Payroll tax

Salaries paid to expatriate employees must be included in the payroll tax base.

As a reminder, the payroll tax is payable by companies not subject to VAT or not liable for VAT on at least 90% of their turnover during the calendar year preceding the payment of salaries.

In the HSBC case No. 460386, dated July 13, 2022, the French Council of State recently ruled that salaries paid to expatriate employees fall within the scope of the payroll tax base, even when those salaries are not subject to the General Social Contribution (CSG).

Therefore, in the context of their international development projects, companies subject to the payroll tax must pay particular attention to their tax filings, especially those relating to the payroll tax.

Are you planning to send one or more of your employees on assignment abroad and would like assistance with the tax aspects of expatriation or secondment?

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