"I am signing in Saudi Arabia, but my family is staying in Lyon. Do I still pay tax in France?" "I have been playing in England for three years and kept my flat in Bordeaux, what do I need to declare?" "I am moving to Monaco, am I done with the French tax authorities?"
These questions come up in every transfer window, from players, their families and their agents. A professional athlete playing abroad may remain tax resident in France where their home or some of their other tax ties remain in France. Time spent abroad is not, on its own, enough to determine residence, and tax treaties play a key role in allocating taxing rights between states. Several well-known cases have shown it.
In short
An athlete who moves abroad to play may remain tax resident in France, in particular where their spouse and children continue to live there. Spending less than six months a year in France is not in itself enough to rule out French residence, which depends on all the circumstances and, where relevant, on the applicable tax treaty.
When two countries treat the athlete as resident, the tax treaty determines their residence. Pay for an activity carried on abroad is generally taxable in the state where the activity is actually performed, and France relieves double taxation under the treaty. Other income, foreign bank accounts and assets, on the other hand, follow residence.
Monaco has a specific rule for French nationals. A French athlete recruited from abroad by a French club may also, under conditions, benefit from the French impatriate regime. These situations should be prepared before the transfer.
Is a contract abroad enough to stop being French-resident?
Not on its own. Meeting just one of the tests in Article 4 B of the French Tax Code is enough to be domiciled in France under domestic law, subject to the applicable tax treaty.
The home (foyer) is one of the main tests for assessing an athlete's tax residence. In principle, it is where the centre of their family life lies. Where a player works abroad but their spouse and children continue to live in France, their tax home may therefore remain in France, regardless of how long they stay in France (BOFiP).
Having a home, the main place of stay, the place of professional activity and the centre of economic interests are alternative tests, whose application must then be reconciled, where relevant, with the provisions of the applicable tax treaty.
The main place of stay, often wrongly reduced to a 183-day rule, is not an automatic threshold. According to the Conseil d'État, it can determine tax domicile only where the taxpayer has no home in France (CE, 31 March 2014, no. 357019). The main professional activity is usually in the club's country, and the centre of economic interests is the place of main investments or the country from which most income derives. French sponsors, image rights income paid in France or significant assets in France can weigh in this analysis.
Since the 2025 Finance Act, Article 4 B provides that persons who meet one of these tests cannot, however, be treated as domiciled in France where, under a tax treaty, they are not regarded as resident of France. Domestic qualification and treaty residence must therefore be distinguished. Where the athlete may be treated as tax resident in two states, the provisions of the applicable treaty must be examined to determine their treaty residence and its tax consequences.
When two countries claim the player, the treaty decides
The club's country often treats the player as its resident, and France may do the same. Tax treaties then decide between the two states through a series of successive tests. The first question is where the player has a permanent home available, meaning accommodation available at all times. If they have one in both countries, the next step is the centre of their vital interests, personal and economic, then where they habitually stay, and finally their nationality.
Keeping a flat in France available all year round while renting near the new club often moves the discussion to vital interests, where the family carries significant weight.
Remaining French-resident does not mean paying tax twice on salary. Depending on the provisions of the applicable treaty, including those specific to entertainers and sportspersons, pay for a sporting activity carried on abroad may be taxed in the state where that activity is actually performed. This is not a universal rule, and each treaty must be read. For a footballer, the Paris Administrative Court of Appeal has held that the activity is carried on where the match is played, including in a third country (CAA Paris, 5 June 2024, no. 23PA01905). Where the athlete remains tax resident in France, the methods for relieving double taxation must be examined under the treaty. Depending on the case, France either exempts that income while taking it into account to set the rate on other income, or grants a tax credit (BOFiP). In individual sports, tournament or race winnings are generally taxable in the country of the event, under Article 17 of the OECD Model Tax Convention, which most French treaties follow.
The real stakes lie elsewhere. A player who remains French-resident is, as a rule, taxable in France on their other income, such as investments, rental income or image rights income, subject to treaties and the mechanisms for relieving double taxation. They must declare the accounts they hold, use or have opened abroad, and their real estate, in France and abroad, falls within the French real estate wealth tax (IFI) where its net value exceeds €1.3 million. With a country that has no tax treaty with France, no treaty mechanism relieves double taxation, and the situation must be reviewed before signing.
