Relocating a business and employees to France: transfers, postings, a company

There are three ways to move a team to France, and the choice is driven not by convenience but by where the employment contract stays. If the employee signs a contract with the French group company, it is the «talent — salarié en mission» card. If the contract stays with the foreign company and the person is sent to France for a while, it is the ICT card. If there is no French entity at all and the work is done under a service contract with a client, it is a posting — détachement under the Labour Code, with its own declarations and fines.

Each route gives a different term: talent runs up to four years, is renewable and lets the spouse work; ICT is capped at three years with no renewal but comes with EU mobility; a posting lasts as long as the assignment and carries strict formalities. A fourth step usually follows any of them: a French company to employ people and issue invoices.

Two things cost the most and tend to surface after the move. France has no social security agreements with Russia, Kazakhstan, Uzbekistan or the UAE, so keeping contributions «at home» is not an option. And having employees in France can create a permanent establishment for the foreign company, and with it French corporate tax.

Three routes and how to choose

Below is each route: what the law requires, how long it lasts and where companies most often run into fines. An overview of all grounds for moving is in the article on the French residence permit, and the order of steps for a family move is in the guide on how to move to France.

Talent «salarié en mission»: a transfer on a French contract

The basis is Article L421-9 3° of CESEDA. The card goes to an employee who comes «within an assignment between establishments of the same company or between companies of a group», has worked for that group outside France for at least three months and signs an employment contract with the French company.

• Pay. At least the average annual gross reference salary set by the ministry each year: for 2026 it is €39,582 a year (service-public). For comparison, the annual SMIC is €22,404.20 gross.
• Term. The card is issued for the length of the contract, up to four years, and is renewable. That is the key difference from ICT. One caveat of this route: years on this card, and on family cards, do not count towards the ten-year EU long-term resident card.
• Family. A spouse over 18 and children get the «talent (famille)» card for the remainder of the main card’s term, and it allows any professional activity. No family reunification procedure is needed.
• Filing. From abroad, a D visa at the consulate and then the card online through ANEF; from inside France, two to four months before the current permit expires.

The other talent passport categories, for skilled employees, researchers, business founders and investors, are covered with thresholds and documents in the article on the French talent passport categories.

The ICT card: a posting inside the group

The «salarié détaché ICT» card comes from Directive 2014/66/EU and lives in Article L421-26 of CESEDA. It is for an employee who lives outside the European Union and whom the company transfers inside the group into a manager or expert role. The employment contract stays with the foreign company: the person is posted to France rather than hired there.

• Service. At least six months with the group’s companies, twice what talent requires.
• Term. It matches the assignment but cannot exceed three years, and the card is not renewable. The same employee gets a new ICT card only after six months of cumulative absence from EU territory.
• Resources and fee. At least the monthly SMIC, €1,867.02 gross; the card fee is €350, made up of a €300 tax and a €50 stamp duty (service-public).
• Trainees. For a traineeship inside the group there is the «stagiaire ICT» card: the same six months of service, a higher education degree, up to one year with no renewal.
• EU mobility. A holder of an ICT card issued by another EU country may work in France for up to 90 days on that permit. For a longer assignment, a «salarié détaché mobile ICT» card is issued for the length of the assignment, capped at three years minus the time already used in other EU countries.

Choosing between the two cards comes down to one question: is the employee moving to France, or staying yours and going for a while. Talent means a contract with the French company, three months of service and four years with renewal, but years on this route do not count towards the ten-year resident card. ICT means the contract stays abroad, six months of service, three years with no renewal, but the assignment can run across several EU countries.

Posting: SIPSI, a representative and fines

A posting in French law is not «going on a business trip» but a regime with its own duties. Under Article L1262-1 of the Labour Code an employer established outside France may temporarily send a worker to France while the employment contract continues, in three cases: under a service contract with a client in France, between establishments of the same company or companies of a group, or on its own account with no French client. Article L1262-3 expressly bans sham postings, where the company carries on no real activity in its country of establishment.

