The implications of buying, selling and renting French Riviera property for residents of Belgium — from the 1964 and 1959 conventions, the signed successor of 2021, the tax code and the state's own transaction register.
Written by Elena Agueeva — licensed French real-estate broker (CPI 06052023000000132), Cannes. First published 2026-07-19 · last reviewed 2026-07-20. Method: statutes and doctrine verified against Légifrance and BOFiP through the Chiron Legal Corpus; market figures from DVF (DGFiP), individually qualified. General information — personalised structuring requires your own counsel.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
The relationship rests today on two instruments of the early treaty era, with a third signed and waiting. The convention of 10 March 1964, in force since 17 June 1965, governs income taxes; it has been amended by the avenants of 15 February 1971, 8 February 1999, 12 December 2008 — which preserved the frontier-worker regime — and 7 July 2009, and it carries, in its consolidated presentation, the multilateral instrument signed by both states on 7 June 2017, including the principal-purpose test under which a treaty advantage can be refused where obtaining it was a principal object of an arrangement. The succession convention of 20 January 1959, in force since 12 June 1960, is among the few France has concluded: it divides the estate of a person dying domiciled in either state into two masses, one taxable in France and one in Belgium. Neither instrument covers taxes on wealth, and the 1964 text predates the French wealth tax by nearly two decades — an absence examined in section I.
The signed successor. On 9 November 2021 the two states — Belgium signing through its federal government and the five governments of its communities and regions — concluded a new convention on income and fortune designed to replace the 1964 text. It aligns the relationship with current treaty practice: the French wealth tax and the social contributions are listed by name, gains on property-rich shares are assigned to the state where the property stands (article 13 §2), and property wealth follows the same rule (article 21). It is not in force. The French approval bill had, when the government last answered Parliament in September 2025, yet to be tabled, adjustments to the new rules on public remuneration remaining under discussion between the two administrations; the Belgian side requires the assent of the federal parliament and of the community and region assemblies. Under article 29, the convention takes effect for the relevant French taxes only from the year following that of its entry into force, and its article 29 §3 terminates the 1964 convention alone — the 1959 succession convention continues regardless. Section 4 tracks the instrument's progress edition by edition.
Residence does the sorting. A person within the tax of both states is assigned by article 1 §2 of the 1964 convention on the familiar cascade: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. The 1959 convention runs its own domicile test to the same design for successions. The administration's commentary on both conventions dates from 2012 to 2016; where commentary and text diverge, this brief follows the text.
The Belgian side keeps its own accents. Belgium taxes the worldwide estate of its residents under succession scales set by region — Flanders, Brussels-Capital and Wallonia each legislate their own — and, as a rule, leaves capital gains realised in the normal management of private wealth outside its income tax. This brief states Belgian law at orientation level only; its verified ground is the French side and the conventions, and the Belgian reading belongs with the family's Belgian advisers.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1964 convention (CML consolidation) arts. 1, 2; 1959 convention arts. 1–3; 2021 signed text (not in force) as published by the French administration; BOI-INT-CVB-BEL-10 (2012–2016 vintage — the text prevails)
Seen from Belgium, the Riviera's €3M+ villa market leads with the Saint-Tropez peninsula, the largest register of its kind on the coast: 1006 qualified sales for €7,049M across 2014–2025, at a €4.9M median and a €85.5M ceiling. Cannes and its hills — the Super Cannes quarter on the Vallauris side included — contributed 306 sales for €2,066M, with 37% of value in eight-figure transactions, while Saint-Jean-Cap-Ferrat remains the narrowest and most expensive register: 178 sales for €2,375M at a €6.5M median. The past 36 months alone account for €3,970M across the three.
| Market | Sales (12 yrs) | Total €M | Median €M | Ceiling €M | 36-mo sales | 36-mo €M | ≥€10M (36-mo) |
|---|---|---|---|---|---|---|---|
| Saint-Tropez & the Gulf | 1006 | 7,049 | 4.9 | 85.5 | 353 | 2,718 | 68 |
| Cannes & its hills | 306 | 2,066 | 4.9 | 46.5 | 98 | 697 | 16 |
| Saint-Jean-Cap-Ferrat | 178 | 2,375 | 6.5 | 200.0 | 53 | 555 | 19 |
Source: DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales ≥ €3M, 2014–2025, estate-deduplicated — the same convention as the published Riviera Intelligence hub, so this brief and the public pages cannot disagree. DVF through 2025-12-31.
