A British passport no longer carries a right to live or work in France. If you have accepted a French job, an intra-group posting from London or a first contract with a company that actually has a seat or an establishment in France, two files sit on the same desk and they are not the same. The residence card — talent, salarié (employee) or another mention — is an immigration file. The régime des impatriés (impatriate tax regime) in article 155 B of the code général des impôts (CGI, the French tax code) is an income-tax file. One can succeed while the other fails. A consulate stamp does not create the exemption. A payroll code on the déclaration sociale nominative (DSN, the employer’s monthly social-data return) does not replace a residence card.
This note is for the British employee, or the director taxed as an employee, who is moving from the United Kingdom after Brexit and needs to know three practical things: whether article 155 B actually applies; what part of pay, foreign dividends or share gains can be left out of French income tax and for how many years; and what to do if the employer never coded the exemption, if the pre-filled 2042 return shows the full salary, or if a proposition de rectification (proposed reassessment) arrives. It is not a guide to buying French property, to creating a company, or to working in France on a visitor card. Those routes are different, and a visitor card still does not authorise work.
The regime is temporary, tightly conditioned and often misunderstood. It does not wipe out contribution sociale généralisée (CSG, a French social contribution on income) by itself. It does not last as long as some recruiters say. It does not rescue a person who already moved to Paris and only then started applying for jobs. Used on its proper facts, with the contract, the DSN and the 2042 aligned, it is one of the few statutory tools that still cuts the French tax on a UK arrival. Used on the wrong facts, it is a classic source of reassessment, late-payment interest and a 10 per cent surcharge.
I. Do I qualify for the French impatriate tax regime after moving from the UK?
A. What conditions must a British employee meet under article 155 B?
Article 155 B I.1, in force since 31 December 2018, opens with a closed list of people and a closed list of conditions: “Les salariés et les personnes mentionnées aux 1°, 2° et 3° du b de l’article 80 ter appelés de l’étranger à occuper un emploi dans une entreprise établie en France pendant une période limitée ne sont pas soumis à l’impôt à raison des éléments de leur rémunération directement liés à cette situation ou, sur option, à hauteur de 30 % de leur rémunération.” In English: employees, and the company officers listed in article 80 ter b, 1° to 3° of the CGI (chair of the board who runs the company, managing director, management-board members, minority managers of an SARL, and similar officers taxed as employees), called from abroad to take up employment in a business established in France for a limited period, are not taxed on the elements of pay directly linked to that situation or, on option, on 30 per cent of their pay.
Two further filters sit in the same paragraph. First, the person must not have been fiscally domiciled in France during the five calendar years preceding the year in which the functions start. Second, the relief lasts “jusqu’au 31 décembre de la huitième année civile suivant celle de cette prise de fonctions, au titre des années à raison desquelles ils sont fiscalement domiciliés en France au sens des a et b du 1 de l’article 4 B”. Until 31 December of the eighth calendar year after the year of taking up the post, and only for years in which the person is fiscally domiciled in France within the meaning of article 4 B, 1 a and b of the CGI. A start date of 1 January 2025 therefore runs, if the other conditions hold each year, to 31 December 2033. That is the current statutory clock. Older judgments still speak of a fifth year; those passages apply to the text then in force, not to a 2026 arrival.
Domicile fiscal (tax domicile) is not the same as a utility bill. Article 4 A of the CGI states: “Les personnes qui ont en France leur domicile fiscal sont passibles de l’impôt sur le revenu en raison de l’ensemble de leurs revenus.” Persons who have their tax domicile in France are liable to income tax on all their income. Article 4 B, 1 a then treats as so domiciled “Les personnes qui ont en France leur foyer ou le lieu de leur séjour principal”; 4 B, 1 b treats as so domiciled those who carry on a professional activity in France, employed or not, unless they show that the activity is only accessory. The foyer (home) is the place where the taxpayer normally lives and has the centre of family interests. The Conseil d’État (French supreme administrative court), 9th and 10th combined chambers, 21 June 2022, no. 449408 recalled that the home is “le lieu où le contribuable habite normalement et a le centre de ses intérêts familiaux, sans qu’il soit tenu compte des séjours effectués temporairement ailleurs en raison des nécessités de la profession ou de circonstances exceptionnelles”, and that the place of principal stay only decides tax domicile if the person has no home. A British employee who keeps a house in Surrey, leaves a spouse and children there, and rents a weekday flat in Paris, is not in the same position as a family that has actually moved. Article 155 B does not apply to a year in which you are not fiscally domiciled in France under 4 B a and b. It also does not apply if a tax treaty treats you as resident only of the United Kingdom: article 4 B, 1 last sentence now says that persons who meet a domestic test “ne peuvent toutefois pas être considérées comme ayant leur domicile fiscal en France lorsque, par application des conventions internationales relatives aux doubles impositions, elles ne sont pas regardées comme résidentes de France”.
