Following the news that the French tax office proved that footballer Samir Nasri was a French tax resident by tracking his takeaway orders, we look at what powers French tax officials have to examine residency and work.
We already knew that the French tax office had quite wide-ranging powers, but the Nasri case confirms it.
The retired footballer claimed that he lived in Dubai, but the French tax office used a combination of travel data and his Deliveroo account (which showed 212 deliveries to his Paris address in a single year) to prove that he was in fact a tax resident of France. He was then served with a €5 million tax bill, and his bank accounts were frozen. His lawyers say that he plans to appeal.
So just how closely can the French tax office track your everyday activities?
Tax residency – the Nasri case hinged on whether he was a tax resident of France or, as he claimed, of Dubai. The French tax office defines tax residency as having “France as your main residence” or “you spend more than half the year here” – which works out to 183 days per year.
You may also become tax resident if you “work in France” – which is defined as doing half or more of your work in France, or having France as “the centre of your economic interests”.
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Those who are not tax resident in France may also have to complete a non-resident’s tax declaration if they have income in France – including from renting out a holiday home, even for just a few weeks of the year.
The powers
So what powers does the tax office have if it suspects that you are a tax resident of France, or that you have income that should be declared here?
For most people, it’s pretty clear where they live – and those who live in France are obliged to complete the annual tax declaration, even if they have no income here.
READ ALSO: EXPLAINED: Who has to do a tax declaration in France in 2026?✎
But where there is doubt about residency, the French tax office says that it is looking at three main things;
- A permanent place of residence, corresponding to the usual place or residence, or the residence of family (spouse/children)
- The centre of a person’s economic and personal interests
- Time spent in France – in particular stays of more than six months of the year (183 days or more)
Property – any property that you own in France is of course a matter of public record.
Since 2024 all property owners have had to complete a one-off déclaration des biens immobiliers, sometimes referred to as the déclaration d’occupation. This requires property owners to declare whether the property is their main residence, a second home or is rented out on either a short-term (eg holiday rental) or long-term basis.
Declaring the property as your main residence saves you some money in property taxes, but also establishes clearly that you live in France.
Economic and personal interests – this one is more vague, but usually refers to work or investment.
Doing work or earning money in France does not make you automatically into a tax resident (although you will have to declare your French income as a non-resident) – but having the majority of your work or economic interests in France does.
If, for example, you are advertising paid-for services in France, this suggests that you have French income – likewise if tourist rentals are advertised at a French property that you own.
The basic rule of thumb is that if more than half of your work is done in France, then you can be considered a tax resident. The ‘economic interests’ bit refers to people who have the majority of their investments in France, or take the majority of their income from dividends in French companies.
‘Personal interests’ is also vague, but essentially refers to anything in your personal life that could suggest that France is the ‘centre of your interests’ – for example if you have a carte de séjour which declares that you are a French resident, or you are registered in the French health system, which also requires you to declare that you are resident in France. Similarly, swapping your driving licence for a French one on the basis that you are resident in France.
There is no law that people have to live with their spouse and/or minor children – and there is a defined procedure for married couples who are tax residents in different countries – but if you have a spouse/children in France, this could be taken into account along with other factors.
Time spent in France – this one is easier to determine and is based on the simple calculation of more than 183 days per year meaning that ‘more than half the year’ is spent in France.
As the Nasri case shows, travel records can be used to track this – in his case flight data established when he arrived and departed in France.
Social media posts can also be used to prove where someone was at a particular time, and setting your accounts to private won’t necessarily help – since 2024 tax authorities have been granted the power to create fake accounts and solicit information and services on social media.
And finally, even records from private companies like Deliveroo can be used to establish a pattern of residency such as having regular deliveries to your home.
Celebrities
The high-profile cases of tax investigation tend to involve either celebrities or wealthy business people.
So do they really do all this with ordinary people? Usually no – but an investigation can be triggered by any anomaly within your tax declarations or accounts, or on the basis of receiving a tip-off.
The tax office has an investigations team which has wide policing powers and is often used for tricky investigations – when France decided to begin seizing the assets of Russian oligarchs in 2022, tax inspectors were assigned to the job.
The tax office also has the power to seize assets – including property – and freeze bank accounts of those who have large outstanding tax debts.
En bref, it’s probably easier just to be honest.
