"My player is signing for a French club. How will they be taxed?"
Agents, players and clubs usually ask this a few days before the signature, which is precisely when most of the answer is decided. Tax residence, access to the French impatriate regime, the drafting of the contract and the organisation of the player's wealth are all settled before the first French tax return, not afterwards.
In brief
A foreign player who moves to France to play generally becomes tax resident in France on arrival, subject to the tax treaty with their home country, and is taxed in France on worldwide income. If the player was not resident in France during the previous five years and is recruited from abroad, they may benefit from the impatriate regime until 31 December of the eighth year after taking up the post. Their impatriation bonus is then exempt, either at the amount set in the contract or, by the player's election, at a flat 30% of total net pay.
Conversely, a French player who moves abroad does not automatically stop being French-resident, especially if their family stays in France. Leaving may also trigger the French exit tax if they hold significant shareholdings.
For clubs, recruiting abroad requires precise contract terms and accurate filings. For everyone, high earnings over a short career call for wealth planning from the outset.
Does a foreign player signing in France become a French tax resident?
As a rule, a player recruited by a French club is likely to be treated as tax resident in France once France is the place of their main professional activity, subject to the applicable tax treaty.
Under Article 4 B of the French Tax Code, a person is French-resident if France is the place of their home or main stay, of their main professional activity, or of the centre of their economic interests. Any one of these tests is enough. A player under contract with a French club usually meets the professional test, even if their family remains in their home country.
This domestic test is not always the end of the matter. Since the 2025 Finance Act, Article 4 B provides that a person treated as resident of another state under a tax treaty is not domiciled in France. Where the player's family stays in their home country and they keep a home there, the treaty with that country may allocate residence to it. The treaty should therefore be reviewed before the signature.
As a resident, the player is taxed in France on worldwide income, including income still received abroad, subject to the tax treaty between France and their home country. In the year of arrival, worldwide taxation generally covers only the period after they settle in France.
The player's salary is subject to French pay-as-you-earn withholding (prélèvement à la source), operated by the club. Without a prior French tax return, the club applies the default, non-personalised rate in the first year, until the player files a first return.
Planning the French impatriate tax regime before signing
The French impatriate regime (Article 155 B of the French Tax Code) applies to employees recruited from abroad to work for a business established in France. A player recruited directly from abroad by a French club can benefit if they were not French-resident in the five calendar years before taking up the post. Nationality is irrelevant, so a French player returning after more than five years abroad may also qualify.
What the regime exempts
The regime runs until 31 December of the eighth year after the player takes up the post. It provides several income tax exemptions.
The impatriation bonus, at the amount set in the contract or, by the player's election in their tax return, at a flat 30% of total net pay, bonuses included (French tax guidance).
The share of pay relating to matches and trips abroad, where they are undertaken in the direct and exclusive interest of the club.
Half of certain foreign-source passive income, such as dividends or gains on foreign securities, subject to conditions.
The first two exemptions are capped, at the player's choice each year, either at 50% of total pay or, for the foreign-activity share alone, at 20% of taxable pay. The better option should be checked by calculation every year.
The flat-rate option also has a broad reach. The Conseil d'État has held that the 30% exemption applies to all taxable pay, including the indemnity paid on the early termination of a footballer's contract (CE, 4 October 2023, no. 466714).
What needs to be secured
One condition is often overlooked. The player's taxable pay must be at least equal to the pay for similar roles in the club or in comparable clubs, otherwise the difference is added back. For a footballer, the Paris Administrative Court of Appeal held that similar roles are assessed objectively, without regard to the player's personal characteristics such as reputation or experience (CAA Paris, 16 March 2021, no. 19PA00956).
Responsibilities are also shared. The club sets the bonus in the contract where the player does not elect for the flat rate and reports the exempt amounts. The flat-rate election and the choice of cap are made by the player in their tax return.
Signing fees, match bonuses and image rights
Signing fees and match bonuses paid by the club are generally salary and taxed as such. The same applies to bonuses paid by a federation to a player released for their national team, who remains an employee of their club during that period (CE, 19 December 2018, no. 413033).
