Tax residence in France for Singapore taxpayers

France treats you as domiciled if your foyer or principal stay is in France, if you carry on your principal professional activity there, or if your centre of economic interests is there — any one is enough. Singapore decides your status for the calendar year by 183 days of presence or employment, normal residence of a citizen or PR, or IRAS's two- and three-year rules. If both countries claim you, Art. 4(2) of the Singapore–France Convention of 2015 decides; it has no nationality step.

Check your status: Singapore and France

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of France and the tax treaty (DTA).

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 Singapore 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 non-resident

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 Singapore 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 Singapore employer — is on its own a ground for domicile, even if your home and family are in Singapore. The conflict is resolved by Art. 4(2) of the Singapore–France Convention: if your only permanent home is in Singapore, you are a resident of Singapore for the treaty, and since 16 Feb 2025 French law then no longer treats you as domiciled in France. Your pay for days physically worked in France can still be taxed in France unless all conditions of Art. 14(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 Singapore; Singapore law has no such test. 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 Singapore. Under the Convention: if your only permanent home is in Singapore, you are a resident of Singapore for the treaty; if you have a permanent home in both countries, family usually pulls the centre of vital interests to France.

What else to know

Two different tests: days and normal residence in Singapore, three alternative criteria in France. Singapore decides residence for the calendar year: 183 days or more of presence or employment in Singapore, normal residence in Singapore as a citizen or Permanent Resident, or IRAS's administrative two- and three-year rules for foreigners. France needs only one of three criteria — foyer or principal stay, principal professional activity, or centre of economic interests in France — and also taxes by calendar year. You can therefore be resident in both countries without spending most of the year in France.
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 Singapore–France Convention (Art. 4(2)) makes you a resident of Singapore, France taxes you only as a non-resident. If permanent home, centre of vital interests and habitual abode do not decide, the Convention does not look at nationality: the competent authorities settle the case by mutual agreement (Art. 4(2)(c); Art. 25 — within three years of the first notification).
Working in France while resident in Singapore: 183 days in any twelve months (Art. 14(2)). If Singapore is your treaty residence, France may tax your pay for work physically done in France unless all conditions of Art. 14(2) of the Convention are met: not more than 183 days in France in any twelve-month period commencing or ending in the fiscal year concerned, an employer that is not resident in France, and pay not borne by a permanent establishment of the employer in France. French withholding applies under art. 182 A CGI. Where France may tax, Singapore exempts the income if the conditions of its Income Tax Act for income received from outside Singapore are met, and otherwise credits the French tax (Art. 23(1)).
How Singapore and France relieve double taxation (Art. 23). If Singapore is your state of residence, it exempts income from France that France may tax under the Convention where the conditions of its own law are met, and otherwise credits the French tax (Art. 23(1)); as foreign-sourced income received by a resident individual is generally exempt in Singapore (s. 13(7A)), the French tax usually stays as the final tax. If France is your state of residence, Singapore income is included in the French base and France gives a credit equal to the French tax on most of it (in effect exemption with progression); for dividends, interest, royalties under Art. 12(3), certain gains, directors' fees and artistes' income the credit equals the Singapore tax, capped at the French tax (Art. 23(2)).
Which treaty applies: the Singapore–France Convention of 2015. The Convention signed at Singapore on 15 January 2015 (in force since 1 June 2016; effective in France from 1 January 2017 and in Singapore from YA 2018) replaced the Convention of 1974. It applies in 2026 as modified by the MLI (principal purpose test, mutual agreement and arbitration), which does not change the residence or relief articles. Residence tie-breaker: Art. 4(2), without a nationality test; employment: Art. 14; pensions: Art. 17; government service: Art. 18; limitation of relief to remitted income: Art. 22; relief: Art. 23; mutual agreement: Art. 25.
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. The regime lowers French tax only; Singapore-source income remains taxable in Singapore under its own rules.
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. Singapore has no split year: it decides your status for the whole calendar year and taxes that year's income in the following Year of Assessment, so for the year of the move the two periods do not match.
Pensions and government service (Arts. 17 and 18). Pensions paid for past employment are taxable only in the State of residence of the recipient (Art. 17); the Convention has no separate rule for social security pensions. Government salaries and pensions are in principle taxable only in the paying State; the other State taxes them only if the recipient is its resident and national without being a national of the paying State (Art. 18).
Social security: no France–Singapore agreement. Singapore is not among the States linked to France by a bilateral social security agreement (CLEISS list). Work done in France generally falls under French social security under French rules, with no posting certificate based on Singapore coverage, and work in Singapore falls under Singapore rules. Social security contributions are not covered by the tax treaty.
Treaty residence in France: a French certificate for Singapore payers. If the Convention makes France your State of residence, ask your tax office for individuals (SIP) for a French certificate of tax residence and give it to Singapore payers so that they can apply the treaty; IRAS requires the payer to obtain the certificate of the non-resident payee. If the Singapore side uses its own form, that form is certified instead.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Government of the Republic of Singapore and the Government of the French Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (signed at Singapore on 15 January 2015), as modified by the MLI. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in France

domicile fiscal: tax domicile under art. 4 B CGI — taxable on worldwide income
foyer: home where your family normally lives
lieu de séjour principal: principal place of stay — more than six months a year
activité professionnelle principale: principal professional activity, including remote work from France
régime des impatriés: impatriate regime of art. 155 B CGI for people taking up a job in France
SIP: tax office for individuals, which issues certificates of residence

Questions

Which treaty applies between Singapore and France?

