France–China — Tax Treaty

1One agreement, signed at Beijing in 2013 — and everything that stands outside it

France and China have a single agreement, and a recent one. The agreement of 26 November 2013, signed at Beijing, entered into force on 28 December 2014 and applies from 1 January 2015, replacing the Paris accord of 30 May 1984; its French and Chinese texts are equally authentic, and this brief quotes the French text in the administration's consolidated presentation. Both states signed the multilateral instrument (the anti-abuse rule agreed internationally in 2017) — France bound from 1 January 2019, China from 1 September 2022 — and for this agreement its effects run from 1 January 2023 for taxes withheld at source and from taxable periods beginning 1 March 2023 otherwise: a rewritten preamble, and a principal-purpose test under which a treaty advantage may be refused where obtaining it was a principal object of an arrangement (article 24, as supplemented). The covered taxes are income taxes: on the French side an open list naming the income tax, the corporation tax and its contributions, which the administration's commentary of November 2024 reads as extending to the CSG, the CRDS and the solidarity levy; on the Chinese side the individual and enterprise income taxes. Nothing in the agreement addresses wealth, and the administration's treaty list of 29 April 2026 records no succession or gift convention with China — the absence around which § 2 and § 6 of this brief are built.

The territorial line matters as much as the material one. The agreement covers the territory in which Chinese tax law applies, and the administration states that it reaches neither the special administrative regions of Hong Kong and Macau nor Taiwan, each answering to a separate arrangement: a Hong Kong purchase runs on the France–Hong Kong agreement of 21 October 2010, outside this brief. This brief reads the mainland relationship only.

Who counts as a resident of China under the 2013 text — and the clause no court has read

Where both states claim a person, article 4 §2 assigns them on the OECD cascade — permanent home, centre of vital interests, habitual abode, nationality, mutual agreement — while French domestic law asks its own prior question through CGI article 4 B, on the family's foyer, the principal place of stay and the centres of professional and economic interest. One boundary of the modern text deserves particular attention: a person taxed in a state only on income sourced there is expressly outside the agreement's definition of a resident (article 4 §1, second sentence). The residence article has been tested at the highest level exactly once in this relationship, and on the old text. A taxpayer living in Shanghai with his wife and children, and working there, received French dividends in 2013 and 2014; France withheld its 30% domestic rate, and he claimed the 10% ceiling the then-applicable 1984 accord reserved for residents of China. The administration answered that China assessed him only on his Chinese salary, so that he was no treaty resident at all. The Conseil d'État annulled that reading: under the 1984 drafting, residence turned on whether Chinese liability attached through a personal link — domicile, residence or an analogous criterion — not on how much of the person's income China in fact assessed (CE, 9 June 2020, n° 434972). The sequel matters as much as the decision: the 2013 agreement contains the sentence the old text lacked, so the question the Shanghai taxpayer carried returns, in a new form, for the non-domiciled family inside China's six-year window, whose Chinese assessment is confined to Chinese-source income. No court has yet read the modern clause; the point belongs to case-specific review when our agency takes the file.

What Chinese law does on its own side

China assesses individuals domiciled there — a status resting on household registration and on family and economic ties rather than on day-counts — on worldwide income, and since the 2019 reform of the individual income tax the same worldwide principle reaches non-domiciled persons after 183-day residence in each of six consecutive years, one absence of more than thirty days in a year restarting the count; on its own arithmetic the rule could produce its first worldwide assessments for 2025. China taxes neither inheritances nor gifts and keeps no annual tax on net wealth; what it does administer closely is the private movement of capital across its border, taken up in § 2. Chinese law is stated throughout at orientation level — the verified ground of this brief is the French side and the 2013 text — and the Chinese reading belongs with the family's advisers in China.

Sources considered: CGI article 4 B; n° 434972; article 24; article 4 §2; article 4 §1. Scope note: Treaty text prevails over earlier commentary; dates are re-verified each edition. The 2013 convention never reaches Hong Kong or Macao.

Reviewed as at 10 August 2026 · 2013 agreement (CML consolidation) preamble, arts. 1–4, 24; BOI-ANNX-000306 (29 April 2026); BOI-INT-CVB-CHN ¶¶40, 70, 110 (20 November 2024); CE n° 434972 — decision text read

2What you pay to buy a property in France, and what it costs you every year

The purchase runs on the sequence French practice fixes: an offer; the pre-sales contract (compromis de vente), with its ten-day cooling-off period and a deposit of customarily 10%; conditions precedent; then the authentic deed before the notaire — the public officer who draws up and registers the deed — who collects the duties and registers the title. The notaire holds a public office and is not the buyer's advocate, so a family steering the file from Shanghai or Beijing will usually add counsel of its own and grant a power of attorney for the deed. On the collection's common yardstick — the €4.9M median villa of Cannes and its hills in the DVF register — the buyer pays transfer duties and land-registration taxes of about 5.81% (€284,526), notaire's émoluments and disbursements of roughly €61,250 on the regulated sliding scale, together an indicative 7% all-in (≈ €345,776) on an existing property. A new-build VAT regime, furniture carve-outs or mortgage security will alter the arithmetic; the notaire itemises the actual deed.

