France's Administrative Supreme Court has overturned the tax authorities' doctrine relating to taxes withheld from French-source salaries, wages, pensions and life annuities paid to persons who are not domiciled in France for tax purposes. It distinguishes between tax domicile within the meaning of French domestic law and tax residence within the meaning of the bilateral tax treaty. This could imply that the preferential tax regime for impatriation applies to taxpayers domiciled in France because their main residence or principal professional activity is there, even if they are not a French tax resident within the meaning of the applicable tax treaty (Judgment No. 469771, Societe Axa Group Operations).
News Source：【Osborne Clarke 2024/4/5】