Riviera Intelligence — Elena Agueeva

France–China — The Riviera Private Wealth Brief

The implications of buying, selling and renting French Riviera property for residents of China — from the 2013 agreement, the tax code and the state's own transaction register.

Edition 1 · July 2026 · France ↔ China · Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

Written by Elena Agueeva — licensed French real-estate broker (CPI 06052023000000132), Cannes. First published 2026-07-20 · 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.

Version française de ce brief

Market data

0Executive summary

1 · At death, one state assesses — France — and nothing tempers its scale. France and China have concluded no succession or gift convention: the administration's own treaty list records the relationship as covering income tax alone. A Riviera villa passing to heirs in China therefore answers to French succession duty as the state where it stands — 45% in the direct line beyond €1.8M per share — while China, which levies no inheritance or gift tax, adds nothing and credits nothing. The assessment is single, yet it is whole: no treaty article limits the French charge, French law reads through family-held companies, and an heir who has been French-resident for six of the ten preceding years brings the worldwide estate within French duty. Among the relationships this series has examined, this is one of the few in which the entire death-tax question rests on the French side alone.
2 · One agreement frames the relationship; it stops at income, and at the mainland's edge. The agreement of 26 November 2013, signed at Beijing and in force since 28 December 2014, replaced the 1984 text and governs taxes on income alone; the multilateral instrument — in force for France since 1 January 2019 and for China since 1 September 2022 — added the principal-purpose test, with effect for this agreement from 2023. Wealth tax, succession duty and gift duty all sit outside its scope, so the French tax on real-estate wealth (IFI) reaches a China-resident owner's Riviera holding above €1.3M with no treaty article to allocate or temper it. Nor does the agreement extend to Hong Kong, Macau or Taiwan, each governed by arrangements of its own; this brief reads the mainland relationship only.
3 · On a sale, France taxes first — and its clause looks back three years. Gains on the villa belong to France as the situs state (article 13 §1), and gains on shares or comparable interests in property-rich companies, partnerships and trusts follow the same allocation where French real estate supplied more than half their value at any time in the thirty-six months before the sale (article 13 §4) — a look-back three times longer than the 365-day period the multilateral instrument writes into conventions that lack one. China then taxes by its own law and credits the French charge (article 23 §2 a). As a third-country seller, a China resident appoints an accredited fiscal representative for the French filing, subject to the automatic dispenses.
4 · The purchase is funded from outside the mainland — by operation of Chinese law. China's exchange administration allows an individual an annual facility of US$50,000 for current items and does not extend it to the purchase of residential property abroad, while its rules anticipate — and exclude — the pooling of family members' facilities toward a single acquisition. Acquisitions at this market's level therefore proceed from capital the family already holds offshore, documented before the compromis is signed; the mechanics are set out in section I, stated at orientation.
5 · The market Chinese buyers ask about is deep and fully documented. Across the Saint-Tropez peninsula, Cannes and its hills and Saint-Jean-Cap-Ferrat, 1,490 villa sales of €3M and above cleared €11.5 billion over the 12-year DVF window. Every figure in this brief traces to the state's own transaction register.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

1The France–China agreement — 2013, income only

The relationship rests on a single instrument. The agreement of 26 November 2013, signed at Beijing, replaced the Paris accord of 30 May 1984 and entered into force on 28 December 2014, its provisions applying from 1 January 2015; French and Chinese are its two equally authentic languages, and this brief quotes the French text in the administration's consolidated presentation. The multilateral instrument, signed by both states on 7 June 2017, entered into force for France on 1 January 2019 and for China on 1 September 2022, and its effects run for this agreement from 1 January 2023 for taxes withheld at source and from taxable periods beginning 1 March 2023 for the rest: it rewrote the preamble and inserted the principal-purpose test, under which a treaty advantage can be refused where obtaining it was a principal object of an arrangement (article 24, as supplemented). The agreement covers taxes on income — on the French side the income tax, the corporation tax and the contributions on the corporation tax are named in an open list, and the administration's commentary of November 2024 confirms that the CSG, the CRDS and the solidarity levy fall within its scope; on the Chinese side the individual income tax and the enterprise income tax. It does not cover taxes on wealth, and the administration's treaty list of 29 April 2026 records no succession or gift convention with China — an absence that organises much of what follows. Territorially, the agreement covers the territory in which Chinese tax legislation applies: the administration states that it extends neither to the special administrative regions of Hong Kong and Macau nor to Taiwan, each of which answers to a separate arrangement, and this brief reads the mainland relationship only.

