France–Canada — The Riviera Private Wealth Brief

0Executive summary

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

1The France–Canada convention — 1975, and its 1995 pivot

The relationship rests on a single instrument of long standing. The convention of 2 May 1975, in force since 29 July 1976, has been amended by the avenants of 16 January 1987, 30 November 1995 and 2 February 2010, and carries, in its consolidated presentation, the multilateral instrument — in force for France since 1 January 2019 and for Canada since 1 December 2019 — including the principal-purpose test, under which a treaty advantage can be refused where obtaining it was a principal object of an arrangement. The text covers taxes on income and on fortune alike: the French wealth tax is listed by name in article 2 §3, and the convention extends to identical or analogous taxes instituted after signature (article 2 §5), the footing on which the IFI, successor to the ISF from 2018, is examined. The pivot of the relationship is the 1995 avenant. It added article 2 §4, by which the convention applies, on the French side, to gift and succession duty — though solely for the purposes of articles 4, 23, 25 and 26 — and it rewrote article 23 to order what those duties meet on the Canadian side at death, a mechanism developed in section I bis. The authentic texts are French and English, both equally authoritative; this brief quotes the French consolidation.

Residence does the sorting. A person within the tax of both states is assigned by the tie-breakers of article 4: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. French domestic residence under CGI article 4 B — foyer, principal place of stay, centre of professional and economic interests — runs underneath, and the treaty cascade settles any conflict the two systems produce.

The Canadian side keeps its own accents. The taxes the convention covers for Canada are those levied by the Government of Canada under the federal Income Tax Act (article 2 §3 a); provincial taxes, Québec's own income-tax system among them, sit outside the instrument, and the administration's commentary refers that ground to the separate fiscal understanding France signed with Québec on 1 September 1987 — a point Québec-bound families raise with their advisers rather than resolve from the treaty. More broadly, Canada taxes death and emigration as deemed dispositions of property rather than through inheritance duty, and knows the common-law trust as an everyday planning instrument outside Québec's civil law. This brief states Canadian law at orientation level only; its verified ground is the French side and the convention, and the Canadian reading belongs with the family's Canadian advisers.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1975 convention (CML consolidation) arts. 2, 4; avenants 1987/1995/2010; BOI-INT-CVB-CAN (2012–2015 vintage — the text prevails)

2The market seen from Canada

Seen from Canada, the Riviera's €3M+ villa market leads with Cannes and the Gulf of Saint-Tropez. Cannes and its hills — the Super Cannes quarter on the Vallauris side included — contributed 306 qualified sales for €2,066M across 2014–2025, at a €4.9M median and a €46.5M ceiling, with 37% of value in eight-figure transactions. The Saint-Tropez peninsula remains the largest €3M+ register on the coast, at 1006 sales for €7,049M, while Saint-Jean-Cap-Ferrat is its narrowest and most expensive: 178 sales for €2,375M at a €6.5M median and a €200.0M ceiling. The past 36 months alone account for €3,970M across the three.

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.

Ownership, in aggregate

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, and Canadian residence accounts for roughly 4% of those foreign-held positions — a measured presence, of the same order as the mid-sized European residences, and one the register records with clarity rather than depth. Notably, the Canadian-resident positions in the current study are held in direct personal ownership, without a company in the chain — a directness the death-tax architecture of section I bis, unusually, does little to discourage.

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

IBuying in France as a Canadian resident

The process and its costs

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 Canadian buyers typically retain their own advisers in addition. Because death, in this relationship, engages two different tax systems on the same day, the structure questions of section I bis deserve to be answered before the compromis is signed; the acquiring vehicle is difficult to change once the process is under way.

The cost of owning

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°), and here the treaty position is settled rather than absent: article 22 §1 of the convention assigns wealth constituted by French real estate to France, and article 22 §2 treats shares whose value derives principally from French real estate the same way. A Canadian-resident owner therefore bears the IFI with the treaty's confirmation rather than its shelter; Canada, levying no annual wealth tax, leaves the charge single. The convention names the ISF, and the IFI is examined on the analogous-tax footing of article 2 §5 — a reading the administration's own practice across the treaty network supports.