The Convention signed at Singapore on 15 January 2015, in force since 1 June 2016 (effective in France from 2017), modified by the MLI. Art. 4(2): permanent home, centre of vital interests, habitual abode; if these do not decide, the competent authorities agree — nationality is not a test.

How many days can I work in France for a Singapore employer before France taxes my salary?

Under Art. 14(2) France cannot tax it if you are there no more than 183 days in any twelve-month period starting or ending in the fiscal year, the employer is not French-resident and no French permanent establishment bears the pay. Remote work from France as your main activity can make you French-domiciled anyway.

Does Singapore tax my French income?

Singapore exempts income from France where the conditions of its Income Tax Act for income received from abroad are met and otherwise credits the French tax (Art. 23(1)); foreign income of resident individuals is generally exempt. Art. 22 limits French treaty reductions to income remitted to Singapore where Singapore taxes only remittances.

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.
s. 2(1) Income Tax Act 1947 (definition of «resident in Singapore», para (a)) — An individual is resident in Singapore if, in the year preceding the year of assessment, he or she resides in Singapore except for such temporary absences as may be reasonable and not inconsistent with a claim to be resident; also resident is a person who in that year was physically present or exercised employment in Singapore (other than as a company director) for 183 days or more.
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
Art. 4(2) Singapore–France Convention (2015) — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home in both States, of the State with which his personal and economic relations are closer (centre of vital interests); if that State cannot be determined, or if he has no permanent home in either State, of the State in which he has an habitual abode; if he has an habitual abode in both States or in neither of them, the competent authorities settle the question by mutual agreement. There is no nationality test. Not modified by the MLI.
Art. 14(2) Singapore–France Convention (2015) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the first State if the recipient is present in the other State for not more than 183 days in aggregate in any twelve-month period commencing or ending in the fiscal year concerned, the remuneration is paid by or on behalf of an employer who is not a resident of the other State, and it is not borne by a permanent establishment of the employer in the other State.
Art. 25(1) Singapore–France Convention (mutual agreement procedure) — A person who considers that the actions of one or both States result or will result in taxation not in accordance with the Convention may, irrespective of domestic remedies, present the case to the competent authority of the State of which he is a resident within three years from the first notification of the action.
Art. 23 Singapore–France Convention (elimination of double taxation) — Singapore (para. 1): income from France that may be taxed in France under the Convention is exempt in Singapore where the conditions of the Income Tax Act for exempting income received from outside Singapore are met (a); otherwise Singapore, subject to its law, credits the French tax paid (b). France (para. 2): income that may be taxed in Singapore is taken into account for French tax and gives a tax credit equal (i) to the French tax on that income — in effect exemption with progression — or (ii) for dividends, interest, royalties under Art. 12(3), gains on immovable property and property-rich shares, directors' fees, artistes' and sportsmen's income and withdrawals under Art. 21(3), to the Singapore tax paid, capped at the French tax on that income.
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
Singapore–France Convention of 15 January 2015, as modified by the MLI (IRAS text) — Signed at Singapore on 15 January 2015 in English and French, both equally authoritative; in force 1 June 2016; effective in France from 1 January 2017 and in Singapore from YA 2018; replaced the Convention of 1974. The MLI applies (preamble, principal purpose test, mutual agreement and arbitration); Arts. 4 and 23 are not modified.
Art. 22 Singapore–France Convention (limitation of relief) — Where income from one State is exempt or taxed at a reduced rate there under the Convention and the other State taxes it only on the amount remitted to or received in that other State, the exemption or reduction applies only to the amount so remitted or received.
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.
s. 2(1) ITA 1947 (definitions of «year of assessment» and «basis period»); IRAS — preceding-year basis of assessment — Tax is charged for a year of assessment (YA) on the income of the preceding calendar year: YA 2027 covers income from 1 January to 31 December 2026. Residence is determined for the same preceding calendar year, so the selected year 2026 is the basis year for YA 2027.
Arts. 17–18 Singapore–France Convention (2015) — Art. 17: subject to Art. 18(2), pensions and similar remuneration paid to a resident of a State for past employment are taxable only in that State. Art. 18: government salaries (other than pensions) are taxable only in the paying State, unless the services are rendered in the other State by a resident who is a national of that State without also being a national of the paying State; government pensions are taxable only in the paying State, unless the recipient is a resident and national of the other State without being a national of the paying State.
CLEISS — FAQ «Accords de sécurité sociale» — Lists the some forty States and territories linked to France by a bilateral social security agreement (consulted 10.11.2026); Singapore is not among them.
impots.gouv.fr — form 731-FR-GB-ES-DE, certificate of tax residence for individuals — The certificate of tax residence is requested from the tax office for individuals (SIP), which checks that the tax domicile is in France and returns the signed form; if the source State has its own form, that form is used.
IRAS — «Claim of relief under the DTA» (withholding tax, updated 8 January 2026) — To apply a reduced treaty rate or an exemption, the Singapore payer obtains a certificate of residence of the non-resident payee from the other state's tax authority (in English or with an English translation, stating residence for treaty purposes and the years covered); non-resident professionals also sign Form IR586. The payer submits the certificate to IRAS by 31 March of the following year, otherwise the relief may be withdrawn.
Art. 4(2)(a) of the Singapore–France Convention — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests).
Art. 4(2)(b) of the Singapore–France Convention — If the State of the centre of vital interests cannot be determined, or if he has no permanent home available in either State, he is deemed to be a resident of the State in which he has an habitual abode.
Art. 4(2)(c) of the Singapore–France Convention — If he has an habitual abode in both States or in neither of them, the competent authorities of the Contracting States settle the question by mutual agreement. There is no nationality test.

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.

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

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