The main parts of the US–France tax treaty that unlock retirement for Americans in France
Why it is important for expats to understand tax treaties
Find out how the US-France tax treaty affects pensions, Social Security and investment income for Americans retiring in FranceLiberty Atlantic Advisors
There is an open secret that American retirees moving to France all know about: the tax treaty between the United States and France is one of the best in the world.
For many retirees, moving abroad raises logistical and financial concerns: Will I pay taxes twice? Do I need to move my investment accounts? Will my retirement income still work the same way?
The US–France Double Taxation Agreement creates a framework that helps answer those questions.
That said, it’s important to understand that tax treaties do not exist for the benefit of Americans, rather, they are bilateral agreements that determine which country gets to tax certain types of income and how issues of double taxation, where they arise, are handled (and where they arise, they may not always be evidently addressed).
For Americans planning retirement in France, a few treaty provisions are especially attractive, but they can come with a few “gotcha” moments if they’re not researched carefully in the context of your particular situation.
1. Article 18: Your US retirement accounts typically continue working well
One of the strongest features of the US–France treaty for retirees is Article 18, which governs pensions and retirement income.
Distributions from qualifying US retirement accounts, including Roth IRAs, Roth 401(k)s, and Social Security, are generally taxable in the US rather than France. France may still take this income into account when calculating your overall tax position, but treaty mechanisms typically prevent the income from being taxed twice.
This creates continuity that Americans retiring elsewhere in Europe do not always enjoy.
For many retirees, this makes keeping existing US retirement structures much more practical than moving everything over to be locally held.
That said, US retirees should also be aware that France’s broader social system will still require payment. There is an update to healthcare system contributions currently pending, which for the first time will introduce a dedicated financial contribution to the French Social Security system by certain foreigners residing in France.
2. Article 24 is what prevents double taxation
Article 24 contains the mechanisms intended to eliminate double taxation between France and the US. In practice, this often means France grants a tax credit on certain US-source income so that the same dollars are not fully taxed twice.
But “not taxed twice” does not mean “not taxed at all.” French tax residents may still owe French tax on income that is not fully protected by the treaty, including French-source income, French rental income, and certain non-US investment income. Investment income such as dividends, interest, and securities gains is often subject to France’s flat tax system, which includes income tax and social levies.
For 2026 income, French official guidance notes that social levies on investment income rise to 18.6%, in addition to the 12.8% income-tax component of the flat tax.
Retirees with substantial passive income and little or no earned income should take care to understand how their cross-border financial plan accounts for the protection universelle maladie, AKA the PUMa tax. This healthcare-related contribution can apply in specific circumstances and is separate from treaty-based income tax relief.
In sum: the treaty is powerful, but it is not a blanket exemption from the French tax system.
Liberty Atlantic Advisors
Final Note: moving to France does not require moving all of your money and accounts to France
One common assumption is that moving to France means moving your money to France.
It’s true that Americans need a French bank account for daily life — paying rent, utilities, insurance, taxes, and local expenses. But everyday banking is not the same as rebuilding your investment strategy inside the French financial system.
Because of US reporting rules, many French and European financial institutions are cautious about working with US citizens. If and when they do, the products they recommend may not be designed with US tax rules in mind, which can create additional burdens on Americans to do their own research to avoid non-compliant US tax missteps.
French investment wrappers, mutual funds, and insurance-based products may be common locally, but they generally (with exceptions for PEA and PER under certain conditions) create significant US tax and reporting complications for Americans. The Assurance Vie, for example, is a classic French retirement vehicle, but the IRS classifies them as Passive Foreign Investment Companies, or PFICs, which can lead to punitive tax treatment and complex annual reporting.
The goal is not to avoid integrating financially into France. It is to understand which parts of your financial life should become local and which parts may be safer, simpler, and more tax-efficient if they remain US-based.
