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HMRC internal manual

International Manual

DT Agreements: France - Income from a UK source paid to a resident of France

Residence and domicile in France

An individual domiciled in France is subject to French tax on his total income from all sources. Individuals of whatever nationality not domiciled in France are normally subjected to French tax only on income arising in France. For the purposes of taxation in France (not the fiscal domicile Article of the DTA) an individual is regarded as having his fiscal domicile in France if he

  • has his home in France or his principal place of abode is there
  • carries out a professional activity there either as an employee or independently and the activity is not merely incidental
  • has his centre of economic interest there
  • is a French State Official, diplomat or a member of military personnel stationed overseas and not subject to tax on his world income in the country where he lives

If a claimant does not fit into one of the above definitions of fiscal domicile he/she will not be subject to tax on the income and relief is not available. You should refer any such case to Technical Advice Group section.