The France–United Kingdom convention of 19 June 2008, published by decree no. 2010-20 of 7 January 2010, still governs that residence tie-break. Article 4 of the convention, in the official English text on GOV.UK, looks first to a permanent home, then to the centre of vital interests, then to an habitual abode, then to nationality. Article 15 (income from employment) then provides: “salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.” A British employee who is a French resident under the treaty and who works in France is therefore in the French tax net on that employment. Article 155 B is the domestic relief that can then reduce the French charge. It is not a treaty credit, and it does not stop the United Kingdom taxing UK workdays if UK law still reaches them.
Who is “called from abroad”? The statute does not require a fixed-term contract. The public guidance of the direction générale des Finances publiques (DGFiP, the public-finance directorate), last modified on 8 April 2026, is explicit: the regime is not conditional on the contract or an amendment stating the duration of the French employment, nor on a fixed term. Two recruitment routes are accepted. Intra-group mobility: a UK employer with capital, legal or commercial links sends you to a French company in the same group. Direct hire: a business established in France recruits you while you are still abroad. The current official commentary, BOI-RSA-GEO-40-10-10 of 11 August 2025, paragraph 80, adds a remark that matters for British candidates who answered a LinkedIn or careers-page advert: “Sont néanmoins considérés comme étant directement recrutés à l’étranger par une entreprise française établie en France les salariés ou dirigeants recrutés après avoir postulé, depuis l’étranger, à une offre d’emploi en vue d’occuper des fonctions dans une entreprise établie en France.” Persons recruited after applying, from abroad, for a job in a French business are treated as directly recruited abroad. Paragraph 80 of the same commentary then draws the red line: “En revanche, les personnes venues exercer un emploi en France de leur propre initiative ou qui ont déjà établi leur domicile en France lors du recrutement ne peuvent pas bénéficier du régime.” People who came to work in France on their own initiative, or who had already established their domicile in France at the time of recruitment, are out.
That line is not a blogger’s gloss. The Cour administrative d’appel de Paris (Paris administrative court of appeal), 9th chamber, 10 June 2022, no. 20PA02279 had already refused to read “appelés de l’étranger” as a requirement that the French company take every initiative. The court held that the 30 per cent relief “n’ont pas pour objet, et ne sauraient avoir pour effet, en tant qu’elles réservent le bénéfice de cette exonération aux « salariés appelés de l’étranger », d’exclure du régime fiscal qu’elles instituent, les contribuables ayant, depuis l’étranger, postulé à une offre d’emploi publiée en France, ou recherché activement un emploi en France.” A Swedish developer domiciled in London in December 2015, who negotiated a Paris post with a French company and then moved, was in. The court added that a failure by the employer to flag impatriate pay on the annual social return, even if proved, “est sans incidence sur le droit que possédait M. C… de bénéficier de l’avantage fiscal litigieux.” The employee’s right does not die because payroll forgot the box.
The same paragraph of the statute requires an “entreprise établie en France” (a business established in France). BOI-RSA-GEO-40-10-10, paragraph 100, reads that as a seat or an establishment in France. A British employee who remains on a UK contract, works from a French kitchen table, and has no French host company, is not in article 155 B. That remote-work pattern raises other questions — tax residence, social security, and in some cases a French establishment of the UK employer — but those questions are not this exemption. Returning expatriates can come back into the regime after more than five full years abroad, if the five-year non-residence test is met and the French company calls them back. Changing roles inside the same French company, or moving to another French company in the same group as defined by article L. 233-3 of the commercial code, does not by itself restart or kill the eight-year clock: article 155 B I.1 says the benefit “est conservé en cas de changement de fonctions” for the remaining duration.