For the family weighing a full move to France, the convention improves on the domestic statute. French law taxes any new resident arriving after five years abroad on French assets only for five years (article 964-1°, al. 2); article 22 §7 of the convention grants Canadian nationals without French nationality the same five-year exclusion of non-French assets as a treaty right — one France cannot narrow unilaterally — and renews it where the person, having ceased to be a French resident for at least three years, later returns. The calendar of a move, and of any return, is therefore worth planning against both texts.

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; convention arts. 2 §5, 22 §§1, 2, 7; cost scales stated for orientation, itemised at engagement

I bisStructures, as questions

The structure question

Holding structures are presented here, in keeping with this line's doctrine, as questions for analysis rather than as recommendations. For a Canadian buyer the analysis carries one organising fact: the treaty's death machinery works by credit between two unlike taxes, and what the deed creates on the day of purchase decides which charges arise and which credits answer them.

Debt against the IFI — what the code anticipates

The financing conversation runs here 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.

What the acquisition decides for succession — two taxes, one credit lattice

No France–Canada succession convention exists, and the absence is structural rather than accidental: Canada taxes death not with inheritance duty but with income tax, the deceased being deemed to have disposed of property at market value on the day of death. French duty therefore applies on its own architecture. Under CGI article 750 ter, France taxes French-situs assets of a non-resident deceased — the villa first, and shares of companies whose French property dominates their value with it — and, where the deceased or an heir has been French-resident for six of the ten preceding years, the reach extends to worldwide assets. The scale is that of article 777, progressive to 45% in the direct line beyond €1.8M per share, after the €100,000 per-child allowance of article 779, with the surviving spouse exempt in succession. Domestic law then offers a credit with a precise boundary: article 784 A imputes foreign tax only where it is itself a gift or succession duty, and only on foreign-situs assets — a description the Canadian charge, being income tax on gains, does not meet. Left there, the two systems would simply stack.

The 1995 avenant is the reason they do not. Article 23 §1 c provides that, in computing the Canadian tax of a person who died a Canadian resident, the French duty borne on French-situs assets of the estate is deducted from the tax otherwise due for the year of death — the succession duty on the villa, in other words, is credited against the deemed-disposition charge on the final Canadian return. Article 23 §2 c answers in the other direction: where the deceased was a French resident, France taxes the worldwide estate and credits the Canadian tax paid on the gains Canada may tax at death (§2 c i); and even for a Canada-resident deceased, France credits the Canadian death-gains tax attributable to assets only Canada may tax — the portfolio above all — against any French duty reaching those same assets, within a double ceiling (§2 c ii). Each asset class thus carries one credit, in one direction, and the ordering rules prevent relief being taken twice. In practice the family bears, per asset, the higher of the two systems rather than their sum — an outcome few of France's treaty relationships achieve where no succession convention exists.

Before either state determines the tax, the civil law determines who inherits. Canadian succession law — the common-law provinces' testamentary freedom, and Québec's civil code, which likewise reserves no fixed share for children — answers the question differently from French forced heirship, and EU Regulation 650/2012 lets a Canadian national habitually resident in France elect the law of his or her nationality for the succession as a whole. The election is not the end of the analysis: since the law of 24 August 2021, where the deceased or a child is a national or habitual resident of an EU member state and the applicable foreign law allows no reserved-share mechanism for children, each child may take a compensatory levy on assets situated in France — the villa first among them — up to the French reserved share (Civil Code, article 913, al. 3). The will, the matrimonial regime carried into the purchase, and the choice of law are questions for counsel on both sides, best answered before the compromis.

