An acquisition framework for family offices and private banks: market depth from the state's deed register, the holding-structure decision, 23 home-country tax pairings, verification, access and process.
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This guide is written the way an acquisition memo is written: the market first, then the structure, then the tax pairing with your home country, then verification, access and process. It is built from the French state's deed register (DVF) and from this office's published, register-matched record — nothing here asks to be taken on trust.
The figures below are the acquisition map: where the depth is, where the ceilings are, and how thin the air gets above €10M in each market.
| Market | €3M+ villa sales | Volume | ≥€10M | Register ceiling |
|---|---|---|---|---|
| Saint-Tropez & the Gulf | 1010 | €7.1bn | 170 | €85.5M |
| Between Nice and Monaco | 359 | €2.8bn | 63 | €59.0M |
| Saint-Jean-Cap-Ferrat | 178 | €2.4bn | 67 | €200.0M |
| Cannes and its hills | 309 | €2.1bn | 46 | €46.5M |
| Antibes incl. Cap d'Antibes | 170 | €1.1bn | 22 | €65.9M |
| Mougins | 184 | €1.1bn | 16 | €34.5M |
| Grasse back-country | 88 | €386M | 1 | €17.0M |
| French Riviera total | 2944 | €20.6bn | 428 | €200M |
Direct personal ownership is the simplest position: French real-estate wealth tax (IFI) applies once net taxable French property exceeds €1.3M, and French succession rules — including reserved shares for children — reach French immovables at death. Simplicity is its argument; exposure is its price.
A French SCI (société civile immobilière) is the standard vehicle for shared family ownership and lifetime planning. It is fiscally translucent rather than protective: IFI still applies, and whether the shares are treated as movable or immovable property at death is precisely what varies treaty by treaty — the question the pair briefs exist to answer.
A foreign entity or trust triggers France's annual 3% tax on the property's market value (article 990 D, Code général des impôts) unless an exemption applies — typically for entities established in the EU or in a state bound to France by an administrative-assistance convention, filing the annual disclosure of their ownership chain (article 990 E). The Conseil d'État held on 9 May 2019 (n° 426431) that trusts fall within the tax whether or not they have legal personality. With today's reporting standards making ownership chains visible regardless, the contemporary case for a structure is governance and succession design, not opacity.
This section is a framework, not advice: the structuring decision belongs with your counsel, made before the search begins.
France taxes what sits on its soil; what your home jurisdiction does about it differs radically across the treaty network. Each brief below opens with the situation it answers — quoted here verbatim.
| Pair brief | The situation it answers (from the brief) |
|---|---|
| France–Australia | An Australian owner, arriving with no wealth tax and no death duties behind them, so the French charges are not doubled — they simply stand alone. |
| France–Belgium | A Belgian owner, where the question is usually not the villa but the company above it, and where the two administrations have disagreed for years. |
| France–Brazil | A Brazilian family, holding an asset the convention was never written to reach for wealth-tax purposes, and a transmission no instrument coordinates. |
| France–Canada | A Canadian family, where the two systems do not even use the same instrument at death and cannot simply be netted against each other. |
| France–China | A family resident in mainland China, frequently advised on the wrong instrument, since the China convention reaches neither Hong Kong nor Macao. |
| France–Germany | A German owner or an arrival to France, holding the rarest combination on this shelf: a wealth tax inside the treaty and a convention that reaches gifts. |
| France–Hong Kong | A Hong Kong family, or its adviser, weighing a Riviera villa held personally, through a company, or through a trust the agreement happens to name in its own text. |
| France–India | An Indian resident or a non-resident member of the diaspora, for whom the binding constraint is often not the tax at all but how the money is permitted to leave. |
| France–Ireland | An Irish family, meeting French duty and a beneficiary-based Irish charge that no convention coordinates — so the acquisition-day choices carry the weight. |
| France–Italy | An Italian owner or an arrival to Italy, where the incentive frequently sits on the home side and reverses the direction of the planning. |
| France–Japan | A Japanese family, in the one relationship where both states levy heavy inheritance taxes on the same villa and nothing coordinates them. |
| France–Luxembourg | A family holding French property through Luxembourg — the arrangement this relationship is known for, and the one the courts have examined most closely. |
| France–Mauritius | A Mauritian resident, where the treaty gives France its taxing right over shares through a substantial-participation threshold rather than a property test. |
| France–Monaco | A Monaco resident, where nationality is asked before residence and where the gap between two conventions is where the planning actually sits. |
| France–Netherlands | A Dutch household comparing a French wealth tax against a home charge that resembles one, is not one, and has been rewritten repeatedly. |
| France–Poland | A Polish family whose French file has one taxing state and whose Polish file, at death, may have another — with nothing between them. |
| France–Singapore | A Singapore resident, arriving from a system with no capital-gains, wealth or estate duty, so most of the treaty machinery is theoretical for a private owner. |
| France–Spain | A Spanish resident, in the one relationship on this shelf where two live wealth taxes meet and the treaty has to organise the overlap. |
| France–Switzerland | A Swiss resident — or a forfait taxpayer, whose treaty position is a question in itself — holding property in a relationship with no succession convention since 2015. |
| France–The Nordics | A Danish, Swedish, Norwegian or Finnish owner, for whom the first question is which of four quite different French treaties governs the file. |
| France–United Arab Emirates | A resident of the Emirates, where nothing answers on the home side and the convention consequently does more work than most on this shelf. |
| France–United Kingdom | A British owner or buyer, reading a relationship governed by two conventions while the home side has just been rebuilt around residence rather than domicile. |
| France–United States | A United States person — wherever resident — for whom the convention expressly preserves the right of the other state to tax as though it did not exist. |
France publishes every property deed since 2014 — price, date, commune, parcels — in the DVF register. That single fact reorders due diligence: asking prices and advertised «records» stop being evidence, because the register can be consulted directly.