The public record itself describes how the Riviera is held. This brief reads it in aggregate — the State's transaction register alongside the public company registers, all of it already published, anonymised in processing, and with no individual holding ever identified. Across 20 Riviera communes, 29% of the ownership positions studied are held from outside France. Belgium accounts for 3% of those foreign-held positions in the current study — a modest share against Belgium's long-standing presence on this coast, with the Saint-Tropez peninsula and the Cannes arc both represented. One structural fact stands out even at this depth: a majority of Belgian-resident positions — 67% in the current study — are held through a company rather than in direct personal ownership, the inverse of the German pattern recorded in this series. That preference for the corporate route, the SCI above all, is precisely where the two states' conventions diverge, and sections I bis and II examine what the wrapper now earns a Belgian family — and what it no longer does.
Aggregates only, drawn from public sources under their re-use conditions; no individual holding is identified or published. Residence attribution follows the address of record. Figures refresh with each edition.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · DVF register, estate-deduplicated · ownership aggregates from public registers only
The acquisition follows the standard French sequence: offer, compromis de vente with a ten-day cooling-off period, deposit of customarily 10%, conditions precedent, and the authentic deed before the notaire, who collects the duties and registers title. The notaire acts as a public officer rather than as the buyer's counsel, and Belgian buyers typically retain their own advisers in addition. Because the holding structure carries more consequence in this relationship than in most — the SCI changes the treaty analysis at three separate points, examined in sections I bis and II — the structure questions deserve to be answered before the compromis is signed; the acquiring vehicle is difficult to change once the process is under way.
| Item | Basis | Amount | Borne by |
|---|---|---|---|
| Transfer duties & land-registration taxes | ≈ 5.81 % of price (standard-rate département; existing property) | €284,526 | Buyer |
| Notaire's émoluments & disbursements | ≈ 1.1–1.4 % at this price point (regulated sliding scale) | ≈ €61,250 | Buyer |
| Indicative all-in acquisition costs | ≈ 7 % on an existing property | ≈ €345,776 | Buyer |
| Agency fee | Per mandate; conventionally included in the advertised price | — | Per mandate |
The notaire itemises duties and émoluments precisely on the actual deed structure; a new-build VAT regime, furniture carve-outs or mortgage security will alter the arithmetic. The figures above reflect the standard published scales and are stated for orientation.
CGI article 964 institutes the annual tax on real-estate wealth above €1,300,000 of taxable assets. For persons not domiciled in France the base comprises French-situs property together with the fraction of any company's shares representing French property (article 964-2°), so the SCI alters the reporting rather than the exposure. Here the treaty position is an absence rather than a rule: the 1964 convention covers income taxes alone (article 2), predates the French wealth tax, and extends only to future taxes of identical or analogous nature — a description a tax on wealth does not meet. A Belgian resident therefore bears the IFI under French domestic law, without treaty restriction and, Belgium levying no wealth tax of its own, without double charge. The statute itself contains one calendar of note: a person who becomes French-domiciled after five years abroad is taxed for five years on French assets only (article 964-1°, al. 2) — a domestic provision, not a treaty right, and one the signed 2021 text would leave to domestic law as well.