Immigration remains a separate gate. After Brexit, a British national needs a long-stay visa and then a residence card before taking up the job, unless a Withdrawal Agreement card already covers the stay. The talent card and the employee work authorisation are the usual routes. Article 155 B does not replace them. A visitor card still forbids work. Qualifying for the tax regime without a right to work is a paper victory.
B. What income is exempt, for how long, and what still stays taxable?
The heart of the regime is a temporary exemption from impôt sur le revenu (income tax), not a holiday from every French levy. Three layers sit in article 155 B I, and a fourth in article 155 B II.
Layer one is the impatriation supplement. The default is the actual extra pay “directly linked” to the move, which must appear distinctly in the employment contract, the corporate office or an amendment drawn up before the French functions start. The public page of impots.gouv.fr, updated on 8 April 2026, states that principle in those terms. If the extra is not carved out, or if you prefer a round figure, you may opt for 30 per cent of total pay. That option is now in the opening sentence of article 155 B I.1 for the employees and officers the article covers. It is not a free extra 30 per cent on top of a huge contractual bonus: you choose the actual supplement or the 30 per cent, and you then face the analogous-pay floor described below. Older case-law, including CAA Paris, 9th chamber, 28 September 2023, no. 22PA00640 on a Goldman Sachs transfer from London, applied a stricter pre-2019 wording that reserved the 30 per cent option to people who were not intra-group assignees. The current statute no longer contains the words “pour les salariés et personnes autres que ceux appelés par une entreprise établie dans un autre Etat”. A 2026 file must be read against the 2018 text, not against that older restriction.
Layer two is pay for work performed abroad, during the same eight-year window, if the trips are “effectués dans l’intérêt direct et exclusif de l’employeur” — made in the direct and exclusive interest of the employer (article 155 B I.2). Boarding passes, hotel bills and a mission letter are the usual proof. The official commentary accepts a working-days prorate and excludes mere travel days. Layer three is the statutory cap in article 155 B I.3: on option, either the exempt fraction under I.1 and I.2 is limited to 50 per cent of total pay, or the foreign-work exemption under I.2 is limited to 20 per cent of the pay that remains taxable after I.1. Article 155 B I.4 then shuts another door: “Les salariés et personnes mentionnés au présent I ne peuvent pas se prévaloir de l’article 81 A.” You cannot stack the impatriate regime with the separate exemption in article 81 A of the CGI for employees sent abroad from France.
The analogous-pay floor is the provision that most often turns a generous offer letter into a reassessment. The last sentence of article 155 B I.1 states: “Si la part de la rémunération soumise à l’impôt sur le revenu en application du présent 1 est inférieure à la rémunération versée au titre de fonctions analogues dans l’entreprise ou, à défaut, dans des entreprises similaires établies en France, la différence est réintégrée dans les bases imposables de l’intéressé.” If the slice of pay that remains taxable is lower than the pay for analogous functions in the same business or, failing that, in similar businesses established in France, the difference is added back. BOI-RSA-GEO-40-10-20, paragraph 110, repeats that the exemption of the bonus, or of the 30 per cent treated as the bonus, is conditional on that comparison. Paragraph 120 says the employee must be able to justify the comparison by any means and may produce an employer certificate. Paragraph 130 dates the reference pay to the calendar year of taking up the French functions, with a time-apportionment if needed. A British hire paid a large “impatriation” line while French colleagues in the same seat earn more on the taxable slice will see the exemption clawed back. That is not an anti-avoidance invention of the auditor; it is the statute.
What does not go into the 30 per cent base is as important as what does. The CAA of Versailles, 3rd chamber, 18 November 2021, no. 19VE02459 refused to treat a transactional termination payment as pay for this purpose. The court held that the payment, fixed by length of service and designed to compensate the loss of the contract, “ne saurait être regardée comme un élément de la rémunération, au sens et pour l’application de ces dispositions, lesquelles doivent s’interpréter strictement”, even though the sum was taxable as salary under article 80 duodecies of the CGI, and could not be built into the 30 per cent calculation. A British employee who leaves a French post in year three cannot assume that a settlement will still ride the impatriate percentage.
