Tax Guide for French Citizens Living in Japan

French tax residency フランスの税務上の居住地

The fundamental good news for French citizens: France uses residence-based taxation, not citizenship-based taxation. Once you lose your French domicile fiscal (tax domicile), France generally stops taxing you on your worldwide income. You will only file and pay taxes in Japan, with exceptions for French-source income.

Domicile fiscal — when are you a French tax resident?

Under the Code Général des Impôts (CGI Article 4 B), you are considered to have your domicile fiscal in France if any one of the following criteria is met:

• Foyer (home/family center): Your foyer — the place where you and your family habitually live — is in France. If your spouse and children remain in France while you move to Japan alone, the French tax authorities may argue your foyer is still in France.
• Lieu de séjour principal (principal place of stay): You spend more than 183 days in France during the calendar year. Since you are moving to Japan full-time, this should not apply.
• Activité professionnelle (professional activity): You carry on a professional activity in France (employment or self-employment) unless you can demonstrate it is ancillary.
• Centre des intérêts économiques (center of economic interests): The center of your economic interests — your principal investments, the seat of your business activities, or the place from which you administer your assets — is in France.

For most French citizens who move to Japan with their family, establish a home, and work in Japan, none of these criteria will be met. You become a non-resident for French tax purposes (non-résident fiscal) from the date of departure. If the treaty's tie-breaker rules are needed (because both countries claim residence), the convention examines your permanent home, centre of vital interests, habitual abode, and nationality, in that order.

Exit tax (exit imposition)

France imposes an exit tax (impôt sur les plus-values latentes) under CGI Article 167 bis when you transfer your domicile fiscal outside France, if you hold significant assets:

• Threshold: The exit tax applies if you hold securities (titres) worth more than €800,000, or if you hold at least 50% of the rights in a company's profits (droits sociaux).
• What is taxed: The unrealized capital gains (plus-values latentes) on these securities are deemed to have been realized on the day before your departure. The gain is calculated as the difference between the market value and your acquisition cost.
• Tax rate: The flat tax (prélèvement forfaitaire unique / PFU) of 30% applies (12.8% income tax + 17.2% prélèvements sociaux), or you can opt for the progressive income tax scale if more favorable.
• Payment deferral: When moving to a country within the EU/EEA or to a country with a tax treaty containing administrative assistance provisions (Japan qualifies), you receive an automatic deferral (sursis de paiement automatique). You do not actually pay the tax — it is deferred until you actually sell the securities.
• Expiration: The exit tax obligation expires after 2 years (for gains under €2.57M) or after 5 years (for gains €2.57M or more) if you still hold the securities. If you have not sold them by then, the exit tax is permanently canceled.

Becoming a Japanese tax resident

Japan determines tax residency based on your 住所 (domicile) or 居所 (place of residence). If you have a 住所 in Japan (generally interpreted as living in Japan with the intention to stay for at least 1 year), you are a Japanese tax resident from day one. (国税庁タックスアンサー No.2010)

Filing in France フランスでの申告義務

Once you are a French non-resident (non-résident fiscal), you are only subject to French tax on French-source income (revenus de source française). You may still need to file a French return in the following situations:

• Year of departure: You must file a departure-year tax return (déclaration de revenus) reporting income from January 1 to the date of departure. Use the formulaire 2042 (and 2042-NR for the non-resident portion of the year if applicable). Report the exit tax on formulaire 2074-ETD if applicable.
• French rental income (revenus fonciers): If you own property in France and receive rental income, you must file a French return annually. Non-residents use formulaire 2042 and 2044 (for rental income). The income is taxed at a minimum rate of 20% (or 30% for income exceeding €27,478 for 2024) under CGI Article 197 A, unless you can demonstrate that your effective global tax rate is lower.
• French-source employment or business income: If you continue to perform work in France.
• Sale of French property: Capital gains on French property are subject to French tax (see property section below).
• Certain French-source investment income: Some dividends and interest from French sources may be subject to withholding, though the treaty may reduce or eliminate this.