Recurring charges follow the property. Taxe foncière runs at communal rates; for furnished secondary residences, communes in the zone tendue — a category that includes the marquee Riviera communes — may vote a surtaxe on the taxe d'habitation for second homes, and the annual occupancy declaration is required of all owners. Because these rates are communal and year-specific, this brief's edition cycle re-verifies them rather than freezing them.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965; 1964 convention art. 2 (income taxes only — no wealth-tax article); cost scales stated for orientation, itemised at engagement
Holding structures are presented here, in keeping with this line's doctrine, as questions for analysis rather than as recommendations. For a Belgian buyer the analysis carries one organising fact: the SCI, the route Belgian families have most often taken on this coast, is treated differently by each of the three French taxes it touches — and differently again on each side of the border.
| Question | What it decides | The Belgian-specific reading |
|---|---|---|
| Direct ownership? | Simplicity; situs taxation for gains and for succession | The villa answers to France on every count — income, gains, wealth and succession duty (1959 convention, art. 4) — with Belgium granting exemption or credit; the analysis is short and the outcomes are certain |
| French SCI? | Governance, co-ownership, French financing, lifetime transmission | The property fraction stays within the IFI in any event; on a sale of the shares the two states' readings of the 1964 text diverge (section II); at death the 1959 convention sends the shares to Belgium (art. 8), outside French duty — the one point where the wrapper retains its full treaty value |
| Belgian or other foreign company? | Confidentiality, consolidation | The annual 3% tax question and its disclosure regimes (CGI arts. 990 D and 990 E — EU entities exempt on filing); property-fraction IFI in any event; at death, shares of a Belgian company likewise fall within article 8's residuary rule for a Belgian-domiciled deceased |
| Foundation or trust in the chain? | Dynastic control | The Belgian family's habitual instruments are the société simple and the private foundation rather than the trust; where a trust does touch French assets or French residents, trustee reporting under CGI article 1649 AB and the dedicated levy of article 990 J apply. Either route is examined with counsel on both sides before the compromis |
| Usufruct / bare-ownership split? | Lifetime transmission at reduced values | Works identically on the French side; and because lifetime gifts sit outside the 1959 convention, French gift duty applies on French-situs assets in full — the démembrement accepts a known French charge today in exchange for certainty at death |
The financing conversation runs as it does elsewhere on this coast: a loan from the buyer's bank, secured on a pledged portfolio, so that liquidity remains invested while the debt reduces the taxable base. The mechanics are lawful and the code anticipates them. Acquisition debt owed to a bank is deductible from the IFI base under CGI article 974, while financial assets sit outside that base altogether. The boundaries are three. Loans repaying capital at term are deemed to amortise, the deduction declining pro rata over the loan's life, and by one twentieth a year where no term is fixed. Where taxable property exceeds €5M and debts exceed 60% of its value, the excess is deductible only as to half, unless the borrower shows the loan was not contracted mainly for tax. And the debt must be real — actually drawn, actually serviced, at market terms; routed through a shareholder account of an SCI it ceases to count for valuing the shares (article 973). Leverage moderates the IFI in its early years and fades by design, a calendar best examined before the compromis rather than after. The 1959 convention adds a succession counterpart: debts secured on the villa are deducted from its value for the duty the treaty allocates to France (article 9), so the mortgage follows the asset it financed at death as well.
The 1959 convention divides the estate of a person dying domiciled in either state into two masses. The villa held directly answers to French duty as the state where it stands (article 4); so do other French immovables, while claims secured by mortgage are expressly excluded from the immovable class. Everything outside articles 4 to 7 — shares in French companies, claims on French debtors, French securities and portfolios — is taxable only in the state of the deceased's domicile (article 8). For a Belgian-domiciled owner the administration's own commentary draws the consequence plainly: those French assets cease to be subject to French mutation duty, France retaining them only for the calculation of its effective rate on what it does tax (article 10 a). Belgium, taxing its residents' worldwide estates, then credits French duty on the immovables France has taxed (article 10 b). An SCI therefore relocates the succession taxing right on the villa's value from France to Belgium — from the scale of CGI article 777, progressive to 45% in the direct line, to the regional Belgian scales, which Flanders, Brussels-Capital and Wallonia each set for themselves, a matter for the family's Belgian counsel.