Article 155 B II then exempts, at 50 per cent, three families of foreign-source passive income during the period in which the person benefits from I: movable-capital income paid by a person established in a State that has a tax treaty with France containing an administrative-assistance clause; certain intellectual-property products in the same conditions; and gains on the disposal of securities where the custodian or, failing that, the company is established in such a State. Losses on those securities are recognised only at 50 per cent. UK dividends paid by a UK company, and gains on a UK share portfolio held with a UK custodian, are the usual British facts. The Conseil d’État, 8th and 3rd combined chambers, 21 October 2020, no. 442799 cancelled two paragraphs of the 2012 official commentary that had required the taxpayer, in the same year, actually to receive exempt activity pay under I before II could apply. The court held that the words “pendant la durée où ils bénéficient des dispositions du même I” “n’ont pas pour objet et ne sauraient avoir pour effet de subordonner leur application à la condition que le contribuable bénéficie effectivement, à raison de la rémunération d’activité qu’il perçoit de l’entreprise qui l’a appelé de l’étranger, de l’exonération prévue au I”, and merely set the same time limit as I. Paragraphs 80 and 90 of that commentary were annulled. Paragraph 20, which still required the person to meet the conditions of I, was left standing. A year with little or no impatriation bonus is not, by itself, a year in which UK dividends lose the 50 per cent.
Several levies sit outside article 155 B and are easy to confuse with it. CSG on activity income remains, in principle, due where article L. 136-1 of the code de la sécurité sociale (CSS, the social-security code) applies: persons who are both fiscally domiciled in France for income tax and covered, on any basis, by a compulsory French sickness-insurance scheme. The DGFiP impatriate page does not list a CSG exemption. A separate, non-tax exemption exists in article L. 767-2 of the CSS: employees called from abroad may, on a joint request with the employer, ask not to be affiliated to French basic and complementary old-age schemes, if they show a minimum old-age contribution paid elsewhere and have not been affiliated to a compulsory French old-age scheme in the five calendar years before the year of taking up functions, save for accessory, seasonal or study-related activity. The URSSAF director grants it once only, for three years, renewable once. It is not automatic, it is not CSG, and the uncovered period buys no French pension. Impôt sur la fortune immobilière (IFI, the real-estate wealth tax) has its own five-year newcomer rule in article 964, 1° of the CGI: a person who was not fiscally domiciled in France in the five calendar years before the year of becoming so domiciled is taxable only on French-situs real-estate assets, “jusqu’au 31 décembre de la cinquième année qui suit celle au cours de laquelle le domicile fiscal a été établi en France”. That clock is five years, not eight, and it does not require a French employment. Mixing the two durations in a spreadsheet is a frequent error.
Exempt pay still enters the revenu fiscal de référence (reference tax income). It can therefore affect means-tested thresholds even though it drops out of the income-tax scale. Payroll social charges, unless article L. 767-2 has been granted, continue to run on the usual base. The exemption is income tax, for a closed period, on identified items, if the analogous-pay floor is met. It is not a general “expat package”.
II. How do I claim the exemption and challenge a refusal or tax audit?
A. What must I and my employer declare, and which mistakes trigger a reassessment?
There is no magic impatriate form that you file at the airport. The claim is made on the annual income-tax return for year N, in the spring of N+1, and on the employer’s DSN each month. Impots.gouv.fr, in the version modified on 8 April 2026, tells the employee to do three things. If you opt for the 30 per cent evaluation of the impatriation bonus, you say so in the “other information” box of the 2042 / 2042 C return; the same box is used to choose the 50 per cent or 20 per cent cap if you combine the bonus with foreign-work relief. You then check the pre-printed salary figure. The net taxable salary after the exempt slice goes in boxes 1AJ or 1BJ of the main 2042. The exempt salary and bonuses go in boxes 1DY or 1EY of the complementary 2042 C. If the pre-printed figure is the full pay, you correct it. Leaving the pre-filled number untouched, while telling a recruiter that you are “on 155 B”, is how the first year is lost.
The employer must show, on the DSN, the pay that remains taxable and the pay treated as exempt under article 155 B I, in the box for sums exempt under the impatriate regime. The employer also sets the analogous reference pay and must be able to justify it. That is an employer duty. It is not, as CAA Paris no. 20PA02279 held, a condition of the employee’s statutory right. If payroll never opened the box, you still declare the exemption on the 2042, keep the contract, the offer letter, proof that you applied from the United Kingdom, proof of UK tax residence in the five previous calendar years, and a note on analogous pay. You then expect questions. You do not wait three years and hope.