Income from practising a sport may, by election, be subject to income averaging over the year and the previous two or four years (Article 84 A of the French Tax Code), which smooths out the peaks of an uneven career. The Paris Administrative Court of Appeal has held that averaging still applies in the year the player leaves France, to amounts received during the years covered by the election. For an impatriate player, taxable income is then the average income for the period, less the average exempt impatriation bonuses (CAA Paris, 5 June 2024, no. 23PA01905).
Image rights follow their own rules. Since a law of 1 March 2017, a club may enter into a separate contract with a player it employs, paid by a royalty, for the commercial use of the player's image, name or voice (Article L. 222-2-10-1 of the French Sports Code). That contract must follow the conditions set by each sport's collective agreement, including the minimum salary above which it may be concluded and the royalty cap. Particular care is needed where income from the commercial use of the athlete's image is received by a separate company, especially one established abroad. In that case, the French tax authorities may tax a French-resident player directly on the sums received by that company, under the conditions of Article 155 A of the French Tax Code. An image rights structure should therefore be designed with its French treatment in mind, not only that of the country where it is set up.
What agents should check before signing
These choices are negotiated before the signature, and agents are often the first to hear the tax question, even before the club. A few key checks can help prevent unexpected tax consequences.
Where the player was resident over the last five years, which determines access to the impatriate regime.
How the contract is drafted, with a quantified impatriation bonus if the player does not elect for the 30% flat rate, and pay consistent with similar roles in the club.
Image rights, who owns them and where the company receiving them is based.
Agent commissions, who pays them and how they are documented. A player cannot deduct commissions they cannot prove were genuine, especially where the club in fact funds them.
Accounts and investments left abroad, which will have to be reported in France.
The family's situation, which weighs on tax residence.
Where the agent is based abroad with no fixed place of business in France, the commission paid by a French club for services provided or used in France falls within the scope of French withholding tax under Article 182 B of the French Tax Code, at the standard corporate income tax rate, currently 25%. This applies subject to the tax treaty with the agent's country of residence, which may exclude it. The club should therefore check the agent's residence and the required documentation before paying.
What clubs need to plan for when recruiting abroad
Once the contract is signed, it is the club that implements the impatriate regime. The club sets the impatriation bonus in the contract where the player does not elect for the flat rate, determines the reference pay and gives the player a certificate setting out the method used. It then reports the exempt amounts in its payroll filings (DSN), in the box provided for the impatriate regime, and excludes the impatriation bonus from French withholding (French tax guidance).
The player, for their part, reports taxable salary and exempt amounts separately, states the flat-rate election and the choice of cap in their tax return, and reports any bank accounts held, used or opened abroad. Failing to report a foreign account carries a fine of €1,500 per account, rising to €10,000 for certain countries (form 3916 notice).
A club or organiser paying a non-resident athlete for a one-off performance in France, such as a friendly match or a tournament, generally applies 15% withholding tax to the amounts paid, unless a treaty provides otherwise (French tax guidance).
These steps recur with every signing, which is why a club or an agency may prefer ongoing support to case-by-case advice.
Does a French player moving abroad remain taxable in France?
Not necessarily, but not automatically either. The residence tests then apply to what the player leaves behind in France.
A player signing for a foreign club now carries on their main professional activity there. The Article 4 B tests are, however, alternatives. If the player's home remains in France because their spouse and children live there, the French tax authorities may continue to treat them as French-resident. The treaty with the new club's country then decides between the two residences. We explain this situation, with the cases that have illustrated it, in our article French Players Moving Abroad.
In the year of departure, the player reports in France the income received until they move their tax home. French-source income received afterwards, such as rent, generally remains taxable in France. Matches played in France for the new club may also be taxed there, as most treaties give a taxing right to the country where the athlete performs.
Leaving France may also trigger the French exit tax if the player has been resident in France for at least six of the previous ten years and holds shares with a total value of at least €800,000 or representing at least 50% of a company's profits. Salary is not affected, but an image rights company or an investment holding company set up during the career may be.
Crossing these thresholds does not mean tax is paid immediately. The exit tax applies to unrealised gains on those shares, payment may be deferred, automatically or on request depending on the destination country, and the tax may be cancelled if the shares are kept for two years, or five years where their value exceeds €2,570,000.
