Tax residence in France for Pakistani taxpayers

France treats you as domiciled if any one test is met: your foyer (household) or principal place of stay is in France, your principal professional activity is in France, or the centre of your economic interests is in France. Pakistan counts days in its tax year of 1 July – 30 June. Where both countries claim you, Art. 4(2) of the 1994 Pakistan–France Convention decides, and since 2025 French law expressly follows the treaty.

Check your status: Pakistan and France

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, compared with the law of France and the tax treaty.

When France treats you as a tax resident

France treats you as domiciled if any one of three tests is met: foyer (household) or principal place of stay in France; principal professional activity in France; centre of economic interests in France.

Your family lives in France — that is your foyer, so under art. 4 B CGI you are domiciled in France and taxable there on your worldwide income.
Your principal professional activity is in France (including remote work performed from France for a Pakistani or other foreign employer) — under art. 4 B 1 b CGI you are domiciled in France.
The centre of your economic interests is in France — under art. 4 B 1 c CGI you are domiciled in France.
With no family, main work or economic centre in France, your principal place of stay decides: more than six months a year in France — you are probably domiciled in France.

When you are a nonresident

None of the art. 4 B CGI tests is met — you are not domiciled in France. French-source income (including pay for work physically done in France) is still taxable there.

Where the rules of France clash with Pakistani tax rules

Collision: your main work in France is enough for France. For France, carrying on your principal professional activity in France — including remote work from France for a Pakistani employer — is on its own a ground for domicile, even if your home and family are in Pakistan. The conflict is resolved by Art. 4(2) of the Pakistan–France Convention: if your only permanent home is in Pakistan, you are a resident of Pakistan for the treaty, and since 16 Feb 2025 French law then no longer treats you as domiciled in France. Your salary for days physically worked in France can still be taxed in France unless all conditions of Art. 16(2) are met.
Collision: the centre of economic interests is enough for France. If most of your income or investments are in France, France treats you as domiciled there even if you live in Pakistan. Pakistani law has no such test: it looks at days, government posting and, for citizens, the s. 82(d) rule. Art. 4(2) of the Convention decides — permanent home first. Property in France counts only if it produces income (Conseil d'État no. 426124), and French courts must apply the treaty tie-breaker once a residence conflict exists (Cour de cassation no. 19-14.013).
Collision: family in France is a foyer. If your spouse or partner and children live in France, France treats you as domiciled there even if you spend most of the year in Pakistan. Under the Convention: if your only permanent home is in Pakistan, you are a resident of Pakistan for the treaty; if you have a permanent home in both countries, family usually pulls the centre of vital interests to France.
Collision: Pakistani citizen resident in both countries. Under s. 82(d) a Pakistani citizen stays resident in Pakistan if he or she was not present in any other country for more than 182 days in the Pakistani tax year (1 July – 30 June), or is not a resident taxpayer of any other country. France can treat you as domiciled with far fewer days — through family, main work or economic interests. With residence in both countries, Art. 4(2) of the Convention decides; if it makes you a resident of France, s. 107 gives the treaty priority in Pakistan, and Pakistan may tax only Pakistan-source income as the treaty allows.

What else to know

Since 2025 the treaty expressly prevails in French law. Since 16 Feb 2025 art. 4 B CGI states that a person who is not a resident of France under a tax treaty is not domiciled in France. If the tie-breaker of the Pakistan–France Convention (Art. 4(2)) makes you a resident of Pakistan, France taxes you only as a non-resident. In Pakistan, s. 107 likewise gives the treaty priority over the Ordinance.
Pay for work done in France while resident in Pakistan. If you are resident in Pakistan under the Convention, France may tax your pay for work physically done in France unless all conditions of Art. 16(2) are met: no more than 183 days in France in the fiscal year concerned, an employer that is not a French resident, and pay not borne by a French permanent establishment. French withholding applies under art. 182 A CGI. In Pakistan, salary earned abroad is exempt if French tax on it was withheld and paid (s. 102); otherwise Pakistan credits the French tax (Art. 24(2), s. 103).
How double tax is relieved between Pakistan and France. If you are resident in Pakistan, French tax on French-source income taxable in both countries is credited against Pakistan tax, up to the share of Pakistan tax attributable to that income (Art. 24(2)); s. 103 computes the limit per head of income and unused credit is lost. If you are resident in France, most Pakistan-source income is in effect exempt (credit equal to the French tax), while for dividends, interest, royalties and technical fees France credits the Pakistan tax paid, capped at the French tax (Art. 24(1)(a)). The MLI did not change Art. 24.
French impatriate regime (art. 155 B CGI). If you were not tax-domiciled in France in the five calendar years before taking up a job there, the impatriate regime can exempt your impatriation premium (actual amount, or a flat 30% of net pay) and pay for work abroad (capped at 50% of total pay, or 20% for the work-abroad part), plus 50% of certain foreign investment income and gains, until 31 December of the eighth year after you start. There is no nationality condition, so Pakistani nationals recruited from Pakistan can use it.
Year of arrival or departure. In the year you arrive in or leave France, the six-month guideline is not applied: France taxes you as a resident only for the period of actual residence. Pakistan fixes status for the whole 1 July – 30 June tax year; a Pakistani citizen who leaves during a tax year and stays abroad for the rest of it is exempt in Pakistan on salary earned abroad in that year (s. 51(2)).
Pakistani government posting to France. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c). Under Art. 20 of the Convention their government salary is taxable only in Pakistan; France may tax it only if the person is a French resident and a French national without Pakistani nationality.
Social security: no Pakistan–France agreement. Pakistan is not among the States bound to France by a bilateral social security agreement (CLEISS list). Work in France is generally subject to French social security under French rules, with no certificate of coverage based on Pakistani coverage. Social security contributions are outside the income tax treaty.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention entre le Gouvernement de la République française et le Gouvernement de la République islamique du Pakistan en vue d'éviter les doubles impositions et de prévenir l'évasion et la fraude fiscales en matière d'impôts sur le revenu (Paris, 15 June 1994). The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

