Tax Treaty Between US and France: What Non-Residents Should Know

Understanding Tax Residency in France

In France, tax residency is determined by national rules or international agreements and cannot be chosen voluntarily. Whether you’re a U.S. citizen or resident working in France temporarily, your tax obligations depend on where you are officially considered a resident for tax purposes.

For an in-depth explanation of how France determines tax residency, check the Determination of Tax Residency fact sheet.

Tax Obligations Under the Tax Treaty Between US and France

The tax treaty between the US and France is designed to prevent double taxation and ensure fair tax treatment for individuals and businesses operating between the two countries. If you are considered a non-resident in France under this treaty, you are typically taxed only on income sourced in France.

For example, income earned through work physically performed in France is taxable there—even for U.S. tax residents—unless the treaty provides an exemption.

How Tax Is Withheld for Non-Residents

In the absence of specific treaty provisions, income such as salaries paid to non-residents is subject to withholding tax at source in France. This means that tax is deducted directly from your income before it is paid out.

However, under the US-France tax treaty, you may be eligible for tax credits or exemptions in the U.S. for taxes already paid in France, helping you avoid double taxation.

Tax Relief for Short-Term U.S. Assignments in France

Many tax treaties, including the one between the US and France, provide exemptions for temporary assignments. If the following conditions are met, your income may not be taxable in France:

• You are present in France for less than 183 days in any 12-month period.

• Your salary is paid by or on behalf of an employer not established in France.

• Your remuneration is not borne by a French permanent establishment of your employer.

This provision is particularly useful for expatriates and short-term contractors.

Withholding Tax Rates for Non-Residents in France (2023, based on 2022 Income)

Mainland France

Overseas Departments and Regions

(Martinique, Guadeloupe, La Réunion, Mayotte, French Guiana)

Source: impots.gouv.fr

Further Information and Resources

For more detailed guidance on how to manage your taxes as a non-resident in France, we recommend reading our full article on Taxation Return in France: Everything You Need to Know.

External Resources

You can also visit the official French government tax website for non-residents for the latest updates and legal guidelines.