If you have no French-source income after the departure year, you generally do not need to file French returns. However, it is good practice to file a "nil" return for one year after departure to formally establish your non-resident status with the Direction Générale des Finances Publiques (DGFiP). Non-residents with French-source income file with the Service des Impôts des Particuliers Non-Résidents (SIPNR) in Noisy-le-Grand.

France-Japan tax treaty 日仏租税条約

The France-Japan Convention Fiscale (Convention entre la France et le Japon en vue d'éviter les doubles impositions) was signed in 1995 and is a modern, comprehensive treaty that closely follows the OECD Model Convention.

Key treaty rates:

Key treaty provisions:

• Pensions: Pensions (including social security pensions) paid to a resident of Japan are generally taxable only in Japan. This is very favorable — France cannot withhold on pension payments to Japanese residents under the treaty.
• Employment income: Taxed in the country where the work is performed, with the standard 183-day short-stay exception.
• Capital gains: Gains from real property (immeubles) are taxed in the country where the property is located. Gains from shares are generally taxed only in the country of residence (Japan), unless the shares derive more than 50% of their value from French real property.
• Royalties at 0%: One of the notable features of this treaty — royalties are taxable only in the country of residence, meaning 0% withholding in the source country.
• No saving clause: The France-Japan treaty does not have a US-style saving clause. Once you are a Japanese tax resident and French non-resident, France does not claim the right to tax your worldwide income based on citizenship.

French pension (retraite) フランスの年金制度

France's pension system is complex, with multiple layers. Understanding how each works when you live in Japan is essential:

Retraite de base (basic pension / régime général)

The basic pension under the régime général (managed by the CNAV — Caisse Nationale d'Assurance Vieillesse, or the relevant regime for your profession) is a defined-benefit pension based on your earnings history. Key points for French citizens in Japan:

• Your trimestres are preserved: Contribution quarters (trimestres) earned while working in France remain on your record. They do not expire because you move abroad.
• Minimum qualification: You generally need trimestres to qualify for a pension. The full rate (taux plein) requires a certain number of trimestres depending on your year of birth (e.g., 172 trimestres / 43 years for those born in 1965 or later, under the 2023 reform). The totalization agreement with Japan can help you meet the minimum (see below).
• Voluntary contributions (assurance volontaire vieillesse): French citizens abroad can voluntarily subscribe to the French pension system through the CFE (Caisse des Français de l'Étranger) to continue accumulating trimestres. However, this is expensive and may not be the best use of your money — see the CFE section below.
• Receiving the pension in Japan: French pensions are paid worldwide, including to Japanese bank accounts. The CNAV (or your relevant regime) can transfer payments internationally. Apply through the CNAV or via your local CPAM/CARSAT before the desired start date.
• Tax treatment under the treaty: French pension payments are taxable only in Japan (your country of residence) under the France-Japan convention. France should not withhold tax on pension payments made to Japanese residents. This is a significant advantage — you pay tax at Japanese rates only.

Retraite complémentaire (supplementary pension — AGIRC-ARRCO)

If you were a salarié (employee) in France, you also contributed to the AGIRC-ARRCO supplementary pension scheme (merged since 2019). This is a points-based pension — your contributions are converted into points, and your pension is calculated by multiplying your points by the point value at the time of retirement.

• Points are preserved: Your accumulated AGIRC-ARRCO points remain on your account regardless of where you live.
• Pension paid abroad: AGIRC-ARRCO pensions are paid worldwide. Apply at least 6 months before your desired start date.
• Tax treatment: Like the basic pension, AGIRC-ARRCO payments to Japanese residents are taxable only in Japan under the treaty.
• Coefficient de solidarité: A temporary reduction (malus) may apply if you retire before age 67 without delaying one year past your taux plein eligibility. This applies regardless of where you live.