Terms you will come across in France

domicile fiscal: French tax domicile under art. 4 B CGI — any one of the three tests is enough
foyer: the household: where your spouse or partner and children normally live
lieu de séjour principal: principal place of stay — as a guideline, more than six months a year in France
centre des intérêts économiques: centre of economic interests: main investments, seat of business, most of your income
régime des impatriés: French impatriate regime (art. 155 B CGI) for people recruited from abroad
retenue à la source (art. 182 A CGI): withholding tax on French salaries of non-residents

Questions

Which tax treaty applies between Pakistan and France?

The Convention signed in Paris on 15 June 1994, in force since 1 September 1996. The tie-breaker for individuals is Art. 4(2): permanent home, centre of vital interests, habitual stay, nationality, then mutual agreement. The MLI applies to it but did not change Art. 4(2).

I work remotely from France for a Pakistani company. Am I domiciled in France?

Probably yes: principal professional activity carried on in France is on its own a ground for French domicile. If Pakistan also treats you as resident, Art. 4(2) of the treaty decides, and since 16 February 2025 French law follows the treaty result.

How does France avoid taxing my Pakistani income twice?

For most Pakistan-source income that Pakistan may tax, France gives a credit equal to the French tax on it, in effect an exemption. For dividends, interest, royalties and technical fees the credit equals the Pakistan tax paid, capped at the French tax (Art. 24(1)(a)).