• Before the work starts. Article L1262-2-1 requires a declaration to the labour inspectorate through the SIPSI portal and a representative in France for the whole period. The law states separately that completing these formalities does not in itself make the posting lawful.
• Fines. Articles L1264-1 and L1264-3 set an administrative fine of up to €4,000 per posted worker, up to €8,000 on a repeat within two years, with an overall cap of €500,000. It is counted per head, not per breach.
• Work authorisation. Since 1 September 2024 Article L5221-2-1 exempts activity of up to three months from work authorisation, and only in a closed list of fields. The list includes audit and expert missions in IT, management, finance, insurance, architecture and engineering where the worker is posted under L1262-1. Outside the list or beyond three months, authorisation is required.

The practical conclusion: a posting suits short, well-defined assignments, not as a way around the talent or ICT card. If the person is needed in France permanently, they are documented under CESEDA.

Social security: there is no agreement with Russia

The A1 form, the first thing people ask about, is an instrument of EU regulations. It works within the EU, the EEA and Switzerland, while third countries are covered by bilateral social security agreements. France has 42 of them, and the CLEISS list includes neither Russia, nor Kazakhstan, nor Uzbekistan, nor the UAE. The agreement with China has been signed but has not entered into force; the one with Moldova was signed on 10 March 2025.

What this means in practice: for an employee from those countries there is no mechanism to keep contributions at home. Work in France leads to French affiliation and French contributions, while contributions in the country of origin are not cancelled, so there is a risk of paying twice. This is the case where the budget for the move is calculated before the contract is signed, not after.

Your own company in France

For a talent transfer a French group company is required: it is the one that signs the contract with the employee. The usual choice is an SAS, or a SASU for a single founder, less often an SARL or EURL. The minimum capital is €1, and the founders set the amount freely.

• Registration. Since 1 January 2023 all formalities, from incorporation to changes and closure, go only through the INPI guichet unique, which replaced the six former networks of formality centres.
• A non-resident director. Company law contains no requirement to live in France: the former declaration to the prefecture for a non-resident director (Article L122-1 of the Commercial Code) was repealed by Law No. 2014-1 of 2 January 2014. You can be president of an SAS or manager of an SARL while living abroad.
• Address. A registered office in France is required.
• If you buy a company instead of setting one up. An existing business is taken either as a fonds de commerce or as shares; the deal, the duty and settlement through a sequestre are covered in the article on buying an existing business in France.
• If the owner moves too. For a business founder there is the talent passport under Article L421-16 of CESEDA: a master’s degree or five years of experience, a genuine economic project, at least €30,000 of funding for it and personal resources of at least the annual SMIC. For an investor, Article R421-35: at least €300,000 in fixed assets plus creating or safeguarding jobs over four years. For a company’s legal representative, the threshold is €67,212.60 gross a year. Details and documents are in the article on the talent passport for entrepreneurs.

Corporate tax and permanent establishment

A French company pays corporate income tax (impôt sur les sociétés) at 25%. The reduced 15% rate applies to the first €42,500 of profit if turnover for the period is no more than €10,000,000, the capital is fully paid up and at least 75% is held by individuals (service-public). Above €7.63m of turnover and €763,000 of tax, a 3.3% surcharge is added (impots.gouv.fr).

A separate risk is a permanent establishment (établissement stable) of the foreign company. French doctrine sets it out in BOI-IS-CHAMP-60-10-10: any fixed installation with a degree of permanence and its own autonomy, such as a head office, an office, a branch or a point of sale. Without an installation, the activity may be carried on through a dependent agent, and the third test is a complete commercial cycle in France. An employee with authority to conclude contracts on behalf of the parent company can create such an establishment on their own, with no registration at all.

Russian companies have no treaty protection: Russia unilaterally suspended Articles 5–22 and 24 of the 1996 convention, and France drew the consequences from the same date, 8 August 2023 (BOFiP, ACTU-2024-00092). So a dispute about permanent establishment is settled under French rules, and double taxation is not relieved by the treaty.

The employee’s tax: the impatriate regime

An employee transferred to France can use the impatriate regime under Article 155 B of the Tax Code. The condition is not having been a French tax resident for the five calendar years before the year of taking up the post. The regime runs until 31 December of the eighth calendar year after that year: arrive in 2026 and it lasts until 31 December 2034.

