Does France tax US Social Security, 401(k)s and IRAs?
How the US-France tax treaty treats Social Security, 401(k), IRA, pension, Roth and HSA withdrawals, dividends and interest for Americans in France.
Updated · Expat Academy · Education, not advice
Once you're a French tax resident, France taxes your worldwide income, and the US keeps taxing you because you're a citizen. The 1994 US-France tax treaty decides who gives way. For most American retirees the answer is good news on retirement income, and less good news on investment income.
The short answer, account by account
| Income | Who taxes it | In practice |
|---|---|---|
| Social Security | Only the US (Article 18) | France counts it, then credits the tax: no French income tax |
| 401(k), traditional IRA, pension | Only the US (Article 18) | The same: no French income tax, lump sums included |
| Roth IRA, qualified | Unsettled | Credited like a pension, or taxed at the French scale |
| HSA withdrawals | No treaty rule | Cautiously, taxed at the French scale |
| Dividends and gains on US shares and funds | Both | France credits its 12.8% income tax for US citizens; social charges may remain |
| US interest | Both | France taxes it; the US gives the credit |
How France's income tax works
France taxes the household together. Income is divided by the number of "parts" (1 for a single person, 2 for a married couple), taxed per part on a progressive scale, and multiplied back. For 2026 (2025 income):
| Income per part | Rate |
|---|---|
| Up to €11,600 | 0% |
| €11,600 to €29,579 | 11% |
| €29,579 to €84,577 | 30% |
| €84,577 to €181,917 | 41% |
| Over €181,917 | 45% |
Pensions and Social Security get a 10% deduction, with a floor per pensioner and a cap per household. Investment income is usually taxed separately at a 12.8% flat rate, plus social charges.
Credited income still sets your rate
France counts your US pension income in full, works out the tax, then gives a credit equal to the French tax on that income. The income still counts when France sets your rate (the taux effectif). So anything France does tax, such as rent from a French property or HSA withdrawals, is taxed at the rate your whole income reaches, not the lower rate it would bear on its own.
The part people underestimate: social charges
French social charges are separate from income tax: 18.6% on dividends, interest and securities gains from 2026. Under one reading of the treaty, only the 7.5% solidarity levy applies to US dividends and gains of US citizens; others charge the full rate in practice. On a taxable account this is often the largest French bill. See French social charges on US investments.
The paperwork that makes the credit work
US income goes on Form 2047 (foreign income) and into the credit lines of Form 2042, along with Form 3916 for each foreign account. Unreported, it's simply taxed. A cross-border preparer who files both returns every year is worth the fee in most cases.
What it means for planning
Because France treats each kind of account so differently, the same spending can cost very different amounts depending on which account it comes from, and some choices are best made before your French residence starts. The France course works through them with your own numbers; see also tax planning before moving to Europe.
Questions
Does France tax US Social Security?
Under Article 18 of the US-France tax treaty, US Social Security paid to a US citizen resident in France is taxable only in the US. France counts it on your return to set your tax rate, then gives a credit equal to the French tax on it, so no French income tax is due on it.
Are 401(k) and IRA withdrawals taxed in France?
They're treated like pensions under Article 18, taxable only in the US. France includes them on the return and credits the tax back. A 2020 ministerial answer confirmed that lump-sum payments are covered as well as regular ones.
Are Roth IRA withdrawals tax-free in France?
It isn't settled. Some advisers treat qualified Roth withdrawals like pensions, which France credits; others expect France to tax them at its income tax scale. A cautious plan assumes they may be taxed.
Do I have to report US income on a French tax return if it's exempt?
Yes. The credit only works if the income is declared, on Form 2047 and the credit lines of Form 2042. US income that isn't reported is simply taxed.
Go deeper
- F3 French income tax on your US income: The French scale, the household quotient, the pension deduction, and the treaty credit that removes French tax from US pensions and Social Security, line by line.
- F4 Social charges (prélèvements sociaux): The 18.6% on investment income is the French tax the treaty may not remove. What it is, what it covers, the debate over the credit, and how to keep it down.
- F5 Each account in France, and the moves to make before you go: How France and the US tax a dollar from a pre-tax account, a Roth, an HSA and a taxable account, why the rates differ so much, and what to do while only the US taxes you.
Sources
- US-France income tax convention (1994), irs.gov
- 401(k), IRA, Social Security: France-US retirement tax, Bensaid Avocats
- How France taxes 401(k), IRA and Roth withdrawals for Americans, Skybound Wealth
- Capital gains tax on US securities in France for US citizens, Levitt Capital
- Barème de l'impôt sur le revenu 2026, Tout sur mes finances
Education, not advice. This guide explains general rules as of the date above. Rules change every year; confirm your own situation with a qualified adviser in the US and in France.