What the well-known cases teach
These cases do not all raise the same question. Those of Yannick Noah and Samir Nasri concern tax residence in France. The first has been decided and, according to the press, ended without bad-faith penalties. The second is ongoing and disputed. Those of Lionel Messi, Cristiano Ronaldo and Carlo Ancelotti concern Spanish tax and the concealment of income, notably image rights income. They therefore do not directly illustrate French residence rules, but they show that the host country audits too.
Yannick Noah, a house and children in France
For 1993, Yannick Noah declared himself resident in Switzerland. The French tax authorities argued that he had remained domiciled in France that year and, according to press reports, reconstructed his stays from card statements, cheques and invoices. In a decision published without his name, which commentators link to his case, the Conseil d'État upheld the existence of a home in France (CE, 31 March 2014, no. 357019).
The taxpayer owned a house there that he occupied regularly, with household staff. His two children lived there with their mother, as did several family members, and he had vehicles and bank accounts in France. Under the France-Switzerland treaty, his permanent home was also in France. Once French residence was established, sums from his undeclared foreign accounts were presumed to be taxable income in France. According to the press, the dispute ended in 2017, with around €661,000 to pay but no bad-faith penalties.
Samir Nasri, an ongoing case over residence in Dubai
More recent, Samir Nasri's case has not been decided. According to press reports, the French tax authorities dispute the former international and pundit's tax residence in Dubai and claim more than €5.5 million in income tax and real estate wealth tax for 2018 to 2025. According to the Associated Press, they rely on 487 days spent in France against 226 in the United Arab Emirates between 2021 and 2023, on airline bookings and on 212 meal deliveries to a Paris address in 2022 (AP). In March 2026, a Paris court authorised, as a precautionary measure, the seizure of some bank accounts and a provisional mortgage on a Paris property.
His lawyers dispute the claim. They say he lives in the Emirates with his partner and son, declares his French-source income in France, that the amount claimed is not owed and that the meal orders do not prove he placed them himself (Le 10 Sport, in French). They have appealed the seizure ruling, and no court has ruled on the merits. The case above all shows the kind of evidence the authorities now gather, days of presence, travel data and traces of daily life, and why an athlete should document their residence year by year.
Messi and Ronaldo, image rights caught up with in Spain
The host country also audits. Lionel Messi was convicted in Spain in 2016, a conviction upheld by the Supreme Court in 2017, and sentenced to 21 months in prison, not served, for evading Spanish tax on around €4.1 million of image rights income between 2007 and 2009 through companies in several countries (Público). Cristiano Ronaldo accepted in 2019 a 23-month suspended sentence and an €18.8 million fine for a €14.7 million fraud on his image rights from 2011 to 2014 (Al Jazeera).
The lesson applies to a French player settling abroad. As soon as they become resident in their club's country, their image rights income is generally taxable there, and a company set up in a third country to receive it will be closely examined. In France, Article 155 A of the French Tax Code pursues the same aim, as we explain in our article on French tax for professional athletes.
Carlo Ancelotti, residence is proven year by year
In 2025, a Madrid court sentenced coach Carlo Ancelotti to one year in prison, which he is not expected to serve, and a fine of around €386,000 for fraud relating to his 2014 income. He was acquitted for 2015, for lack of sufficient evidence that he was then living in Spain (Euronews). The year of arrival and the year of departure are often the most disputed, and each year is assessed separately.
What tax risks should an agent anticipate before an international transfer?
Beyond the headlines, these cases show how much is at stake in an athlete's international career. Misjudged tax residence, image rights income that was not anticipated or overlooked filing obligations can lead to significant tax reassessments, plus late-payment interest and, where the legal conditions are met, penalties. These difficulties can arise several years after a transfer, even once the player has changed club or country of residence.
For an agent, three situations deserve particular attention before the signature.
A player whose family stays in France. French tax residence may continue, with French tax on other income and the reporting of accounts opened abroad.
Image rights income received abroad. An image rights company set up in a third country is closely examined, in the club's country as well as in France.
A player considering a return to a French club. The impatriate regime has to be prepared before the return, as it depends on the years spent outside France and on how the player is recruited.
An international transfer is not just the negotiation of a sporting contract. Its tax consequences can extend well beyond the signature and have a significant impact on the player's wealth. For agents and clubs involved in these moves, anticipating these issues is an essential part of securing the athlete's career path.
