LLC × residence calculator · Edition 2026.09
If you lived in France: how much tax you would pay on your LLC profit
France does not treat a single-member US LLC as transparent by default. Since Carmejane (Conseil d'État, 12 November 2025, No. 502894) the decisive test is the members' limited liability, not management flexibility: that assimilates the LLC to a French SAS and makes it opaque. The decided case involved a two-member LLC, but the same reasoning covers a single-member LLC, which carries the same limited liability. Until you distribute, France does not attribute the profit to you; since the member is assumed to withdraw the full profit that same year, it is taxed as a foreign company dividend at the 31.4% PFU, not on the general scale.
Isaac Cubero · Checked on 14 September 2026 · worldwide income
At $100,000 of profit
On $100,000 of LLC profit, living in France, you would pay about $31,400 a year: a 31.4% effective rate.
worldwide income
| France treats the LLC as an opaque company: the profit you withdraw that year is taxed like a foreign company dividend, at the 31.4% PFU (flat tax) | $31,400 |
| Estimated total | $31,400 |
Sources: BOFiP BOI-IR-LIQ-20-10 (2026 scale) and Law 2026-103 of 19 Feb 2026 (2026 Finance Act), art. 4 · BOFiP BOI-IS-LIQ-20-20 (15% reduced corporate tax rate for SMEs up to €42,500) · Conseil d'État, 12 Nov 2025, No. 502894, Carmejane (Légifrance); Conseil d'État, 24 Nov 2014, No. 363556, Artémis (assimilation method) · 2026 Social Security Financing Act, art. 12 (31.4% PFU), per LégiFiscal, DLA Piper and Banque Transatlantique · Fixed exchange rate 0.86 EUR/USD.
Rank 34 of 38 residences by effective rate at this profit.
- 2026 scale on 2025 income (Law 2026-103 of 19 Feb 2026, +0.9% revaluation): 0% up to €11,600, 11% up to €29,579, 30% up to €84,577, 41% up to €181,917, 45% above. Not used in the base calculation since the LLC is modelled as opaque; it feeds the alternative scenario below.
- PFU 31.4% in force since 1 Jan 2026 (12.8% income tax + 18.6% social levies, after the 2026 Social Security Financing Act).
- No self-employed social contributions, no family quotient, no deductible CSG.
- If a court still applies the pre-Carmejane line (CAA Douai, 12 May 2011, Feelware; CAA Marseille, 2 Feb 2017, Emerald Shores), which treated the LLC as transparent, the full profit is taxed every year on the general scale (up to 45%) even if you withdraw nothing, instead of the 31.4% PFU modelled here: that is a worse scenario, not a better one.
- Carmejane involved a TWO-member LLC; as of today there is no Conseil d'État ruling that squarely settles the single-member case after the 2025 shift, so the opaque reading is the most defensible one but not 100% closed.
- If you manage the LLC from France, the tax authority can argue effective place of management and tax it directly under French corporate tax (25%), Carmejane or not.
- If you hold 10% or more of a foreign company under a privileged tax regime (art. 123 bis CGI), the profit is attributed to you without distribution; the US normally does not count as 'privileged', but Estonia, Cyprus, Dubai or Georgia can qualify depending on the effective rate paid there.
- The inbound-assignee regime (art. 155 B CGI, up to 8 years) exempts part of the income for people relocated to France by their employer; it usually does not cover someone setting up their own LLC on their own.
- BOFiP BOI-IR-LIQ-20-10 (2026 scale) and Law 2026-103 of 19 Feb 2026 (2026 Finance Act), art. 4
- BOFiP BOI-IS-LIQ-20-20 (15% reduced corporate tax rate for SMEs up to €42,500)
- Conseil d'État, 12 Nov 2025, No. 502894, Carmejane (Légifrance); Conseil d'État, 24 Nov 2014, No. 363556, Artémis (assimilation method)
- 2026 Social Security Financing Act, art. 12 (31.4% PFU), per LégiFiscal, DLA Piper and Banque Transatlantique
- Fixed exchange rate 0.86 EUR/USD.
At three profit levels
What you would pay in France depending on what your LLC earns.
| Annual profit | Estimated tax | Effective rate | You would keep |
|---|---|---|---|
| $50,000 | $15,700 | 31.4% | $34,300 |
| $100,000 | $31,400 | 31.4% | $68,600 |
| $250,000 | $78,500 | 31.4% | $171,500 |
And if it were not an LLC
The five cheapest structures from France, distributing all the profit.
| Structure | Corporate | Withholding | You, in France | Total |
|---|---|---|---|---|
| US LLC | $0 | $0 | $31,400 | 31.4%$31,400 |
| UAE free zone | $0 | $0 | $31,400 | 31.4%$31,400 |
| Hong Kong Ltd | $8,250 | $0 | $28,810 | 37.1%$37,060 |
| Bulgarian EOOD | $10,000 | $4,500 | $23,760 | 38.3%$38,260 |
| Georgian LLC | $15,000 | $4,250 | $22,440 | 41.7%$41,690 |
Frequently asked questions
Does a US LLC pay tax if I live in France?
The LLC pays no US federal tax if it has no US activity. France does not treat a single-member US LLC as transparent by default. Since Carmejane (Conseil d'État, 12 November 2025, No. 502894) the decisive test is the members' limited liability, not management flexibility: that assimilates the LLC to a French SAS and makes it opaque. The decided case involved a two-member LLC, but the same reasoning covers a single-member LLC, which carries the same limited liability. Until you distribute, France does not attribute the profit to you; since the member is assumed to withdraw the full profit that same year, it is taxed as a foreign company dividend at the 31.4% PFU, not on the general scale.
How much would I pay in France on $100,000 of profit?
On $100,000 of LLC profit, living in France, you would pay about $31,400 a year: a 31.4% effective rate. The figure comes from applying france treats the llc as an opaque company: the profit you withdraw that year is taxed like a foreign company dividend, at the 31.4% pfu (flat tax) to the profit converted to EUR.
Is France a territorial country?
No: France taxes its residents' worldwide income. The LLC profit goes into your income tax under the country's rule (worldwide income).
Next
The figure is the start. The structure is the decision.
To see France against the other 37 residences: the full ladder.