The documents that usually decide a later audit are banal and often missing. A contract or amendment dated before the French start date, with a distinct impatriation line, or a written 30 per cent option. Proof that, on the recruitment date, your real home was still in the United Kingdom: tenancy, council tax, HMRC correspondence, school places, travel. BOI-RSA-GEO-40-10-10, paragraph 90, says that justification “peut résulter de multiples documents : pièces justificatives des contacts avec l’entreprise, justificatifs de domiciliation, justificatifs des déplacements effectués, situation familiale, etc.” UK tax returns or certificates showing you were not French-resident in the five calendar years before the year of taking up the post. A certificate of analogous pay, or payslip data for comparable French roles. For foreign-work relief, tickets and a mission letter. For article 155 B II, the UK dividend voucher or the custodian contract showing a UK or other treaty-State payer.
A rescrit fiscal (formal ruling) is available if the facts are unusual: a group with a thin French presence, a start-up that did not yet exist on day one (the commentary admits that case if the purpose of the move is to create the French company), a director who also holds shares, a split family. Article L. 80 A of the livre des procédures fiscales (LPF, the tax-procedure book) then becomes useful. Its third paragraph states: “Lorsque le redevable a appliqué un texte fiscal selon l’interprétation que l’administration avait fait connaître par ses instructions ou circulaires publiées et qu’elle n’avait pas rapportée à la date des opérations en cause, elle ne peut poursuivre aucun rehaussement en soutenant une interprétation différente.” If you applied the published commentary as it stood in the year of the facts, the administration cannot reassess you by inventing a harsher reading. That guarantee cuts both ways: it protects a file built on BOI-RSA-GEO-40-10-10 of 11 August 2025, including the “applied from abroad” remark, and it does not protect a file that simply ignored the analogous-pay floor already written in the statute.
Typical triggers for a reassessment are predictable. The person was already living in France when the contract was signed. The five-year look-back includes a year of French tax domicile, for example a previous posting that ended in year N-4. The taxable slice after exemption is below analogous French pay. The 30 per cent was applied to a termination payment. Foreign-work days include holidays. UK dividends were halved even though the payer is not in a treaty State with an assistance clause. The DSN and the 2042 tell different stories. The eight-year clock was counted from the visa, not from the taking-up of functions. Functions started on a visitor stay. Each of those facts is fixable before the first return if someone actually reads article 155 B. After a proposition de rectification, they become a litigation file.
B. How do I challenge a rejected impatriate claim or a proposition de rectification?
If you claimed the exemption on the 2042 and the administration silently ignored it, or if an auditor later adds the exempt slice back, the procedure is the ordinary income-tax procedure, not an immigration appeal and not a UK statutory review.
A proposed reassessment must be motivated so that you can accept it or answer it. Article L. 57 of the LPF provides: “L’administration adresse au contribuable une proposition de rectification qui doit être motivée de manière à lui permettre de formuler ses observations ou de faire connaître son acceptation.” On a request received before the time-limit in article L. 11, that time-limit is extended by thirty days. When the administration rejects your observations, “sa réponse doit également être motivée.” A letter that merely says “you were not called from abroad” without addressing the London application file, the BOI paragraph 80 remark and CAA Paris no. 20PA02279 is not a motivated rejection in any useful sense. You answer in time, in writing, with the documents listed above. Silence after a proposed reassessment is treated as acceptance of the extra tax, the late-payment interest and, often, the 10 per cent surcharge in article 1758 A of the CGI where the return omitted the extra base without a reasoned note. Article 1727 II of the CGI, as applied in CAA Paris no. 22PA00640, withholds late-payment interest only if the return or an attached note set out “des éléments précis et circonstanciés sur les motifs de droit et de fait”. A vague “impatriate package” in box “other information” is not that note.