Residence does the sorting. A person within the tax of both states is assigned by the tie-breakers of article 4 §2, on the OECD cascade: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. French domestic law reaches the same question through CGI article 4 B — the family's foyer, the principal place of stay, the centres of professional and economic interest — and the treaty settles the conflicts the two systems produce. Notably, the agreement's definition of a resident excludes persons taxed in a state only on income sourced there, a boundary worth keeping in view for families whose Chinese liability is not yet worldwide.

The Chinese side keeps its own accents. China taxes individuals domiciled there — a status that follows household registration, family and economic ties rather than day-counts — on their worldwide income, and since the 2019 reform of the individual income tax it applies the same worldwide principle to non-domiciled persons once they have resided 183 days a year for six consecutive years, a single absence of more than thirty days in any year restarting the count; by its own arithmetic, that rule could produce its first worldwide assessments for 2025. China levies no tax on inheritances or gifts and no annual tax on net wealth; what it does administer closely is the movement of private capital across its border, examined in section I. This brief states Chinese law at orientation level only; its verified ground is the French side and the 2013 agreement, and the Chinese reading belongs with the family's advisers in China.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 2013 agreement (CML consolidation) preamble, arts. 2–4, 24, 30; BOI-ANNX-000306 (29 April 2026); BOI-INT-CVB-CHN (20 November 2024)

2The market seen from China

Seen from China, the Riviera's €3M+ villa market opens on the Saint-Tropez peninsula, the largest register of its kind on the coast: 1,006 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 at a €4.9M median, while Saint-Jean-Cap-Ferrat is the narrowest and most expensive of the three: 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 markets.

MarketSales (12 yrs)Total €MMedian €M Ceiling €M36-mo sales36-mo €M≥€10M (36-mo)
Saint-Tropez & the Gulf10067,0494.985.53532,71868
Cannes & its hills3062,0664.946.59869716
Saint-Jean-Cap-Ferrat1782,3756.5200.05355519

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.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · DVF register, estate-deduplicated · ownership aggregates from public registers only

The place, documented

IBuying in France as a China 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 Chinese buyers typically retain their own advisers in addition. Because no treaty governs what happens to the villa at death or by gift, 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.

Worked example — the median Cannes villa (€4.9M, the 2014–2025 DVF median of Cannes and its hills):
ItemBasisAmountBorne by
Transfer duties & land-registration taxes ≈ 5.81 % of price (standard-rate département; existing property) €284,526Buyer
Notaire's émoluments & disbursements ≈ 1.1–1.4 % at this price point (regulated sliding scale) ≈ €61,250Buyer
Indicative all-in acquisition costs ≈ 7 % on an existing property€345,776 Buyer
Agency feePer 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.

Funding the purchase — the exchange-control setting

China administers the movement of private capital across its border, and the practical geometry of a Riviera purchase follows from it. An individual's annual foreign-exchange facility stands at the equivalent of US$50,000, a ceiling designed for travel, study and comparable current items; the purchase of residential property abroad is not among its permitted uses, and the administration's rules anticipate — and exclude — the pooling of relatives' facilities toward a single acquisition. Recent practice has moved toward fuller documentation rather than wider ceilings, with reporting and record-keeping requirements reinforced again in late 2025. In consequence, acquisitions at this market's level proceed in practice from capital the family already holds outside the mainland — accounts in international banking centres, existing offshore companies, the proceeds of earlier disposals abroad — and the French side of the transaction applies its own provenance checks through the notaire and the receiving bank, as it does for every buyer. The calendar consequence follows: the deposit of customarily 10% falls due at the compromis, so the funds that will carry the purchase should stand outside the mainland, documented, before the offer is made. The position under Chinese exchange rules is stated here at orientation and is confirmed with the family's advisers in China.

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 965, 2°). Here the treaty position is simply absent rather than settled: the 2013 agreement covers income alone, so no article allocates or tempers the charge — the same footing as the Denmark and Brazil relationships, and the opposite of the Germany one, whose 1959 text covers wealth expressly. China levies no net-wealth tax of its own, so the IFI is a French cost of carry rather than a double charge, yet it stands on domestic law alone and follows the property whatever the owner's treaty residence.

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 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965; cost scales stated for orientation, itemised at engagement · Chinese exchange administration stated at orientation

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 Chinese buyer the analysis carries one organising fact: with no succession or gift convention, and no Chinese tax on transmissions at all, whatever the deed creates will be read at death by French law alone — and French law reads it on its own terms, with no treaty to temper them.

