TLDR: The tax procedure for arriving in France does not apply to internal transfers of personnel already working in the country or in the absence of tax treaties with the country of origin. These cases require the application of standard French tax rules.
Internal transfers already active in France
The special tax arrival procedure does not cover the transfer of employees already working in France. This applies to relocations to a head office or logistics center located in France. In such cases, the worker does not benefit from the incentives reserved for new arrivals from abroad.
Absence of international tax treaties
In the absence of tax treaties, full taxation in France applies to income earned there, without tax credits or partial exemptions. It is not possible to access special regimes for expatriation allowances or other benefits related to international mobility.
Differences from preferential regimes
Unlike covered cases, excluded taxpayers must independently determine the taxable base according to standard rules. No protection is provided against future interpretative changes.
Standard tax rules
Taxpayers excluded from the arrival procedure must apply standard French tax rules. This includes full taxation of income earned in France and the absence of specific benefits for expatriates.
Territoriality and residency
Determining tax residency and the territoriality of income is essential for establishing the application of tax rules. In the absence of treaties, general territoriality and residency rules apply.
Documentation and procedures
Excluded taxpayers must independently determine the taxable base and submit the documentation required by standard tax rules. No special procedure is provided for these cases.