France's **impatriate tax regime** offers special tax treatment for foreign employees recruited by French companies. This system is outlined in Article 155 B of the General Tax Code (CGI), introduced by Law No. 2008-776 of August 4, 2008, and later extended for eight years by Law No. 2016-1917 of December 29, 2016. The regime aims to help French employers attract talent from abroad by offering various tax benefits, such as exemptions on the **impatriation bonus**, salary portions earned abroad, and 50% of certain **capital income** and **capital gains** from the sale of securities. Additional benefits include the ability to deduct foreign pension contributions and exemptions from payroll tax for employers. To qualify, the individual must be financially assimilated to an employee under specific provisions of the CGI, including roles like chairman of the board or general director. The host company must be based in France, excluding public administrative entities. The individual must be recruited from abroad, either through **intragroup mobility** (moving within the same corporate group) or direct hiring overseas. Recent changes in 2025 allow applications from abroad to be considered direct recruitment and recognize returns from abroad, even after a previous French contract was suspended or ended, as long as the person was not a tax resident in France in the five years before returning. The tax benefits last until December 31 of the eighth year following the year of appointment in France. A change in job role within the same company or group does not extend the period but does not shorten it either. The benefits end if the employee leaves the company or group, even if they remain a tax resident in France. The **impatriation bonus** can be calculated either based on the actual amount or using a 30% flat rate of the net salary. Salary portions earned abroad can also be exempted, with a cap on the total exemption at 50% of the total salary or 20% of the bonus's net taxable salary. Recent court rulings have stressed the need for objective and verifiable data, such as anonymized **DSNs** (employee identification numbers), rather than vague certificates or press estimates, to justify the **reference salary**, which is a tax floor and not a requirement for eligibility. Employers benefit from reduced payroll tax on the impatriation bonus and lower net costs, while employees can opt out of mandatory French social security for pensions under specific conditions. Properties abroad are also exempt from the **Impôt de Solidarité sur la Fortune (ISF)**, a wealth tax, for a limited time, provided the individual was not a tax resident in France five years before moving abroad. Recent updates in 2025-2026 include extending the 30% flat rate to intragroup mobility, explicitly including candidates who applied from abroad, and excluding occasional sales of **cryptoassets** from the 50% exemption. The list of countries eligible for the 50% exemption on passive income has also been updated. Additionally, the regime now applies to **director shareholders** of the hiring company, without requiring a fixed-term contract or specifying employment duration in the contract.