Other pension schemes

France has numerous special pension regimes depending on your profession:

• Professions libérales: If you were a doctor, lawyer, architect, or other liberal profession, you contributed to a specific caisse (e.g., CARPIMKO, CNBF, CIPAV). Your rights are preserved.
• Fonctionnaires (civil servants): Government pension schemes (SRE, CNRACL) have their own rules. Government service pensions may have different treaty treatment — under some treaties, government pensions are taxable in the paying country, but the France-Japan convention generally allocates taxing rights to the residence country for most pensions.
• PER (Plan d'Épargne Retraite): The newer retirement savings plan. If you have a PER, it remains in France. Withdrawals at retirement are taxable — generally only in Japan under the treaty. Early withdrawal rules apply regardless of where you live.

Sécurité sociale フランスの社会保障

When you leave France and work in Japan, you exit the French social security system (Sécurité sociale). In Japan, you will be covered by the Japanese system. However, France offers a unique option for expatriates:

CFE — Caisse des Français de l'Étranger

The CFE (Caisse des Français de l'Étranger) is a voluntary social protection scheme that allows French citizens abroad to maintain coverage similar to French Sécurité sociale. The CFE offers three types of coverage:

• Assurance maladie-maternité (health/maternity insurance): Covers medical expenses. The CFE reimburses at French Sécurité sociale rates. This is primarily useful for coverage when visiting France or as a complement to Japanese health insurance. It does not replace Japanese health insurance — you must still be enrolled in 社会保険 or 国民健康保険 in Japan.
• Assurance vieillesse (pension insurance): Allows you to continue contributing to the French basic pension (régime général) and accumulate trimestres while abroad. The cost is based on your income (approximately 6.90% of a reference salary). This can be valuable if you need additional trimestres to reach the taux plein.
• Assurance accidents du travail (workplace accident insurance): Covers work-related injuries. Less commonly subscribed by those already covered by Japanese 労災保険.

Should you subscribe to the CFE? The decision depends on your situation:

• Pension contributions: If you are far from the taux plein (full rate) and plan to retire relatively soon, CFE pension contributions may help you reach it. However, the cost is significant, and the totalization agreement may already help you qualify for a partial pension. Do the math carefully.
• Health insurance: CFE health coverage is primarily useful for visits to France (French hospitals will bill at Sécurité sociale rates and CFE reimburses). In Japan, you are fully covered by Japanese health insurance, which is generally excellent.

In Japan, your health and pension coverage comes from:

• 社会保険 (Shakai Hoken) — If employed by a company. Covers 健康保険 (health) and 厚生年金 (pension). Employer pays roughly half.
• 国民健康保険 + 国民年金 — If self-employed or not covered by employer. Premiums vary by municipality and income.

France-Japan totalization agreement 日仏社会保障協定

France and Japan have a Social Security Agreement (社会保障協定 / Accord de sécurité sociale) that has been in force since June 1, 2007. This agreement coordinates pension and social insurance between the two countries.

1. Eliminating double contributions

• Employed locally in Japan: You pay into the Japanese system (厚生年金 and 健康保険) and are exempt from French social security contributions (cotisations sociales) on that employment.
• Temporarily posted from France (détachement): If your French employer sends you to Japan for a temporary assignment (up to 5 years, extendable in exceptional cases), you can remain in the French social security system. Your employer continues French cotisations and you are exempt from Japanese 厚生年金. You need a certificat de détachement (certificate of coverage) from the CLEISS (Centre des Liaisons Européennes et Internationales de Sécurité Sociale) or URSSAF.
• Self-employed: If self-employed in Japan, you generally pay into the Japanese system (国民年金). The agreement ensures you are not also subject to French cotisations sociales.

2. Combining contribution periods

• French pension qualification: Japanese pension contribution periods can be counted toward the minimum trimestres needed to qualify for French pensions. This helps you meet the conditions for a partial pension even if your French career was short.
• Japanese pension qualification: Japan requires 10 years of contribution periods. French contribution periods can count toward this minimum.
• Benefit calculation: Totalizing helps you qualify, but each country calculates its pension based only on contributions to its own system. You receive a proportional pension from each country. France uses the "proratisation" method — it calculates what your pension would be if all your combined periods were French, then pays a proportion corresponding to your actual French periods.