Two boundaries deserve equal prominence. Lifetime gifts sit outside the 1959 convention altogether: a gift of the villa, of its bare ownership, or of the SCI shares themselves falls under French domestic territoriality (CGI article 750 ter, which reaches property-rich shares by its own terms), so the shelter the convention provides at death does not travel to the gift the family may prefer to make in life — and the Belgian registration of movable gifts, since the closing of the foreign-notary route in December 2020, belongs with Belgian counsel. And the shelter turns on domicile: it protects the estate of a deceased domiciled in Belgium, so a family that later moves to France re-enters French worldwide territoriality, the convention then working in the opposite direction. Before either state determines the duty, the civil law determines who inherits: both states apply EU Regulation 650/2012, so a Belgian national habitually resident in France may elect Belgian law for the succession as a whole, while the fiscal allocation above is unaffected by the election. The choice of law, the matrimonial regime carried into the purchase, and the calendar of any gifts are questions for counsel on both sides, best answered before the compromis.
The structure commonly proposed alongside the loan divides ownership itself: the buyer retains the usufruct, the use of the villa and its income for life, and gifts the bare ownership to the next generation. The code values the split by age. Under the scale of CGI article 669, bare ownership represents 60% of full value where the usufructuary is between 61 and 70, and 70% between 71 and 80; the gift bears duty on that fraction alone, at today's value, and the reunification of full ownership at the usufructuary's death is not a further taxable transmission. Article 751 sets the conditions — a notarised gift, made more than three months before death, valued on the article 669 scale — and article 968 keeps the full value within the usufructuary's IFI base, so the wealth tax is unmoved. For a Belgian family the treaty setting gives the choice its particular shape: the gift falls outside the 1959 convention and bears French duty in full today, where the SCI's succession shelter operates only at death and only while Belgian domicile holds. The two routes thus answer different questions — the démembrement settles the villa's own transmission now; the SCI moves the taxing right for later — and the forced-heirship consequences of either, present in both states' civil law, belong with the family's counsel alongside the choice-of-law election noted above.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 669, 750 ter, 751, 777, 779, 968, 973–974, 990 D–E, 990 J, 1649 AB; 1959 convention arts. 4, 8, 9, 10; BOI-INT-CVB-BEL-20; EU Reg. 650/2012
For the villa held directly, the 1964 convention is categorical: income from immovable property, including gains on its disposal, is taxable only in the state where the property stands (article 3 §§1 and 4). France therefore taxes first and alone. For a Belgian-resident seller the French charge runs under CGI article 244 bis A: the taxable gain is reduced by an ownership-duration allowance of 6% for each year of ownership beyond the fifth and 4% for the twenty-second (article 150 VC), the income-tax component then applying at 19% (article 200 B) and extinguishing after 22 years, while the social levies extinguish after 30 and follow the seller's social-security affiliation — for owners within the European social-security coordination, generally at the reduced solidarity rate, verified at engagement. Taxable gains above €50,000 bear in addition the progressive surcharge of article 1609 nonies G, which reaches 6% at the levels this market transacts. Belgium being a member state of the European Union, the accredited fiscal-representation requirement borne by third-country sellers does not arise (article 244 bis A, IV bis); on its own side, Belgium exempts what the convention assigns exclusively to France, retaining the income for the progression of its rates alone (article 19 A).
| Ownership | Allowance (150 VC) | Taxable gain | Income tax at 19% | Surcharge (1609 nonies G) |
|---|---|---|---|---|
| 10 full years | 30% | €700,000 | €133,000 | €42,000 |
| 15 full years | 60% | €400,000 | €76,000 | €24,000 |
| 22 full years | 100% | — | — | — |
Social levies apply in addition until the thirtieth year, at the rate the seller's affiliation commands. On the holding periods this coast's pocket studies measure — frequently two decades and more — the income-tax component has often already extinguished by the time of sale. Figures computed on the statutory scales; the actual base is itemised on the deed (works, acquisition costs) at engagement.
