TLDR: French civil servants and state agents on missions abroad are taxed in France if they are not subject to a personal tax on all their income in the host country. Additional remuneration related to the mission is exempt from income tax but is not considered when calculating the reference tax income.
Individuals Concerned
State agents on missions abroad, including civilian and military personnel, statutory civil servants, and employees under contract with the French state, are considered fiscally domiciled in France if they are not subject to a personal tax on all their income in the host country. This also includes agents of the Direction Générale du Trésor (DGT) posted abroad within the Ubifrance network, under specific conditions.
Tax Domicile
State agents on missions abroad are considered fiscally domiciled in France if they cannot prove they have been subject to a personal tax on all their income in the host country. This condition applies automatically if the agent cannot demonstrate being taxed abroad on all their income, except for income from French sources unrelated to remuneration.
Tax Exemptions
Additional remuneration related to the mission abroad is fully exempt from income tax. However, these supplements are not considered when calculating the effective tax rate or determining the reference tax income (RFR).
Exclusions and Limits
Public sector employees are excluded from the total income tax exemptions granted to other categories of workers seconded abroad. Additionally, the exemption for additional remuneration does not apply to the calculation of the reference tax income (RFR) or the effective tax rate.
Evidence and Justifications
To benefit from the French tax regime, agents must prove they are not subject to a personal tax on all their income in the host country, except for income from French sources unrelated to remuneration. The exemption in the foreign country must be by law and not due to errors or omissions.
Specific Regimes
Foreign diplomatic and consular agents in France are exempt from the taxe d'habitation (residence tax) for their official residence, subject to reciprocity with the represented country. This exemption does not apply to honorary consuls engaged in profit-making activities.
Additional Information
State agents on missions abroad must comply with French tax rules and provide the necessary documentation to benefit from the provided exemptions. It is important to note that public sector employees are excluded from certain exemptions granted to other categories of workers seconded abroad.