The démembrement — and why lifetime gifts deserve particular care

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 French mechanics are settled. 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. The Canadian side, however, distinguishes this relationship from most: a gift is, in Canadian law, itself a disposition at market value, so the same act can bear French gift duty and Canadian capital-gains tax at once — and the treaty's credit lattice is written for death, not for gifts. Article 2 §4 extends the convention to gift duty only for the domicile, mutual-agreement and information articles; no provision allocates or credits the two charges between the living. The calendar and form of any lifetime transmission therefore belong with counsel on both sides before the deed, with the death-time architecture above as the measured alternative.

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, 784 A, 792-0 bis, 968, 973–974, 990 J, 1649 AB; convention arts. 2 §4, 23 §§1 c, 2 c; EU Reg. 650/2012; C. civ. art. 913

IISelling as a Canadian resident

France taxes first. Article 6 §3 of the convention makes gains from the alienation of immovable property taxable in the state where the property stands, and article 13 §1 confirms the assignment, reaching also shares, partnership interests and trust interests that drew more than half their value from French real estate at any time in the 365 days before the sale — the modern property-rich clause, carried into the text by the multilateral instrument. For a Canadian-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. 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.

Two features mark the Canadian seller's file as a third-country one. Canada sitting outside the European Union and the European Economic Area, the seller must in principle appoint an accredited fiscal representative in France, who signs the gain computation and answers for it; the administration grants an automatic dispensation where the price does not exceed €150,000 per seller or where the duration allowances have extinguished both the tax and the levies — thresholds a Riviera villa meets only through long ownership. And the social levies apply at their full rate of 17.2%: the carve-out that reduces EU-affiliated sellers to the 7.5% solidarity levy rests on the European coordination regulation, and the Conseil d'État has confirmed, on the sale of a third-country resident, that the levies apply in full and that the free movement of capital offers no escape. The bilateral social-security understanding between France and Canada does not alter that analysis.

Canada then answers by credit. The gain on the French villa remains within the Canadian base — Canada taxes its residents on worldwide income — and the French tax paid conformably to the convention is deducted from the Canadian tax on the same gain (article 23 §1 a), the sourcing rule of §1 d treating treaty-taxable French gains as French-source for the purpose. Selling shares of a property-rich company changes neither side of that arithmetic: the shares are French-situs under article 13 §1 b, and the credit machinery runs identically. In practice a Canadian seller therefore bears the higher of the two systems on the exit — a figure best computed, on both sides, before marketing begins rather than in the course of negotiation.

Leaving after the sale — a note on the exit tax

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. The relationship adds a familiar note: article 13 §5 of the convention expressly preserves each state's right to tax, under its own law, gains realised by its former residents — nationals, or ten-year residents who left within the preceding five years — the same design on which Canada's own departure charge rests; for most sellers the exit tax is a question of calendar and paperwork rather than of cost, and 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 · Convention arts. 6 §3, 13 §§1, 4, 5, 23 §1; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A, 1609 nonies G; representative doctrine of 22 Jan 2025; CE 5 Mar 2018 and 31 Mar 2021

IIIRenting — as tenant and as owner

Renting as a tenant

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; the five-year window of article 22 §7, described above, then gives the calendar of those first years a treaty value of its own. 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.

Renting the villa out

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, for Canadian-affiliated owners at the full rate, the European carve-out not extending to third-country affiliation. The convention assigns the primary right to France: article 6 makes income from immovable property, however exploited, taxable in the state where the property stands. Canada then keeps the income within its own base and credits the French tax under the ordinary machinery of article 23 §1 a; how the credit is returned on the Canadian side, and how Québec's own system treats it, belongs with the family's Canadian advisers.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A; convention arts. 6, 22 §7, 23 §1 a

4What changed

Edition 1 — baseline (July 2026). The instrument as it stands: the convention of 2 May 1975, amended by the avenants of 16 January 1987, 30 November 1995 and 2 February 2010, and modified by the multilateral instrument — in force for France since 1 January 2019 and for Canada since 1 December 2019, on the notifications lodged by France on 26 September 2018 and by Canada on 29 August 2019. The Canadian treaty registry lists the same consolidated instrument, and no later protocol is signed or announced on either side. Watch items for edition 2: annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; Canadian federal budget movements on the capital-gains inclusion rate, which sets the weight of the deemed disposition at death; and any refresh of the administration's 2012–2015-vintage commentary on the convention, which predates the multilateral instrument and the IFI alike. 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

5Questions, answered

Does a Canadian resident pay French wealth tax on a Riviera villa?