Where the villa is held through a property-rich company, the analysis changes character, because the 1964 text carries no express clause for such shares and each state has read the silence its own way. The French reading is settled at the highest level: the final protocol permits France to treat as immovable the shares of transparent property companies, the administration reads that stipulation as non-limitative and extends it to property-rich SCIs generally, and the Conseil d'État upheld that interpretation on 24 February 2020 (n° 436392). France accordingly taxes a Belgian resident's gain on such shares under article 244 bis A, as it taxes the villa itself. Belgian practice, by contrast, has historically classed the same shares as movable property within the residuary article 18 — taxable only in the state of residence, where gains realised in the normal management of private wealth are, as a rule, outside the Belgian charge. That divergence once carried an obvious attraction; it now carries mainly risk. The French assessment is collected at the deed, the divergence leaves the double-taxation question to a mutual-agreement procedure rather than to a clear rule, and the signed 2021 convention closes the subject at its root: its article 13 §2 assigns gains on shares of companies, fiducies and comparable institutions whose value derives more than half from immovable property to the state where the property stands. A seller weighing an asset deal against a share deal prices the French charge under either route; what the share route still changes is examined with counsel, before marketing begins rather than in the course of negotiation.
Families who sell and then move away from France sometimes ask whether an exit charge applies on departure. The answer is narrower than the name suggests. France's exit tax (CGI article 167 bis) is aimed at securities, not at property: it concerns persons who were French-domiciled for at least six of the ten years before leaving, and taxes the unrealised gains on substantial securities holdings — positions whose combined value exceeds €800,000, or stakes of 50% or more in a company's profits, the second criterion catching a controlling holding whatever its value — as they stand on the day of departure. A villa already sold has settled its own tax under the regimes above, and the sale proceeds themselves are not within the charge. Shares of a family SCI follow the property rather than the portfolio: so long as the company keeps the ordinary income-tax regime, gains on its property-rich shares remain within the real-estate regime (CGI article 150 UB) and outside the exit tax — the French right to tax a later sale being preserved instead by article 244 bis A. A company that has opted for corporation tax changes the classification, and with it the analysis; the option belongs on the pre-departure checklist. The residence clock matters equally: a person who leaves before six years of French domicile within the preceding ten stands outside the latent-gains charge altogether, so the family that tried France for a few years and moved on typically departs untouched; gains already placed under a tax deferral follow their own rules and are reviewed at engagement. Where the machinery does apply, payment is generally deferred, and the assessment lapses automatically where the securities are still held two years after departure — five where the portfolio exceeded €2.57M — or upon a return to France. For most sellers the exit tax is therefore a question of calendar and paperwork rather than of cost; the destination-specific mechanics of the deferral are settled at engagement.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1964 convention arts. 3, 18, 19 A + protocole final §2; CE n° 436392 (24 Feb 2020); CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A (incl. IV bis), 1609 nonies G; 2021 signed text art. 13 §2 (not in force)
A rental year before purchase remains the classic first step, and it carries one caution worth stating clearly: French tax domicile under CGI article 4 B turns on the location of the foyer, the principal place of stay, and the centres of professional and economic interest — none of which defers to a lease. A Riviera villa that becomes the family's effective home can establish French residence, with worldwide consequences, well before any purchase; a person then within the tax of both states is assigned by the cascade of article 1 §2 of the 1964 convention, permanent home first. Unlike the German relationship examined earlier in this series, the Belgian instruments grant no treaty-anchored grace years to the newly arrived, so the calendar of the trial rests on domestic law alone. The choice between furnished seasonal lettings and the one-to-three-year civil lease determines exit flexibility, and is best matched to the trial's real purpose.