The impatriation bonus is exempt, either in its actual amount or, by election, at a flat 30% of total net remuneration, with limits on the share of income that can be exempt. In addition, half of income from movable capital and of capital gains on securities from countries with a tax treaty with France is exempt. The key practical condition: the bonus must be written into the contract or an addendum before work begins — it cannot be arranged retrospectively. The tax scale, contributions and the family quotient are covered in the article on taxes in France.

What to budget for

• Card and visa fees: €350 per employee for ICT; for other cards the amounts are on service-public.
• French social security contributions if the employee comes from a country with no agreement.
• A representative in France for the whole posting and the running of SIPSI declarations.
• Setting up and running the French company: registered office, accounting, corporate tax.
• Apostilles and translations of degrees, certificates and corporate documents.
• An assessment of the permanent establishment risk before the move, not after the first audit.

Common mistakes

• Counting on an A1 form for an employee from Russia, Kazakhstan, Uzbekistan or the UAE: it works only within the EU.
• Starting work in France without the SIPSI declaration and a representative — the fine is counted per worker.
• Planning to renew an ICT card: three years is the limit, after which a six-month break outside the EU or another card is needed.
• Transferring an employee with less than three months in the group under talent, or less than six under ICT.
• Sending a manager with signing authority to France without assessing permanent establishment.
• Arranging the impatriation bonus after the person starts work, which forfeits the relief.

The route is chosen not by convenience but by where the contract stays, how long the person has been with the group and whether you need a French company. If you are weighing a team transfer or moving the business itself, describe your situation — we will review free of charge which route fits and what it will require from the company. How the same task works in Spain is covered in the article on relocating a business and employees to Spain.

Frequently asked questions

How do you move a company’s employees to France?

In three ways. If the employee signs a contract with the French group company and has worked for it for at least three months, it is the «talent — salarié en mission» card. If the contract stays with the foreign company and there are six months of service, it is the ICT card. If the work is done under a contract with a French client, it is a posting with a SIPSI declaration.

How does the ICT card differ from the talent card?

Under talent the French company signs the contract, three months with the group and pay from €39,582 a year are required, and the card runs up to four years and is renewable. Under ICT the contract stays abroad, six months of service are required, the card is capped at three years and is not renewable, but it gives EU mobility.

Is a SIPSI declaration required?

Yes, before the work starts, when a worker is posted to France under Article L1262-1 of the Labour Code. A representative in France is appointed for the whole period at the same time. Without this the fine is up to €4,000 per worker and up to €8,000 on a repeat within two years.

Can contributions be paid in the home country instead of France?

France has no social security agreements with Russia, Kazakhstan, Uzbekistan or the UAE, so there is no mechanism to keep contributions at home. Work in France leads to French affiliation, while contributions in the home country are not cancelled.

Do you need a French company to transfer an employee?

For the talent card, yes: the French group company signs the contract. For the ICT card and for a posting the contract stays with the foreign company, but having employees in France may create a permanent establishment for it and French corporate tax.

What tax does a French company pay?

Corporate income tax at 25%. The 15% rate applies to the first €42,500 of profit where turnover is no more than €10,000,000, the capital is fully paid up and individuals hold at least 75%. Above €7.63m of turnover and €763,000 of tax, a 3.3% surcharge is added.

Official sources

• CESEDA, Article L421-9 — the talent card; Article L421-26 — the ICT card; Articles L421-16 and following — entrepreneurs and investors; Article R421-35 — investor
• service-public: talent salarié en mission; service-public: salarié détaché ICT; arrêté of 21 August 2025 on the reference salary; service-public: SMIC 2026
• Labour Code, Article L1262-1; Article L1262-2-1 — SIPSI and the representative; Articles L1264-1 and L1264-3 — fines; Article L5221-2-1 — work authorisation
• CLEISS: list of social security agreements; Tax Code, Article 155 B — impatriates; service-public: corporate tax; impots.gouv.fr: impôt sur les sociétés
• BOFiP, BOI-IS-CHAMP-60-10-10 — permanent establishment; BOFiP, ACTU-2024-00092 — suspension of the treaty with Russia; INPI: guichet unique; service-public: SAS