Two register limits are worth knowing. The agency behind a sale is never recorded, so no agency ranking can be verified from the register — which is why this office publishes its own register-matched record instead of asking for trust. And declared villa surfaces are unreliable, so whole-property comparisons beat per-square-metre arithmetic above €3M.
Every price in this guide can be checked in the register. The register data behind this site's analytics is individually qualified under a proprietary protocol.
The advertised market is what portals show. Above €10M a meaningful share of transactions never appears there; access at that level runs through relationships. This office maintains an off-market register of unadvertised sale mandates and qualified buyer briefs across the six markets above.
Discretion works in both directions: a sale's price becomes public register data by law, but identities do not. Client identities are never published, and a sale is referenced only with the parties' consent — never beyond what the register itself makes public.
Schools. The international-school map splits into three belts — Sophia Antipolis, Nice and Monaco — with 37 register-verified campuses; the 30-minute catchment around the International School of Monaco alone overlaps €4.7bn of €3M+ villa volume. The schools brief maps them.
Daily infrastructure. Restaurants, clubs, crewed water — the private concierge notes cover the five markets with verified entries.
Process. Accepted offer → compromis de vente within days → 10-day statutory cooling-off → notarial phase (searches, planning, financing) of eight to ten weeks → acte authentique. Roughly three months end to end.
This guide's method is the office's method: published numbers, checkable in the register. The track record is published deal by deal, and the profile page carries the verifiable facts behind the practice.
Four decisions organise an acquisition well before any villa is chosen. First, the market: the Riviera recorded 2,944 villa sales at €3M or above over 2014–2025 — €20.6bn in total, per DVF, the French state's deed register — with Saint-Tropez the single deepest market (1,010 sales). Second, the holding structure: personal ownership, a French SCI or a foreign entity carry different wealth-tax, 3%-tax and succession consequences. Third, the home country: France's treaty with your jurisdiction often decides the structure question — a dedicated France–[country] brief exists for 23 jurisdictions. Fourth, verification: every price in this guide can be checked in the register, and any agency's claims should be tested the same way.
Yes, and many do — but France levies an annual tax of 3% of market value on property held by legal entities (article 990 D of the tax code) unless the entity qualifies for exemption, typically by being established in the EU or a treaty state and disclosing its ownership chain annually (article 990 E). The Conseil d'État confirmed in 2019 that trusts fall within the tax whether or not they have legal personality. Since reporting standards now make ownership chains visible in any case, the modern rationale for a structure is governance and succession planning, not discretion. The choice is counsel's work; the France–[country] briefs map the treaty side of the question.
A typical timeline runs about three months from accepted offer to deed. The compromis de vente (preliminary contract) is usually signed within days of agreement; a 10-day statutory cooling-off period follows for the buyer; the notarial phase — searches, planning certificates, financing where used — commonly takes eight to ten weeks; the acte authentique then transfers title. The deed's price, date and parcels are later published in the state register.
Through DVF, the French state's register of property transactions: every deed since 2014 is published with its price, date, commune and parcel identifiers. Two limits matter: the register never records which agency handled a sale — so advertised track records cannot be checked there, only a published, register-matched record can — and villas' declared surfaces are unreliable, so whole-property comparisons beat per-square-metre arithmetic. The figures on this page are register figures, individually qualified under a proprietary protocol.
Enquiries on this market reach this office directly.
Emailelena@elenaagueeva.comTelephone+33 7 66 44 02 34WhatsAppMessage this office
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