French-source rental income of non-residents — the furnished lettings common at this price point included — is taxed under the minimum-rate regime of CGI article 197 A, at no less than 20% up to the second-bracket ceiling and 30% above it, unless the taxpayer demonstrates a lower worldwide effective rate; social levies apply in addition, at a rate that depends on the owner's social-security affiliation, for Belgian-affiliated owners generally the reduced solidarity rate, verified at engagement. The convention is categorical on the allocation: article 3 §1 makes income from immovable property, however exploited, taxable only in the state where the property stands. Belgium accordingly exempts the income, retaining it for the progression of its rates alone (article 19 A §§2 and 4); how the exemption is returned on the Belgian side belongs with the family's Belgian advisers.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A; 1964 convention arts. 1 §2, 3, 19 A
Edition 1 — baseline (July 2026). The instruments as they stand: the convention of 10 March 1964 as amended by the avenants of 1971, 1999, 2008 and 2009 and modified by the multilateral instrument, and the succession convention of 20 January 1959, in force since 1960. One watch item leads the file: the convention signed on 9 November 2021 — property-rich gains clause (art. 13 §2), the IFI and the social contributions expressly covered (art. 2), fortune assigned to the situs state (art. 21), a substantial-participation clause reaching former residents (art. 13 §4), the frontier-worker provisions of 2008 preserved (art. 29 §4) — remains unratified on both sides. The French approval bill had not been tabled when the government last answered Parliament (September 2025, after a first answer of February 2025 citing continuing discussions on the public-remuneration rules), and a Sénat question of May 2026 records ratification complete in neither state; the French administration continues to list the text as not in force. Under article 29 the new rules would first reach the relevant French taxes on 1 January of the year following entry into force — 2027 at the very earliest — and the 1959 succession convention is not among the texts the new instrument terminates. This brief will track the ratification from announcement to effect, and re-examine sections I, I bis and II in full when it comes. Further watch items for edition 2: annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; Belgian regional legislation on succession and gift scales; and any refresh of the administration's 2012–2016-vintage commentary on the two conventions. The ownership aggregates of section 2 are refreshed with each edition.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
No. The convention signed on 9 November 2021 awaits ratification by both states: as at July 2026 France has not yet laid the approval bill before Parliament and Belgium's federal and federated assemblies have not yet assented. The 1964 income convention and the 1959 succession convention remain the applicable law, and under its own article 29 the new text would first reach the relevant French taxes on 1 January of the year following its entry into force.
Yes, once French real-estate assets exceed €1.3M, whether held directly or through the property fraction of company shares (CGI art. 964). The 1964 convention covers income taxes only and contains no wealth-tax article, so the IFI applies under French domestic law with no treaty relief to invoke — though Belgium levies no wealth tax of its own, so the charge is never doubled. The signed 2021 text will list the IFI expressly and assign French property wealth to France.
France alone, as the state where the property stands (1964 convention, art. 3), under CGI article 244 bis A with the ownership-duration allowances — the income-tax component extinguishing after 22 years and the social levies after 30. Belgium exempts the gain, retaining it only for the progression of its rates (art. 19 A), and as an EU resident the seller needs no accredited fiscal representative (art. 244 bis A, IV bis).
Not as a plan. France treats property-rich SCI shares as the property itself and taxes the gain under article 244 bis A — a reading the Conseil d'État upheld on 24 February 2020 — while Belgian practice has historically read the same shares as movable and taxable in Belgium alone, where private gains are typically untaxed. What remains of the old asymmetry is a divergence between the two states, not a shelter; the signed 2021 convention ends it with an express property-rich clause (art. 13 §2).
France, as the situs state (1959 convention, art. 4), on the scale of CGI article 777 after the allowances of article 779; the surviving spouse is exempt. Belgium, taxing its residents' worldwide estates under its regional scales, credits the French duty on the immovables (art. 10 b).
Yes, at death. Under article 8 of the 1959 convention, shares in French companies held by a Belgian-domiciled deceased are taxable only in Belgium, outside French mutation duty, France counting them solely for its effective rate (art. 10 a). The shelter does not extend to lifetime gifts, which sit outside the convention and fall under French domestic territoriality (CGI art. 750 ter) — and it lasts only while Belgian domicile does. The 2021 convention, which replaces the income text only, leaves this allocation unchanged.