Once the extra tax is collected, or once you have paid income tax computed without the exemption, the contentious claim is the réclamation. Article R*196-1 of the LPF, in force since 30 July 2026, states: “Pour être recevables, les réclamations relatives aux impôts autres que les impôts directs locaux et les taxes annexes à ces impôts, doivent être présentées à l’administration au plus tard le 31 décembre de la deuxième année suivant celle, selon le cas : a) De la mise en recouvrement du rôle ou de la notification d’un avis de mise en recouvrement ; b) Du versement de l’impôt contesté lorsque cet impôt n’a pas donné lieu à l’établissement d’un rôle ou à la notification d’un avis de mise en recouvrement ; c) De la réalisation de l’événement qui motive la réclamation.” For 2025 income tax collected in 2026, the ordinary long-stop is 31 December 2028. A claim that you paid the tax yourself, without a collection notice, runs from the payment. Do not wait for a friendly email from the inspector. The claim asks for discharge or reduction on the ground that article 155 B was met, or that the analogous-pay add-back was wrongly computed, or that article 155 B II was refused in a year still inside the I time-limit, following Conseil d’État no. 442799.
If the administration’s decision on that claim does not give full satisfaction, article L. 199 of the LPF, still in force until 1 January 2027, sends income-tax disputes to the tribunal administratif (administrative court): “En matière d’impôts directs et de taxes sur le chiffre d’affaires ou de taxes assimilées, les décisions rendues par l’administration sur les réclamations contentieuses et qui ne donnent pas entière satisfaction aux intéressés peuvent être portées devant le tribunal administratif.” In Paris and inner Île-de-France, that is in practice the Tribunal administratif de Paris or the court of the department of the tax domicile, with appeal to the Cour administrative d’appel de Paris or Versailles. The file is documentary. The judgments cited above show what wins: a London domicile at the time of the negotiations (20PA02279), a statutory reading of article 155 B II that the commentary had tightened without authority (442799), and what loses: a termination payment forced into the 30 per cent (19VE02459), or an intra-group transfer argued under a wording that no longer matches the current article if the facts are old (22PA00640).
Two related challenges should not be mixed into the same paragraph of the claim. If the residence card is refused, the appeal is an immigration appeal against the consulate or the préfecture, with its own two-month time-limit, not a tax réclamation. If URSSAF refuses the article L. 767-2 old-age exemption, that is a social-security dispute. If CSG has been charged on the UK pension of a different household member, that is another regime. Article 155 B is only the income-tax exemption for the impatriate employee and officer.
A British employee in Paris should also keep the immigration and payroll calendar in the same folder as the 2042. The taking-up of functions that starts the eight-year clock is the day the contract actually begins to be performed in the French business, not the visa vignette and not the first remote week from London. If the family home only follows in the next calendar year, the official page admits that the regime can still run from the year of taking up functions provided the home is installed before the end of the following calendar year, all other conditions being met. That is an administrative concession, not a statute. If the home never moves, article 4 B a is not met and article 155 B falls away for that year, without necessarily poisoning a later year in which the conditions are met.
Conclusion
Article 155 B is still, after Brexit, a real income-tax relief for a British employee or assimilated director who is called from the United Kingdom to a business established in France, who was not fiscally domiciled in France in the five previous calendar years, and who becomes so domiciled under article 4 B a and b. The current clock runs to 31 December of the eighth calendar year after the year of taking up the post. The exemption covers a documented impatriation supplement or, on option, 30 per cent of pay, foreign-workdays in the employer’s exclusive interest, and 50 per cent of listed foreign passive income. It does not cover a visitor who already lives in France and then finds a job, a remote UK contract with no French host, a termination payment, CSG as such, or IFI beyond the separate five-year rule in article 964. The analogous-pay floor in article 155 B I.1 is the provision that most often destroys an over-large bonus on audit.
The claim is made on the 2042 and the DSN. An employer’s silence does not kill the right. A motivated proposition de rectification is answered under article L. 57; a paid assessment is then attacked by a réclamation within the time-limit in article R*196-1, and if needed before the administrative court under article L. 199. The case-law that actually moves these files is on Légifrance: Paris 20PA02279 on applications from abroad, Conseil d’État 442799 on article 155 B II, Versailles 19VE02459 on termination pay. Build the evidence before the first spring return. Once the pre-filled 2042 has been validated with the full salary, the recovery is slower, dearer and less certain.
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Call +33 6 46 60 58 22 (Maître Reda Kohen). Write through the contact form. The firm advises British employees and families from Paris and Île-de-France, including files before the Direction régionale des finances publiques d’Île-de-France and the Tribunal administratif de Paris.
Related reading: how to prove tax residence when a couple is split between France and the UK; the talent residence card and a refused salary threshold; a British job offer and a refused employee work authorisation; UK dividends once you are a French resident; why a visitor card still does not let you work.