QuestionWhat it decidesThe China-specific reading
Direct ownership?Simplicity; situs taxation for gains and for successionOn a sale, France taxes as the situs state and China credits (arts. 13 §1, 23 §2 a); at death, French duty attaches to the villa and no Chinese assessment answers it — the single, untempered charge of the block below
Chinese or other foreign company?Confidentiality, consolidation The annual 3% tax question and its disclosure regimes; property-fraction IFI in any event; a sale of the shares stays within France's reach for three years under the 36-month clause (art. 13 §4); at death, French law reads through companies held above one half by the family and taxes the villa as if held directly (CGI art. 750 ter, 2°)
French SCI?Governance, co-ownership, French financing The Chinese classification of the SCI is a counsel question; the French side taxes the property fraction regardless, a sale of the shares stays within France's charge under the 36-month clause, and the family look-through of 750 ter reaches the villa at death
Trust in the chain?Dynastic control Trusts are familiar instruments in the offshore planning of mainland families, and French law answers them with machinery of its own: trustee reporting under CGI article 1649 AB and the dedicated levy of article 990 J where French assets or French residents are touched; the principal-purpose test of article 24 asks its own question of any arrangement built around treaty access. Either route is examined with counsel on both sides before the compromis
Usufruct / bare-ownership split?Lifetime transmission at reduced valuesWorks identically on the French side; with no gift convention and no Chinese gift tax, the transmission is read by France alone, on the valuation mechanics below

Debt against the IFI — what the code anticipates

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). For a Chinese buyer the loan carries one further convenience worth naming: bank finance raised in France or in an international banking centre reduces the call on funds that would otherwise have to be assembled offshore. 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 — and for gifts

This is the section the absence of a treaty writes, and here it writes an unusual page: the assessment at death is single, and it is French. French duty attaches to the villa as French-situs property whatever the owner's domicile, for estates and for lifetime gifts alike, and reads through interposed companies: an immovable held through entities in which the deceased or donor, together with spouse, ascendants, descendants or siblings, holds more than half the interests is deemed held directly (CGI art. 750 ter, 2°). Where the deceased was French-domiciled, or the heir has been French-resident for six of the ten preceding years, France taxes the worldwide transmission instead (art. 750 ter, 1° and 3°). 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. China, for its part, taxes neither inheritances nor gifts, so no second assessment arises and no credit question with it; what the family loses is not relief — there is nothing to relieve — but any treaty limit on the French reach, and the residence clock of 750 ter 3° therefore deserves attention wherever children study or settle in France. The one instrument that does speak is European: under Regulation 650/2012, which France applies to all successions, a Chinese national habitually resident in France may elect Chinese law for the succession as a whole.

The election meets French forced heirship on less settled terms than in most relationships. Chinese succession law knows no general reserved share for children: it reserves a necessary portion only for an heir who lacks both the capacity to work and a source of income, stated here at orientation. The compensatory levy French law added in 2021 arises where the foreign law applicable to the succession permits no protective reserve mechanism for children (Code civil, art. 913, al. 3), alongside its condition that the deceased or a child be an EU national or resident, and whether the narrow Chinese protection satisfies that test has not been settled by the courts. The choice of law, the matrimonial regime carried into the purchase — the Chinese statutory community of property acquired during marriage among them — and the calendar of any gifts are questions for counsel on both sides, best answered before the compromis.

The démembrement — bare ownership gifted, use retained

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 Chinese family the setting is simpler than in most relationships and no lighter for it: the gift falls within no convention, France taxes it as the situs state on the French scale, and no Chinese charge arises on the donee's side. The forced-heirship consequences of a gift to children belong with the family's counsel, alongside the choice-of-law election noted above.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 669, 750 ter, 751, 777, 779, 784 A, 968, 973–974, 990 J, 1649 AB; Code civil art. 913; EU Reg. 650/2012; 2013 agreement arts. 13, 23 §2, 24

Selected rankings

IISelling as a China resident

France taxes first, as the state where the property stands: article 13 §1 assigns gains on French immovables to France, and paragraph 4 of the same article reaches gains on shares, interests or comparable rights in companies, partnerships, trusts and other entities that drew more than half their value, directly or through interposed entities, from French real estate at any time in the thirty-six months before the sale — the agreement's own test, which the multilateral instrument left in place while adding the partnership and trust breadth, and a look-back three times longer than the 365-day period that instrument writes into conventions that lack one. Substantial shareholdings outside the property-rich case follow their own rule: a 25% participation held at any time in the twelve months before the sale keeps the gain taxable in the company's state (article 13 §5). The property side of the agreement is written firmly for the situs state — even the sovereign funds the protocol names, the China Investment Corporation among them, take their treatment of French real-estate gains from French domestic law, the treaty providing no shelter there (protocol, point 5).

