US Retirement Income When You Live in France

Article 18 gives US retirement income to the United States

The US–France income tax treaty, signed on August 31, 1994, has been amended by protocols signed on December 8, 2004 and January 13, 2009, and both rewrote Article 18 (Pensions). Article 18 covers pensions, annuities, Social Security, private-sector pensions and traditional IRA and 401(k) distributions. Since the 2004 protocol it also covers government-service pensions: federal civil service, state, local and military. This page applies that article to each kind of US retirement income; residence, other income and double-tax relief are covered in our guide to the treaty as a whole.

The key question is where a distribution “arises”. A pension distribution arises in the country where the paying pension or retirement arrangement is established, not where you live. A plan established in the US therefore arises in the US, and Article 18(1) makes it taxable only there, whether it is paid periodically or as a lump sum. This is the reverse of the usual OECD-model default, under which the country of residence taxes private pensions.

The rule is one of the treaty’s saving-clause exceptions that apply to individuals generally, so a US citizen living in France gets the same source-only treatment as anyone else. The saving clause still lets the United States tax its citizens, so your US filing does not change: you report these amounts on your US return and pay US tax on them as usual.

Social Security: taxed only by the US

Article 18(1) provides that amounts paid under one country’s social security legislation to a resident of the other are taxable only in the paying country. For an American receiving US Social Security while living in France, the benefit is taxable only in the United States, not by France. It is the mirror image of the rule that French social security paid to US residents is taxable only by France.

France does not tax the benefit, but it still has to be declared on your French return, as the section on the French return below explains.

Traditional IRAs, 401(k)s and private pensions: taxed only by the US

An IRS information letter applying Article 18 as amended by both protocols concludes that a pension distribution arising in the United States and paid to a French resident is taxable only in the US and exempt from French tax. Because a 401(k), a traditional IRA or a private-employer pension is established in the US, its distributions arise in the US, so the US alone taxes them even though you are a French tax resident.

Descriptions of US private pensions as taxed by France as the country of residence appear to reflect the treaty as it stood before 2004 and are outdated for the amended treaty.

• Contributions are a separate question: Article 18(2), added by the 2004 protocol, allows someone working in France who takes part in a US pension or retirement arrangement to deduct contributions to it from French taxable income, under specific conditions
• Article 18(1) speaks of pensions paid in consideration of past employment. Whether an IRA not tied to an employer, such as one funded only by rollovers, squarely fits that wording is not fully resolved in the sources the knowledge base reviewed; professional practice treats traditional IRAs like employer pensions, but get case-specific advice if the distinction could matter for you

Government and military pensions: the same rule, no nationality exception

Since the 2004 protocol, a US federal civil service pension, a state or local government pension or a US military pension paid to a French tax resident is governed by Article 18(1), the same rule that applies to private pensions, IRAs and 401(k)s. It is taxable only by the United States as the source country, wherever you live. The US Treasury’s Technical Explanation of the protocol and the US Senate’s report on it both state that Article 18 now governs these pensions.

There is no French-nationality exception for pensions under the amended treaty. The old paragraph 2 of Article 19, which could carry nationality-based treatment for government pensions, was deleted by the 2004 protocol and nothing equivalent was put into Article 18. Many other US tax treaties do keep that kind of exception, which is why general guidance on government pensions does not always match the France treaty.

A nationality exception does survive in Article 19, but only for current government salaries. It concerns someone actively working for a government, not a retiree, and has no bearing on a monthly pension.

Roth IRAs and Roth 401(k)s: not settled

The treaty text predates the modern Roth accounts and does not mention them. A French Senate official question and answer on this exact point noted that, because Roth contributions are not deductible and Roth withdrawals are not taxed in the US, the French tax administration (DGFIP) could take the position that Roth distributions are taxable in France, since the treaty gives them no explicit exemption.

At least one professional cross-border advisory source takes the opposite view: that Roth IRAs are US retirement accounts covered by the treaty’s pension article, so their tax-free character is kept when the holder lives in France.

These positions disagree, and whether France recognizes the US tax-free character of qualified Roth distributions remains an open, officially acknowledged grey area. Get written, individualized guidance from a cross-border tax professional rather than assuming that Roth income will be tax-free in France, or that it will not.

How US retirement income goes on the French return

France taxes its residents on worldwide income, so income the treaty leaves to the US must still be declared. US Social Security, IRA and 401(k) distributions and US pensions are reported first on form 2047 (« Revenus de source étrangère »), following its official notice, and then carried to the main return, form 2042. They count toward the taux effectif, the rate applied to your other French-taxable income, even though no net French tax is owed on them.

The impots.gouv.fr pensions page separates two kinds of foreign pension income on form 2042:

• Foreign pensions that carry a tax credit equal to the French tax (« un crédit d’impôt égal à l’impôt français ») go on lines 1AL–1DL and are also carried to form 2047
• Foreign pensions that do not carry that credit go on lines 1AM–1DM

CSG and CRDS on US pensions: only if you are in the French health system

CSG and CRDS are French social levies, separate from income tax. For 2026, the CSG rates on pension income depend on your revenu fiscal de référence (RFR) bracket, and CRDS is added at 0.5%. These levies apply to pensions, French or foreign, only when you are both tax-resident in France and covered by a French compulsory health-insurance scheme such as PUMa (Code de la sécurité sociale, article L136-1; the tax administration’s BOFiP states the same two conditions for pensions). A French tax resident who is not covered by a French scheme does not owe CSG or CRDS on US pensions or US Social Security.

Normal ratetaux normal

8.3%, of which 5.9% is deductible from taxable income

Median ratetaux médian

6.6%, of which 4.2% is deductible

Reduced ratetaux réduit

3.8%, fully deductible

Exemptionexonération

0% for lower-income households

Accounts left to heirs fall under a different treaty

The income tax treaty does not govern what happens to retirement accounts at death. A separate US–France Estate and Gift Tax Treaty, signed on November 24, 1978 and amended by a protocol in 2004, allocates taxing rights between US estate and gift taxes and French inheritance and gift duties. 401(k)s, IRAs and similar US plans typically pass by beneficiary designation outside a will, which interacts with French forced-heirship rules and French inheritance tax. Treat it as a separate question and consult a cross-border estate specialist.