French property フランスの不動産

Many French citizens who move to Japan keep property in France. The tax treatment for non-residents has some notable features:

Rental income (revenus fonciers)

Rental income from French property is taxable in France, regardless of where you live:

• Income tax: Non-residents pay French income tax on net rental income at a minimum rate of 20% (30% for income exceeding €27,478), unless they can demonstrate their effective global tax rate would be lower (CGI Article 197 A). You file a French return (formulaire 2042 + 2044) with the SIPNR.
• Prélèvements sociaux (social charges): This is a major issue for non-residents. French rental income was historically subject to prélèvements sociaux of 17.2% (CSG, CRDS, etc.) even for non-residents. Following EU court decisions, non-residents in the EU/EEA/Switzerland who are affiliated with their home country's social security system are exempt from CSG/CRDS (but may still owe the prélèvement de solidarité of 7.5%). For non-residents in Japan (outside the EU), the situation is less clear — France may still impose the full 17.2% prélèvements sociaux on your rental income. This significantly increases the effective tax rate.
• Micro-foncier regime: If gross rental income is below €15,000/year, you can use the micro-foncier regime (30% flat deduction instead of actual expenses). This applies to non-residents as well.
• Japan reporting: Report the French rental income on your Japanese 確定申告 and claim a foreign tax credit (外国税額控除) for French tax paid.

Selling French property (plus-value immobilière)

Capital gains on French property by non-residents are subject to French tax:

• Income tax on the gain: Non-residents pay 19% income tax on the capital gain (plus-value), after applying taper relief (abattement pour durée de détention). The gain is fully exempt from income tax after 22 years of ownership.
• Prélèvements sociaux on the gain: The gain is also subject to 17.2% prélèvements sociaux. The taper relief for prélèvements sociaux is slower — full exemption after 30 years of ownership.
• Surtaxe: For gains exceeding €50,000, an additional surtax of 2% to 6% applies.
• Principal residence exemption: Non-residents can claim an exemption for the sale of their former principal residence (résidence principale) if the sale occurs before December 31 of the year following the year of departure, and the property was not rented or lent in the interim. Additionally, a special exemption allows non-residents to be exempt on one property sale up to €150,000 of gain, provided they were fiscally domiciled in France for at least two years at some point before the sale.
• Représentant fiscal: For property sales exceeding €150,000, non-residents from countries outside the EU/EEA must appoint a représentant fiscal accrédité who guarantees the tax payment. This is an additional cost (typically 0.5-1% of the sale price). Since Japan is outside the EU, this requirement applies to you.
• Japan reporting: Report the capital gain on your Japanese 確定申告 with a foreign tax credit for French tax paid.

NISA for French citizens フランス人のためのNISA

Japan's NISA (少額投資非課税制度) is an excellent deal for French citizens — with significant advantages over what French tax-advantaged accounts offer:

• No PFIC issues: France does not have US-style "Passive Foreign Investment Company" rules. You can invest in Japanese mutual funds (投資信託) through NISA without any punitive French tax treatment. You are free to use eMAXIS Slim, SBI V Series, or any other popular Japanese index fund.
• Genuinely tax-free: Since you are a Japanese tax resident and French non-resident, NISA gains are tax-free in Japan, and France has no claim to tax them. No PFU (prélèvement forfaitaire unique), no prélèvements sociaux — your NISA investment income is completely tax-free.
• Better than PEA: France's Plan d'Épargne en Actions (PEA) provides tax advantages after 5 years, but is limited to European securities, has a €150,000 cap, and still subjects withdrawals to 17.2% prélèvements sociaux. NISA has a ¥18M lifetime cap (roughly €110,000-120,000 depending on exchange rates), covers a wider range of investments including Japanese and international funds, and is completely tax-free — no social charges of any kind.
• Full access to both NISA envelopes: You can use both the つみたて投資枠 (¥1.2M/year for index funds) and 成長投資枠 (¥2.4M/year for stocks, ETFs, and funds). No French tax complications with either.

What about your French PEA and assurance-vie?