Sources

Legislation and official guidance

art. 4 A CGI — Individuals domiciled in France for tax purposes pay income tax on their worldwide income; others only on French-source income.
art. 4 B CGI (as amended by art. 83 of Law no. 2025-127 of 14 Feb 2025, in force from 16 Feb 2025) — You are domiciled in France if (a) your foyer (household) or principal place of stay is in France, OR (b) you carry on your principal professional activity in France, OR (c) the centre of your economic interests is in France. One criterion is enough. Since 16 Feb 2025: if you are not a resident of France under a tax treaty, you are not domiciled in France under French law either.
impots.gouv.fr — «Suis-je non-résident fiscal ?» — The foyer is where your spouse or PACS partner and children live, even if you yourself spend most of the year abroad; tax-treaty criteria take precedence.
BOFiP BOI-IR-CHAMP-10-20160728 — Foyer = where the family normally lives; principal place of stay = guideline of more than six months a year, not absolute; principal activity = the one you devote most time to; centre of economic interests = main investments, seat of business, most of your income; one criterion is enough.
art. 164 B CGI — Income from professional activity performed in France is French-source income.
art. 182 A CGI (version from 1 Jul 2026) — French withholding tax applies to French salaries of non-residents: 12% and 20% above set thresholds.
Art. 4(2) Pakistan–France Convention (1994) — Dual-resident individual: (a) resident of the State where he has a permanent home (foyer d'habitation permanent); if in both States — the State with which his personal and economic relations are closer (centre of vital interests); (b) if that State cannot be determined, or if he has no permanent home in either State — the State where he habitually stays; (c) habitual stay in both or neither — nationality; (d) both nationalities or neither — mutual agreement of the competent authorities.
Art. 16(2) Pakistan–France Convention (1994) — Pay of a resident of one State for employment exercised in the other State is taxable only in the residence State if the employee stays in the other State for a period or periods not exceeding in total 183 days in the fiscal year concerned («au cours de l'année fiscale considérée»), the employer is not a resident of the other State, and the pay is not borne by a permanent establishment or fixed base of the employer there.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; consolidated text amended up to 30.06.2026 listed by FBR) — A citizen of Pakistan is also a resident individual if he or she is not present in any other country for more than 182 days during the tax year, or is not a resident taxpayer of any other country. Applies from tax year 2023.
Income Tax Ordinance, 2001, s. 107(2) — Subject to s. 109, a double taxation agreement and its implementing notification have effect notwithstanding anything in any other law, so far as they provide relief from tax under the Ordinance, determine the Pakistan-source income of non-residents, or provide for exchange of information.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
Art. 24 Pakistan–France Convention (1994) — France: income a resident of France derives from Pakistan that Pakistan may tax is included in the French base, with a tax credit equal to the French tax on that income (para. 1(a)(i) — in effect an exemption); for dividends, interest, royalties, technical fees and other listed items the credit equals the Pakistan tax paid, capped at the French tax on that income (para. 1(a)(ii)). Pakistan: French tax on French-source income taxable in both States is credited against Pakistan tax, up to the share of Pakistan tax attributable to that income (para. 2).
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
impots.gouv.fr — consolidated version of the France–Pakistan Convention as modified by the MLI (unofficial) — MLI in force for France from 1 January 2019 and for Pakistan from 1 April 2021; effective for taxes other than withholding taxes for tax periods beginning on or after 1 October 2021. MLI articles applied: 6, 7, 8, 9, 12, 13, 15, 16, 17; Art. 4(2), 16 and 24 of the Convention are not modified. Only the authentic texts are legally applicable.
art. 155 B CGI — impots.gouv.fr «Le régime des impatriés» — For people who were not tax-domiciled in France in the five calendar years before taking up the job: the impatriation premium (actual, or a flat 30% of net pay on option) and pay for work abroad in the employer's interest are exempt (caps: 50% of total pay overall, or 20% for the work-abroad part), plus a 50% exemption of certain foreign passive income and gains, until 31 December of the eighth calendar year after taking up the job. No nationality condition.
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
Art. 20 Pakistan–France Convention (1994) — Salaries and other remuneration (other than pensions) paid by a State, its political subdivisions or local authorities, or their public-law bodies, for services rendered to them are taxable only in that State; they are taxable only in the other State if the services are rendered there and the individual is a resident and a national of that State without being a national of the paying State. Government pensions follow the same rule.
CLEISS — FAQ «Accords de sécurité sociale» — Lists the roughly forty States and territories bound to France by a bilateral social security agreement; Pakistan is not among them.
Art. 4(2)(b) Pakistan–France Convention — If you have no permanent home in either State, the treaty goes straight to the State where you habitually stay (the centre of vital interests step applies only where there is a home in both States).
Art. 4(2)(a) Pakistan–France Convention — Centre of vital interests: the State with which your personal and economic relations are closer.
Art. 4(2)(c), (d) Pakistan–France Convention — Habitual stay in both States or in neither — the State of which you are a national; both nationalities or neither — the competent authorities settle the question by mutual agreement (Art. 26).

Case law

Conseil d'État (France), no. 450692, 11/05/2022 — The foyer of a single person is the place where he or she normally lives and has the centre of personal life, disregarding temporary stays elsewhere for work or exceptional reasons; the principal place of stay matters only where there is no foyer.
Cour de cassation (France), commercial chamber, no. 15-27.364, ECLI:FR:CCASS:2017:CO00562, 26/04/2017 — Foyer and centre of interests in France were established by facts: two houses, registration on electoral rolls, substantial electricity consumption, accounts only in French banks, French health insurance; a third party's statement about renting a home abroad, without rent receipts, did not rebut this. Wealth tax (ISF) case.
Conseil d'État (France), no. 469771, 05/02/2024 — The CEO of a French company whose family lived in Switzerland was domiciled in France under the principal-professional-activity test; occasional remote work from abroad did not change this. (The Court's view on the effect of the treaty for withholding purposes was overridden by statute from 16 Feb 2025.)
Conseil d'État (France), no. 426124, 07/10/2020 — The centre of economic interests cannot be established merely from owning companies and real estate in France: the court must check whether they generate income and compare it with income abroad.
Cour de cassation (France), commercial chamber, no. 19-14.013, ECLI:FR:CCASS:2021:CO00809, 24/11/2021 — Where France treats a person as domiciled under art. 4 B CGI (here: centre of economic interests) and another State also treats the person as its resident, there is a residence conflict and the court must apply the treaty tie-breaker. Wealth tax (ISF) case; same residence criteria.
Cour de cassation (France), commercial chamber, no. 19-13.710, ECLI:FR:CCASS:2021:CO00698, 13/10/2021 — A dwelling the person kept in France for his own long-term use is a permanent home under the treaty even if he also has a house abroad; where personal ties were split between the two States, economic ties (almost all income and assets in France) decided the centre of vital interests. Wealth tax (ISF) case; same criteria.

Updated 04/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

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