Monaco, Switzerland, the Gulf, destinations that are not equal
Monaco is a special case. Under the 1963 France-Monaco treaty, French nationals who move there remain taxed in France as if they were domiciled there, on all their income (BOFiP). The treaty and guidance provide limited exceptions, notably for French nationals who could show five years of habitual residence in Monaco on 13 October 1962 and for certain dual nationality situations. For a French athlete, moving to Monaco therefore does not, as a rule, mean leaving the French tax system.
For Switzerland, the Noah case shows that a declared residence can be set aside when personal life remains centred in France.
The Saudi, Qatari and Emirati leagues attract players with salaries that are lightly taxed or not taxed at all locally. That is precisely why French residence is closely examined if the family stays in France. Each treaty France has signed with these countries has its own residence rules, to be read before signing.
What the player must do in France during a career abroad
In the year their tax home is actually transferred abroad, the player declares as a resident the income received until that date, then only their French-source income. That date does not always coincide with the signature or the first match, and should be documented. If they remain resident, they declare all their worldwide income, subject to treaties, and every account they hold, use or have opened abroad, failing which a fine of €1,500 applies per undeclared account, raised to €10,000 for a non-cooperative country (form 3916 notice).
If they become non-resident, they remain taxable in France on French-source income, such as rent from French property, and on their French real estate under the IFI, where its net value exceeds €1.3 million. Leaving may also trigger the French exit tax if they have been domiciled in France for at least six of the previous ten years and hold shares with a total value of at least €800,000 or representing at least 50% of a company's profits, for example an image rights company or a holding company. The tax applies to unrealised gains on those shares, payment may be deferred and, under conditions, the tax may be cancelled.
To secure their position, the player should keep the club contract, the lease for their home abroad, the children's school certificates if they moved too, a record of days spent in each country and the tax residence certificate issued by the club's country.
Coming back to play in France after a career abroad
A French athlete recruited from abroad by a club established in France may, under certain conditions, benefit from the French impatriate tax regime. The regime is not reserved for foreign nationals (BOFiP). It requires in particular that the athlete was not domiciled in France for tax purposes during the five calendar years preceding the year they take up the post, and that they were recruited while their home was still abroad, an application sent from abroad being treated as such recruitment. The regime notably exempts an impatriation bonus set in the contract or, by the player's election in their tax return, valued at a flat 30% of total net pay, within caps explained in our article on French tax for professional athletes.
The return also needs preparation, as the player generally becomes resident again from the date their tax home actually returns to France. A sale of shares, a distribution by an image rights company or the reorganisation of a holding company do not have the same effects before and after the return.
Anticipating the tax side of an international transfer
Signing a contract abroad can have significant tax consequences, for the athlete's pay as well as for their other income and their wealth. These issues deserve to be examined before the transfer, to prevent filing difficulties and to secure the player's tax position.
Beaupère & Guermouche Avocats advises professional athletes, their agents and their advisers on the tax consequences of international mobility, working with their contacts abroad. We act ahead of a transfer, during the athlete's international career or when they return to France, in English or in French. Contact the firm
Frequently asked questions
Is spending less than 183 days in France enough to stop being resident?
No. Length of stay only counts if the athlete has no home in France. If their family lives there, they may remain French-resident however many days they spend abroad, depending on all the circumstances and subject to the tax treaty.
Does a French athlete living in Monaco pay tax in France?
Yes. Save for very limited exceptions, a French national living in Monaco is taxed in France as if domiciled there, on all their income.
Is my salary from a foreign club taxed twice?
Generally not. The pay is taxable in the state where the activity is actually performed, and where the player remains resident in France, the treaty leads France to exempt it, while taking it into account for the rate, or to grant a tax credit. It must be checked, however, that a treaty exists with that country.
Can a French player returning to France benefit from the impatriate regime?
Yes, under conditions. They must have been recruited while their home was still abroad, an application sent from abroad being treated as such recruitment, and must not have been domiciled in France for tax purposes during the five calendar years before taking up the post. Nationality does not matter.
Do foreign bank accounts have to be declared?
As a rule yes, as long as the player is domiciled in France for tax purposes, for the accounts they hold, use or have opened abroad. Each undeclared account exposes them to a fine of €1,500, or €10,000 in a non-cooperative country, and sums coming from it may be presumed taxable.
General information up to date as of 31 October 2026, which does not constitute legal advice. The cases cited are described on the basis of published decisions and press reports. Each situation is assessed case by case, under the applicable treaty.