 in total or representing at least 50% of a company's profits. Article 4 B also treats some French state agents working abroad as French tax domiciled where the host country does not tax their total income (relates to FR-RES-01 to FR-RES-03).
Reporting duties to check
- Foreign accounts (form 3916 / 3916 bis). Accounts opened, used or closed abroad during the year are declared with the income tax return on form 3916 / 3916 bis, with limited exceptions set out by the tax authority. Source
- Exit tax declaration (form 2074-ETD). Unrealized gains under article 167 bis are declared on form 2074-ETD for the year of transfer, followed by tracking declarations in later years. Source
Social security
Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.
Living base
EU citizens can move to France under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a long-stay visa or residence permit. A visa or permit does not decide tax domicile, which follows article 4 B of the General Tax Code.
How visas, permits and tax residence differ
Citizenship
Naturalisation by decree generally requires at least 5 years of residence in France, reduced to 2 years in listed cases such as a French higher-education diploma after 2 years of study, with no minimum for some groups such as refugees; the applicant must live in France with their main material and family ties there when the decree is signed. Service-Public states that a person can hold several nationalities and that French law does not require a foreigner who becomes French to give up their original nationality.
Questions to take to a professional
- Where is my foyer, and would my pattern of stays be treated as a principal stay in France?
- Is any professional activity I carry on in France ancillary, or is it my principal activity?
- Where is the centre of my economic interests, given my investments and sources of income?
- If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?
- Could the exit tax under article 167 bis apply to my holdings if I leave, and what payment deferral rules apply?
- Which foreign accounts do I need to declare on form 3916 / 3916 bis?
Official authorities
Sources
- Article 4 B - Code général des impôtsPrimary law
- IR - Champ d'application et territorialité - Personnes imposables et domicile fiscal (BOI-IR-CHAMP-10)Official guidance
- Je quitte la France, suis-je concerné par l'Exit Tax ?Official guidance
- Dois-je déclarer mon compte Paypal ou un compte bancaire ouvert à l'étranger ? Et si oui, comment ?Official guidance
- Naturalisation française par décretOfficial guidance
- Can we have several nationalities in France?Official guidance
- Social security cover abroad - Your EuropeOfficial guidance
Other countries in Europe
- Countries covered
- France
- Sources
- 7 sources listed above
- Tax year
- Current rules as checked
- Review
- Not professionally reviewed
Sources checked November 8, 2026