Intra Company Transfer to France: Work Permits, Tax Rules, and Legal Requirements for 2025

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The intra company transfer is one of the most common mobility routes for international professionals relocating to France. Whether you’re a multinational company posting talent to your French subsidiary or a foreign employee assigned to work in France temporarily, understanding the visa process, work authorization, and tax implications is essential for a compliant and successful transfer in 2025.

What Is an Intra Company Transfer?

An intra company transfer (ICT) refers to the temporary relocation of an employee from a foreign branch of a company to its office or subsidiary in France. It enables skilled professionals—often executives or specialists—to contribute to projects or operations while remaining under contract with their original employer abroad.

In France, this process is governed by specific residence permits designed for seconded employees. There are two main pathways:

  • The “ICT seconded employee” residence permit

  • The “Talent Passport – Employee on Assignment” for those on a French employment contract

For a full overview of intra-corporate transfer regulations, you can refer to the official resource:
🔗 Welcome to France – Intra-Corporate Transferees (ICT)

Who Needs an ICT Residence Permit in France?

Non-EU/EEA/Swiss nationals planning to stay in France for more than 90 days as part of an intra company transfermust apply for:

  • A long-stay visa, and

  • Either a multi-year ICT residence permit or a VLS-TS (long-stay visa equivalent to a residence permit), depending on the mission’s duration.

This applies only when the employee remains under contract with the foreign parent company. If a French contract is signed, a different residence status applies.

Eligibility Criteria for ICT Seconded Employees

To qualify for the “ICT seconded employee” residence permit (Salarié détaché ICT), an applicant must:

  • Have at least six months of seniority in the group

  • Hold a contract with the foreign company, not the French host

  • Be transferred as a senior manager or high-level expert

  • Ensure that the home and host entities are part of the same corporate group

  • Receive compensation aligned with French legal and industry minimums

The ICT permit is issued for a maximum of three years and is non-renewable. After this period, the employee must return to their home country or apply for a change of status.

Mobile ICT Transfers Within the EU

Employees already holding an ICT residence permit from another EU Member State can be transferred to France under a mobile ICT permit for up to three years.

Requirements include:

  • A valid ICT permit from the first EU country

  • An amendment to the employment contract specifying the French assignment

  • Proof that both companies belong to the same group

  • Notification to French authorities if the mission is under 90 days

The mobile ICT permit acts as both a residence and work permit, authorizing the individual to work only in the role described in the application.

Mandatory Posting Declaration for Foreign Employers

Before beginning any intra company transfer in France, employers based outside France must submit a posting declaration via the SIPSI online platform.

This legal requirement ensures French authorities are informed of:

  • The nature of the assignment

  • The host entity in France

  • The duration and conditions of the transfer

📌 Declaration must be submitted before the employee starts work in France.

Tax Implications for Intra Company Transfers in France (2025)

While seconded employees stay under contract with a foreign company, they may still face tax obligations in Francedepending on the assignment length and activities.

French Income Tax Considerations

If the employee works physically in France and remains in the country for more than 183 days in any 12-month period, they may become tax resident in France. This would trigger French income tax obligations unless tax treaty relief applies.

France has signed numerous double taxation treaties, including one with the UK. These treaties are designed to prevent the same income from being taxed twice.

👉 For full details, read our article on the Double Taxation Treaty France–UK and How It Affects Non-Residents in 2025.

Withholding Tax for Non-Residents

Employees temporarily assigned to France but who retain tax residency abroad are often subject to withholding tax at source. As of 2025, the standard non-resident withholding rates in mainland France are:

  • 0% on income up to €15,228

  • 12% on income between €15,228 and €44,172

  • 20% on income above €44,172

Tax credits may be available in the home country, depending on applicable treaties.

Social Security and Payroll Issues

Intra company transferees may remain under their home country’s social security system if supported by an A1 certificate or equivalent. Otherwise, French contributions may apply.

Final Thoughts: Planning a Successful Intra Company Transfer

The intra company transfer process to France provides streamlined mobility for qualified professionals—but it requires careful planning. Between visa applications, tax rules, social security compliance, and posting obligations, it’s essential for both employers and employees to understand their responsibilities.

Navigating this process effectively helps prevent legal issues, ensures tax efficiency, and supports successful international assignments in 2025 and beyond.