Yes, once French real-estate assets exceed €1.3M, whether held directly or through the property fraction of company shares (CGI art. 964). Article 22 §1 of the convention assigns wealth constituted by French real estate to France, and Canada levies no annual wealth tax, so the charge is confirmed by treaty yet never doubled.

Does moving to France expose a Canadian's worldwide assets immediately?

Not for the first five years. Under article 22 §7 of the convention, a Canadian national without French nationality who becomes a French resident keeps assets situated outside France out of the French wealth-tax base for the five years following the move, and the window renews after at least three years of non-residence. French real estate itself stands outside the shelter in every era.

Who taxes the gain when a Canadian resident sells a French villa?

Both states, in an ordered way. France taxes first as the situs state (convention, arts. 6 §3 and 13 §1), 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 — and Canada keeps the gain in its base while crediting the French tax (art. 23 §1 a). The effective burden is, in practice, the higher of the two systems rather than their sum.

Canada has no inheritance tax — what actually happens at death?

Two different taxes meet. Canada treats death as a disposition of the deceased's property at market value and taxes the gains on the final return; France levies succession duty on the villa as the situs state (CGI art. 750 ter). Since the 1995 avenant, article 23 orders the encounter: the French duty on French assets is deducted from the deceased's final Canadian tax (art. 23 §1 c), and France credits the Canadian death-gains tax where its own duty reaches Canadian assets (art. 23 §2 c).

Is there a France–Canada succession convention?

No separate instrument exists. The income convention itself extends, on the French side, to gift and succession duty — but only for the domicile, double-taxation, mutual-agreement and information articles (art. 2 §4). France therefore taxes on its domestic architecture, and the treaty's contribution is the death-credit machinery of article 23 rather than an allocation of taxing rights.

Are lifetime gifts coordinated the way estates are?

No — and the distinction deserves care. The credit lattice of article 23 is written for death; a lifetime gift of the villa, or of its bare ownership, bears French gift duty while Canadian law treats the gift as a disposition at market value, and no treaty provision allocates or credits the two charges. The calendar and form of any gift belong with counsel on both sides before the deed.

Is rental income from France taxed if the owner lives in Canada?

Yes, by France first: article 6 of the convention makes income from immovable property taxable in the situs state, and France applies the minimum-rate regime of CGI article 197 A, at no less than 20% and 30%, with social levies in addition. Canada keeps the income in its own base and credits the French tax under article 23 §1 a.

Does a French exit tax apply after selling and leaving?

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.

What is the Chiron Legal Corpus?

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

6Methodology, sources & qualifications

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, 784 A, 792-0 bis, 964–965, 968, 973–974, 990 J, 1609 nonies G, 1649 AB; Civil Code art. 913 — consolidated texts) and the convention of 2 May 1975 in its official French consolidation, carrying the avenants of 1987, 1995 and 2010 and the multilateral instrument — the authentic texts being French and English, both equally authoritative, with the English official presentation published on the Canadian side. The administration's commentary on the convention (BOI-INT-CVB-CAN) dates from 2012–2015 and predates the multilateral instrument and the IFI; this brief follows the treaty text. Third-country sale mechanics follow the administration's representative-accreditation doctrine of 22 January 2025, and the social-levy position follows the Conseil d'État's rulings of 5 March 2018 and 31 March 2021. Canadian domestic law — the deemed disposition at death, on gifts and on emigration, the absence of inheritance tax, Québec's separate system and the 1987 France–Québec fiscal understanding — is stated at orientation level from the treaty text and the French administration's references, 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, the deed-level gain base, the Canadian return of foreign tax credits, any Québec-side treatment — 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, nationality, 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.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

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