For a China-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 distinguish the third-country seller. First, the social levies apply at their full combined rate of 17.2%, the reduced solidarity rate being reserved to sellers within the European social-security coordination — an affiliation a China-resident seller does not hold. Notably, the administration's commentary confirms that the CSG, the CRDS and the solidarity levy are taxes the agreement covers, so these levies enter the treaty's credit machinery as French tax; how far the Chinese credit absorbs them is a question of Chinese law, examined at engagement. Second, representation: a seller domiciled outside the EU and the EEA appoints a representative accredited by the French administration, who answers for the filing and the payment (article 244 bis A, IV). The administration's own doctrine grants automatic dispenses — sales at €150,000 or less per seller, and sales fully exempt through the thirty-year holding clock — under its instruction of 22 January 2025, and the deed's notaire ordinarily organises the appointment where one is required.

Worked example — the duration clock, per €1,000,000 of gross gain on a villa sold at the Cannes median of €4.9M:
OwnershipAllowance (150 VC)Taxable gain Income tax at 19%Surcharge (1609 nonies G)
10 full years30%€700,000€133,000€42,000
15 full years60%€400,000€76,000€24,000
22 full years100%

Social levies apply in addition until the thirtieth year, at the 17.2% combined rate borne by third-country sellers. 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.

China then answers as the residence state. The agreement leaves the situs allocation non-exclusive: the gain enters Chinese taxation under China's own law, and the tax paid in France in accordance with the agreement is credited against the Chinese charge, within the limit of the Chinese tax on that income (article 23 §2 a). In current Chinese practice the worldwide principle reaches domiciled individuals as a matter of course and non-domiciled residents only from their seventh consecutive year, so the weight of the Chinese return varies with the family's own residence history; the mechanics of the credit, and the treatment of the proceeds under China's exchange administration should they return to the mainland, are stated at orientation and belong with the family's advisers in China. The choice between selling the asset and selling the shares of a property-rich company therefore alters the pool of buyers and the French filing mechanics more than the allocation itself, which article 13 keeps with France on both routes for three years of history; that choice is still best evaluated 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. 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 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 2013 agreement arts. 2, 13 §§1, 4–5, 23 §2, protocol pt 5; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 235 ter, 244 bis A (incl. IV), 1609 nonies G; BOI-RFPI-PVINR-30-20 (22 Jan 2025)

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, and the tie-breakers of article 4 §2 of the agreement then decide which state prevails. The Chinese side has its own accent here: a Chinese national's liability follows domicile — household registration, family and economic ties — rather than day-counts, so a season in France does not of itself end Chinese worldwide taxation while it may begin the French one; the tie-breakers then carry real weight. 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; the social levies apply in addition at the full 17.2% rate borne by owners outside the European coordination. The agreement assigns the income to France as the situs state, whatever the form of exploitation (article 6 §§1 and 3), and leaves the allocation non-exclusive: China taxes its resident on the same income under its own law and credits the French tax (article 23 §2 a), the mechanics of that credit — the CSG, CRDS and solidarity levy included, all taxes the agreement covers on the administration's reading — belonging with the family's advisers in China.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A, 235 ter; 2013 agreement arts. 4 §2, 6, 23 §2

4What changed

Edition 1 — baseline (July 2026). The instruments as they stand: the agreement of 26 November 2013, in force since 28 December 2014, as modified by the multilateral instrument — in force for France since 1 January 2019 and for China since 1 September 2022, its effects on this agreement running from 1 January 2023 for taxes withheld at source and from taxable periods beginning 1 March 2023 for the rest. No succession or gift convention exists, and none is recorded as under negotiation; an inheritance tax has been discussed in China at intervals without being enacted, and a first Chinese death duty — or a first France–China succession instrument — would rewrite section I bis entirely. The administration's commentary on the agreement (BOI-INT-CVB-CHN) was refreshed on 20 November 2024 and postdates both states' entry into the multilateral instrument, so text and commentary run together — the reverse of several relationships this series has examined, where the commentary predates the instrument. Further watch items for edition 2: annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; the administration of China's exchange rules, reinforced most recently in late 2025; the first assessments under the six-year rule's worldwide reach, which its own arithmetic could not produce before 2025; and any refresh of the 2024 commentary. The ownership aggregates of section 2 are refreshed with each edition.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

Questions, answered

5Questions, answered

Does a China 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). The 2013 agreement covers income alone, so no treaty article allocates or tempers the charge — the position already familiar from the Denmark and Brazil relationships. China levies no comparable net-wealth tax, so the cost is one-sided in practice, but it stands on French domestic law alone.