Yes, and only by France on the treaty's own terms: article 3 of the 1964 convention makes income from immovable property taxable only in the situs state. France applies the minimum-rate regime of CGI article 197 A, at no less than 20% and 30%, with social levies in addition; Belgium exempts the income, retaining it for rate progression alone (art. 19 A).
Rarely, and never on the villa itself. The charge (CGI art. 167 bis) reaches only persons French-domiciled for six of the ten years before departure, and only their unrealised gains on securities — above €800,000 in value, or stakes of 50% or more of a company's profits; the sold villa and its proceeds stand outside, as do family-SCI shares kept under the ordinary income-tax regime (art. 150 UB). Where it does apply, payment is generally deferred and the assessment lapses after two years — five above €2.57M — or upon return to France.
Yes. Acquisition debt owed to a bank is deductible from the IFI base under CGI article 974, and pledged financial assets remain outside the tax altogether. The deduction is bounded: interest-only loans are deemed to amortise each year, and where property exceeds €5M and debt exceeds 60% of its value, the excess counts only as to half unless a mainly non-tax purpose is shown. At death, debts secured on the villa are deducted from its value for the duty the 1959 convention allocates to France (art. 9).
The Chiron Legal Corpus is the research library behind this brief, maintained by this office's offshore legal-research partner: an extensive cross-border collection of consolidated statutes, tax-authority doctrine, treaty instruments and case law, including the French primary sources in full text. Every statement of law in these pages is verified against it, re-checked against Légifrance and BOFiP at each edition, and stamped with its review date section by section.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
Method. Legal statements are verified against the Chiron Legal Corpus, the research library maintained by this office's offshore legal-research partner — an extensive cross-border and international collection of consolidated statutes, tax-authority doctrine, treaty instruments and case law, including French primary law held in full text and re-checked against the official sources at each edition. The review of 19 July 2026 covered Légifrance (CGI arts. 4 B, 150 UB, 150 VC, 167 bis, 197 A, 200 B, 244 bis A, 669, 750 ter, 751, 777, 779, 964–965, 968, 973–974, 990 D–E, 990 J, 1609 nonies G, 1649 AB — consolidated texts), the three treaty instruments in their official French presentations — the 1964 convention consolidated with its four avenants and the multilateral instrument, the 1959 succession convention, and the signed 2021 convention as published by the French administration with its not-in-force notice — together with Conseil d'État n° 436392 (24 February 2020) and the administration's commentary (BOI-INT-CVB-BEL-10 and -20). That commentary dates from 2012 to 2016 and does not yet address the 2021 text; this brief follows the treaty texts. The ratification status is taken from the French treaty list and the government's answers to Parliament of 4 February 2025 and 16 September 2025, checked against the parliamentary record through May 2026; Belgian domestic law is stated at orientation level from secondary sources and is never load-bearing for a legal claim. Market data: DVF (DGFiP), villa sales ≥ €3M, estate-deduplicated, register through 2025-12-31. Ownership aggregates: compiled from public land and company registers, anonymised, as at 19 July 2026. Items flagged "at engagement" — communal rates, social-levy affiliation, the Belgian return of exempted income, the deed-level gain base — are stated at mechanism level pending case-specific verification.
Qualification. This brief documents published law and public transaction data; it is research rather than personalised legal or tax advice, and individual circumstances — residence history, domicile, matrimonial regime, the chain of title — change outcomes. For a live transaction, this office coordinates the appropriate French counsel (avocat fiscaliste, notaire) and executes the property side.
Enquiries on this brief reach this office directly.
elena@elenaagueeva.com · WhatsApp +33 7 66 44 02 34 · Subject line: Confidential brief — France–Belgium
© 2026 Elena Agueeva · Riviera Intelligence · Confidential: for the addressee's professional use; not for onward distribution.
Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
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