Tax and wealth planning for professional athletes
An athlete's career often concentrates most of a lifetime's earnings into about ten years, with peaks in the year of a transfer, contracts in several successive countries, first property purchases often decided quickly and a second career to prepare well before the end. Wealth planning should start from that reality rather than from standard solutions.
Use the windows that open on arrival. Under the impatriate regime, half of certain foreign passive income is exempt from income tax. A player who was not resident in France in the previous five years is subject to the French real estate wealth tax (IFI) only on French real estate until 31 December of the fifth year after settling in France. This is the time to structure investments, bearing in mind that these advantages come to an end.
Separate what can be held through a company. Salary is received personally. A holding company or a property company can, however, receive amounts that have already been taxed in order to invest, provided its own tax treatment is assessed.
Buy property with mobility in mind. A flat bought in France generates rental income taxable in France even after a move abroad, falls within the IFI above the threshold and may weigh in the residence analysis. How it is held should be chosen with the player's future countries of residence in mind.
Smooth tax over the career. The Article 84 A averaging election softens progressive rates in peak years.
Think now about where to live after the career. The country where the player settles next will determine how their investments and gains are taxed and, where relevant, the exit tax due on leaving France.
Document every flow. For agent commissions, image income and foreign accounts, evidence often makes the difference in a tax audit.
For substantial wealth, succession planning should start early, as a family living in several countries and assets located in several states are exposed to different inheritance and tax rules.
Beaupère & Guermouche Avocats advises professional athletes, their agents and clubs on their tax and wealth planning matters, in France and internationally.
The firm acts on a one-off basis ahead of signings and transfers, to review the player's tax residence, anticipate the consequences of the contract and determine eligibility for the impatriate regime. It also supports clubs and agencies on an ongoing basis in securing their tax and filing obligations, and athletes in organising and passing on their wealth.
We would be delighted to discuss your needs, in English or in French, and to work alongside your usual advisers abroad where appropriate. Contact the firm
Frequently asked questions
Can a foreign footballer benefit from the flat 30% exemption?
Yes, if they meet the conditions of the impatriate regime, in particular having had no tax home in France during the previous five years. By election in their tax return, their impatriation bonus is deemed equal to 30% of total net pay, bonuses included, within the regime's caps. Their taxable pay must remain at least equal to that for similar roles.
How is a signing fee paid by a French club taxed?
As salary, in the year it is received, with withholding by the club. For an impatriate player, it forms part of the total net pay on which the flat 30% is calculated. Electing for income averaging under Article 84 A may soften the progressive rates.
Must a professional athlete declare foreign bank accounts in France?
As a rule, an athlete who is tax resident in France must declare the bank accounts they hold, use or have opened abroad, under the conditions set by French rules, including accounts opened before arrival. Each undeclared account carries a fine of €1,500, rising to €10,000 for certain countries.
Can a French club secure the impatriate regime for a foreign player?
The regime benefits the player, but its implementation depends largely on the club. The club sets the bonus in the contract where the player does not elect for the flat rate, fixes a consistent reference pay, gives the player the certificate and reports the exempt amounts in its payroll filings (DSN). The flat-rate election and the choice of cap are the player's.
Is a foreign athlete who plays a match or a tournament in France taxed there?
As a rule, yes, on the amounts relating to the performance in France. The club or organiser withholds 15% tax, unless a treaty provides otherwise. The withholding is credited against any French tax due, but any excess is not refunded.
Can a French player returning to France benefit from the impatriate regime?
Yes, if a French club recruits them while they are abroad and they were not French-resident in the previous five calendar years. Their nationality is irrelevant.
Are agent commissions paid by the player deductible?
They may be deducted as actual professional expenses, provided the player can prove they are genuine and linked to the player's activity. The Conseil d'État has upheld the refusal to deduct commissions whose genuineness was not established and which were in fact funded by the club.
General information, up to date as of 30 October 2026, which does not constitute legal advice. Each athlete's position depends on their residence, their contract and the applicable tax treaties, and must be assessed case by case.