• PEA: You can keep your PEA while living abroad. However, since 2024 reforms, non-residents can no longer open a new PEA. If you already have one, it continues to function but you should verify with your bank whether they allow non-residents to maintain and trade within the PEA. The PEA's tax advantages (exempt from income tax after 5 years) apply on the French side, and Japan generally should not tax unrealized gains within the PEA — but withdrawals may be taxable in Japan.
• Assurance-vie: French assurance-vie contracts continue while you live abroad. The tax treatment of withdrawals for non-residents depends on the treaty and the nature of the withdrawal. The France-Japan convention may allocate taxing rights to Japan. Consult a cross-border advisor for your specific contract.

If you return to France: Your NISA account will be frozen (no new contributions as a non-Japan-resident). The investments remain, but you may need to eventually sell and transfer the proceeds. Capital gains that accrued while you were a Japanese tax resident and French non-resident should generally not be retroactively taxed by France — but France may apply PFU (30%) or progressive rates to gains realized after you return. Consult a French tax advisor.

Frequently asked questions よくある質問

Do I need to notify the French tax authorities when I move to Japan?

Yes. Indicate your departure and new Japanese address on your departure-year tax return (déclaration de revenus). If you will have French-source income (rental income, etc.), your dossier will be transferred to the SIPNR (Service des Impôts des Particuliers Non-Résidents) in Noisy-le-Grand, which handles all non-resident tax matters. Keep your numéro fiscal.

Can I keep my French bank accounts?

Yes, most French banks allow non-residents to maintain accounts, though some may restrict certain products (Livret A, LDD, LEP). The Livret A and LDDS can generally be maintained by non-residents (interest is tax-free in France), but Japan will tax the interest as regular income. Update your address and non-resident status with the bank. Interest on taxable French accounts is subject to withholding (PFU at 30%), which can be reduced under the treaty to 10%. Claim a foreign tax credit in Japan.

What about my Livret A?

You can keep your Livret A while living in Japan. Interest is tax-free in France (exempt from income tax and prélèvements sociaux). However, Japan does not recognize the Livret A's tax-exempt status — you must report and pay Japanese tax on the interest. At Japan's tax rates, this reduces the effective benefit of the Livret A, though it remains a useful savings vehicle for funds you keep in France. The current Livret A rate (3% as of 2024-2025) is still attractive even after Japanese tax.

I still have my foyer (family) in France. Am I still a French tax resident?

Possibly. If your spouse and children remain in France while you work in Japan, the French tax authorities may consider your foyer to be in France and treat you as a French tax resident. This is one of the most common areas of dispute. If both countries claim you as a tax resident, the treaty's tie-breaker rules (Article 4) determine your residence for treaty purposes. The key factors are: where is your permanent home (foyer d'habitation permanent), where is your centre of vital interests, and where is your habitual abode. Ideally, move your family to Japan to create a clean break.

Does the exit tax apply to me?

Only if you hold securities worth more than €800,000 or hold 50%+ of a company's profit-sharing rights. If your portfolio is below these thresholds, the exit tax does not apply. If it does apply, payment is automatically deferred when moving to Japan, and the tax expires after 2-5 years if you do not sell the securities. You must still declare it on formulaire 2074-ETD with your departure-year return.

I am a dual French-Japanese citizen. Any special considerations?

Your tax obligations are determined by tax residence, not citizenship. As a Japan-resident without a domicile fiscal in France, you file and pay taxes in Japan on your worldwide income. Your French citizenship does not create a French filing obligation (unlike US citizenship). France permits dual nationality — holding both French and Japanese citizenship is legally recognized by France (note: Japan does not officially recognize dual nationality and may require you to choose, though enforcement varies).

I am leaving Japan and returning to France. What should I do?

File your final Japanese 確定申告 (or appoint a 納税管理人 to file after you leave). Consider claiming the pension refund (脱退一時金) if you contributed to 厚生年金 or 国民年金 for at least 6 months — this refund is taxable in France in the year received. Close or decide what to do with Japanese bank and brokerage accounts. Your NISA account will be frozen. Upon returning to France, you re-establish your domicile fiscal and become subject to French worldwide taxation. Re-enroll in the Sécurité sociale system and update your address with the DGFiP. See our Leaving Japan tax guide for the complete checklist.