American citizens moving to France: what taxes? (2024)

  • 23 February, 2023
  • Durée de lecture

American citizens moving to France: what taxes? (1)

Many American citizens decide to expatriate to France, particularly for their retirement. The purpose of this article is to clarify the French taxation of US-source income of US citizens.

1 – IN WHICH COUNTRY WILL MY US PENSIONS BE TAXED?

France and the United States have signed a tax treaty to avoid double taxation. Under this convention, retirement pensions and payments recognized as such are taxable only in the “payer” country. Thus, US-source pensions are taxable only in the United States.

For the purposes of Article 18 of the Tax Convention, France recognizes :

  • Qualified plans covered by Section 401 (a) of the Internal Revenue Code;
  • Individual retirement plans (including individual retirement plans that are part of a simplified employee retirement plan that meets the conditions of section 408 (k), retirement individual accounts, individual life annuities and accounts covered by section 408 (p));
  • Qualified plans covered by section 403 (a) and those covered by section 403 (b), are generally considered to correspond to a pension plan constituted, established and recognized for tax purposes in France.

2 – IN WHICH COUNTRY WILL MY US PROPERTY INCOME BE TAXED?

Once again, France and the United States have signed a tax treaty to avoid double taxation. The rule under the treaty is taxation in the country where the property is located, i.e. the United States.

3 – WHAT ABOUT OTHER REVENUES?

For the most part, the treaty neutralizes taxation in France on U.S.-source income received by U.S. citizens resident in France. It is therefore strongly recommended that you consult your tax advisor in order to clearly determine the place of taxation for each category of income, and to avoid errors in reporting.

4 – DO YOU HAVE ANY TAX OBLIGATIONS IN FRANCE?

Yes, as a French tax resident you are required to declare all your worldwide income. Article 24 of the same tax treaty sets out the procedures for avoiding double taxation. Income that is taxable only in the United States must be declared on the French tax return, but taxation in France is offset by a tax credit equal to the amount of the corresponding French tax.

Please note that this analysis is applicable as of today, and does not take into account any changes in the law brought about by the Finance Acts published each year.

If you have any further questions, please do not hesitate to contact us and we will be happy to assist you.

Do you have any questions? Your dedicated team member will be happy to answer any questions you may have.

Circular written by Maud MESTRE – Tax Manager at Ruff & Associés

Need help?

It is important to note that this article may be subject to change depending on government news and directives.
So if you have any questions, our Ruff & Associés teams are always at your disposal. Let us help you with your projectscontact us!

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FAQs

American citizens moving to France: what taxes? ›

Self-employed U.S. expats living in France are only subject to France social security taxes, not U.S., thanks to the US-France Totalization Agreement. This agreement ensures American expatriates avoid double taxation, clarifying that their social security contributions are due only in the country where they work.

Do I have to pay US taxes if I live in France? ›

If you are a U.S. citizen or resident living or traveling outside the United States, you generally are required to file income tax returns, estate tax returns, and gift tax returns and pay estimated tax in the same way as those residing in the United States.

Is my US social security taxed in France? ›

As a French resident, you will pay French taxes on most income, but there is an exemption for certain retirement and pension programs that includes your social security income. So, you will be reporting social security income to both governments, but it is taxable in the U.S. (See Article 18 of the Tax Treaty here).

What taxes do expats pay in France? ›

Non-residents pay tax on French-sourced income at a flat rate of 20% for income up to €27,478 and 30% for income above this threshold. Savings, investments, and bank interest are also subject to income tax at a flat rate of 30%. Income tax returns are due in May or June each year, depending on where you live in France.

Is there an income tax treaty between US and France? ›

The US France tax treaty, originally signed in 1994, serves as an agreement between the two countries for determining the taxation of income where both nations may have the legal right to tax according to their respective laws.

Do US citizens living abroad pay double taxes? ›

The US is one of the few countries that taxes its citizens on their worldwide income, regardless of where they live or earn their income. This means that American expats are potentially subject to double taxation – once by the country where they earn their income, and again by the United States.

What is the 183 day rule in France? ›

An employee residing in France for less than 183 days does not owe tax on income earned through their work in the country, as long as their remuneration is paid by or on behalf of an employer which is not established in France.

What happens to my social security if I move to France? ›

If you have social security credits in both the United States and France, you may be eligible for benefits from one or both countries. If you meet all the basic requirements under one country's system, you will get a regular benefit from that country.

Do retirees pay taxes in France? ›

Taxes on retirement in France

You'll need to fill in an annual tax declaration, even if you're not making any income. France has agreements with many of its European neighbors and other countries around the world.

Are taxes higher in France or the USA? ›

the USA ones may look unreasonable. In contrast to the US combined rate of 15.3%, European rates range between 13.97% (not including medical insurance and pension contributions) in Switzerland and a whopping 65-68% in France, based on the 2022 table by Trading Economics.

What is the 30% rule in France? ›

For French residents : the 30% flat-rate levy (of which 12.8% for income tax and 17.2% in social levies) applies to investment income including dividends, interest and capital gains on the disposal of securities and shares. The 40% allowance on dividends and similar income does not apply.

Is healthcare free in France? ›

French healthcare costs

Medical treatment and tests are partially paid for by the government, but the patient is responsible for the remaining amount. French state health insurance covers 70–100% of necessary treatments like doctor visits and hospital stays.

Is France a highly taxed country? ›

As of 2024, the average statutory top personal income tax rate is approximately 42.8% in Europe. The nations that get the shameful medal for highest tax OECD countries include Denmark, France and Austria, with rates ranging between 55 and 55.9%.

How is US income taxed in France? ›

Unlike residents, non-residents in France are only taxed on their French-sourced income. Non-resident taxes are typically collected by withholding at the source. These withholding taxes are applied at progressive rates of 0%, 12%, and 20%, depending on the total amount of taxable income.

How to avoid double taxation in France? ›

To avoid double taxation, when this income has been taxed under the terms of a treaty in the country or territory from which it originates, the tax paid outside France is not deductible from income but provides entitlement to a tax credit that may be deducted from French tax.

Which states in France are exempted from paying taxes? ›

The First and the Second Estate formed the privileged classes. They owned most of the land even though they were only a tiny fraction of the French population, all the important posts of the state were held by them and they were exempted from paying taxes. The Third Estate, on the other hand, received no privileges.

Do you have to pay US taxes if you don't live in the US? ›

I'm a U.S. citizen living and working outside of the United States for many years. Do I still need to file a U.S. tax return? Yes, if you are a U.S. citizen or a resident alien living outside the United States, your worldwide income is subject to U.S. income tax, regardless of where you live.

Do I have to pay US state taxes if I live abroad? ›

The answer depends on the state. Some U.S. citizens and residents living abroad must file a state tax form, but not all expats are required to do so. What U.S. expats do for state taxes depends on which state they lived in before their move to another country.

Do I have to pay US taxes if I have dual citizenship? ›

In both cases, the same tax rules apply to you as any other citizen of the US, including all other dual citizens. You will have to file a US tax return every year, and you may have to pay taxes on any income you receive. The only way to escape this obligation is to renounce your citizenship.

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