Which country taxes the succession on a French villa?

France, and France alone — but in full. No succession convention exists, and China levies no inheritance or gift tax of its own. France taxes the villa as French-situs property, reading through family-held companies (CGI art. 750 ter), at rates reaching 45% in the direct line beyond €1.8M per share; and where an heir has been French-resident for six of the ten preceding years, French duty extends to the worldwide transmission.

Does the France–China agreement extend to Hong Kong or Macau?

No. The agreement covers the territory in which Chinese tax legislation applies, and the administration states that it extends neither to the special administrative regions of Hong Kong and Macau nor to Taiwan. Hong Kong's relationship with France is governed by a separate agreement signed in 2010, with its own scope and terms; Taiwan's by a dedicated provision of French law. This brief reads the mainland relationship only.

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

France first, as the state where the property stands (art. 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. China then taxes the same gain under its own law and credits the French charge against its own (art. 23 §2 a). Property-rich company shares follow the same allocation where French real estate supplied more than half their value at any time in the 36 months before the sale (art. 13 §4).

Does the sale require a fiscal representative?

As a rule, yes. A seller domiciled outside the EU and the EEA appoints a representative accredited by the French administration, who answers for the filing and the payment (CGI art. 244 bis A, IV). Automatic dispenses cover sales at €150,000 or less per seller and sales fully exempt through the thirty-year holding clock; the deed's notaire ordinarily organises the appointment where one is required.

Can the villa be paid for from mainland China?

Not in the ordinary course. The individual foreign-exchange facility of US$50,000 a year is designed for current items, does not extend to the purchase of residential property abroad, and the rules exclude the pooling of relatives' facilities toward a single acquisition. Purchases at this level are funded in practice from capital already held outside the mainland, documented before the compromis; the position under Chinese exchange rules is stated at orientation and confirmed with the family's advisers in China.

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

Yes — France taxes it first as the situs state (agreement, art. 6), under the minimum-rate regime of CGI article 197 A at no less than 20% and 30%, with social levies at 17.2% in addition. China taxes the same income in the resident owner's hands and credits the French tax under article 23 §2 a) of the agreement.

Does French forced heirship bind a Chinese family?

The question is less settled than for most nationalities. Under EU Regulation 650/2012, a Chinese national habitually resident in France may elect Chinese law for the succession as a whole; Chinese law, however, reserves a necessary portion only for an heir unable to work and without a source of income, and whether that narrow protection counts as a protective reserve mechanism within Code civil article 913, al. 3 — whose compensatory levy also requires the deceased or a child to be an EU national or resident — has not been settled by the courts. The point is assessed on the succession's actual facts.

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 20 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 20 July 2026 covered Légifrance (CGI arts. 4 B, 150 UB, 150 VC, 167 bis, 197 A, 200 B, 235 ter, 244 bis A, 669, 750 ter, 751, 777, 779, 784 A, 964–965, 968, 973–974, 990 J, 1609 nonies G, 1649 AB; Code civil art. 913 — consolidated texts), the agreement of 26 November 2013 in its official French consolidation — the multilateral instrument incorporated, as published by the administration, the French text being one of the agreement's two equally authentic languages — the administration's commentary on the agreement of 20 November 2024 (BOI-INT-CVB-CHN), and the administration's treaty list of 29 April 2026, which records the France–China relationship as covering income tax alone. The non-resident representation and dispense mechanics follow the administration's instruction of 22 January 2025. Chinese domestic law — the individual income tax and its six-year residence rule, the absence of inheritance, gift and net-wealth taxation, and the foreign-exchange administration — 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. Items flagged "at engagement" — communal rates, the Chinese return of French-taxed 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, 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.

Enquiries on this brief reach this office directly.

elena@elenaagueeva.com · WhatsApp +33 7 66 44 02 34 · Subject line: Confidential brief — France–China

© 2026 Elena Agueeva · Riviera Intelligence · Confidential: for the addressee's professional use; not for onward distribution.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

Further intelligence

The Riviera villa market — the coast-wide €3M+ index

Riviera property tax & relocation — the incoming buyer's primer

France–Hongkong — the convention pair

Source: Légifrance & BOFiP through the Chiron Legal Corpus · DVF (DGFiP), estate-deduplicated · public land and company registers, aggregates only