Funding the purchase — the exchange-control setting

China administers the private movement of capital across its border, and the practical sequence of a Riviera acquisition follows from that administration rather than from French law. Each individual holds an annual foreign-exchange facility equivalent to US$50,000, designed for travel, study and comparable current items; the purchase of residential property abroad is not among its permitted uses, and the rules anticipate — and exclude — several relatives directing their facilities at a single acquisition. Recent adjustments have tightened documentation rather than widened ceilings, reporting and record-keeping duties having been reinforced again in late 2025. Purchases at this market's level therefore proceed, in the ordinary course, from capital the family already keeps outside the mainland: accounts in international banking centres, existing offshore companies, the proceeds of earlier disposals abroad. The French side asks its own questions in parallel — provenance checks by the notaire and the receiving bank, applied to every buyer alike — and the calendar draws the practical conclusion: the deposit falls due at the pre-sales contract, so the funds carrying the purchase should stand offshore, documented, before the offer is made. The position under Chinese exchange rules is stated at orientation and is confirmed with the family's advisers in China.

The wealth tax arrives without a Chinese counterpart

CGI article 964 taxes real-estate wealth above €1,300,000; for persons not domiciled in France the base is property located in France together with the fraction of any company's shares that stands for French property (article 965, 2°). The 2013 agreement has nothing to say here — it covers income alone — so the IFI applies on domestic terms: neither doubled, China keeping no net-wealth tax that could duplicate it, nor treaty-moderated, the footing this collection has already recorded for the Denmark and Brazil relationships and the opposite of the German one, whose 1959 text covers wealth expressly. An adviser used to a system without an annual wealth charge should read the IFI as the property's principal recurring cost above the threshold, following the property whatever the owner's treaty residence. The value declared each year is the owner's own detailed estimate of real market value (CGI article 973 I). The local charges then follow the deed: the annual local property tax (taxe foncière) runs at communal rates; communes in designated high-demand areas (zone tendue) — the marquee Riviera communes among them — may vote a surcharge (surtaxe) on the taxe d'habitation for furnished second homes; and every owner files the annual occupancy declaration. These rates being communal and year-specific, the brief's edition cycle re-verifies them rather than freezing them.

Our agency prepares a free valuation for owners at valuation.elenaagueeva.com. An agent contacts you within 48 hours to arrange a visit.

It rests on the same official records a French property valuer (expert immobilier) works from: the government's register of recorded sale prices, the cadastre, and the planning permits granted on the parcel. The agent then visits to appraise the view, the garden, and the quality of the construction and the finishes. The valuation report (avis de valeur) is produced within 48 hours of the visit.

The same figure carries your French filings. Wealth tax, the 3% company tax and gift duty are all declared at the property's market value. The law takes that value from your own detailed estimate (articles 761 and 973 of the tax code), and asks no particular valuer to produce it. A court-appointed expert (expert judiciaire) belongs to litigation, not to a declaration. If the administration challenges your figure, a dated, written valuation resting on comparable sales is what supports it.

The first valuation of a property is free for its owner or seller. A repeat valuation of the same property, or one commissioned by a family office, a bank or another adviser for a client, is a billable engagement — ask us for terms.

Sources considered: 2013 agreement art. 2; CGI arts. 964, 965 2°, 973 I; cost scales stated for orientation, itemised when our agency takes the file. Scope note: the Chinese exchange administration is stated at orientation; currency controls decide the funding route before any French rate does.

Reviewed as at 10 August 2026 · CGI arts. 964–965, 973 I; 2013 agreement art. 2 — Chinese exchange administration at orientation

3Five ways to own a French property, and what follows from each

Holding structures appear here, per this collection's doctrine, as questions for analysis rather than recommendations. For a Chinese buyer one fact organises the whole table: no convention governs transmissions, China taxes none of them, and whatever the deed creates will be read at death by French law alone, on French terms, with nothing above them.

Direct ownership

Simplicity, and France taxes it at every stage. On a sale France taxes as the state where the property stands and China credits the French charge (articles 13 §1 and 23 §2 a); at death French duty attaches to the property and no Chinese assessment answers it — the single, whole charge that § 6 develops.

A Chinese or other foreign company

Confidentiality and consolidation, at three French prices. The annual 3% tax on entities holding French property (CGI articles 990 D and 990 E) asks its disclosure question every year; the property fraction of the shares bears the IFI regardless; and a sale of the shares stays French for three years of history under the 36-month clause of article 13 §4. At death, French law reads through companies the family holds above one half and taxes the property as if held directly (CGI article 750 ter, 2°).

A French SCI

An SCI (a French property-holding company) offers governance, co-ownership between family members and access to French financing. The Chinese classification of the SCI belongs to counsel in China; on the French side the property fraction bears the IFI, share sales remain within the 36-month clause, and at death article 750 ter taxes the property as if the family held it directly.

A trust in the chain

A familiar instrument of mainland families' offshore planning, met in France by machinery of its own: trustee reporting under CGI article 1649 AB, the dedicated levy of article 990 J where declaration fails, transmission rates that reach 60% where beneficiaries' shares are undetermined (article 792-0 bis), and the principal-purpose test of article 24 asking its question of any arrangement built around treaty access. Examined with counsel on both sides before the pre-sales contract.

Giving your children the ownership now, and keeping the use for life (démembrement)

The structure most often set beside the loan divides ownership itself: the buyer keeps the usufruct — the use of the property and its income for life — and gives the bare ownership to the next generation. The code prices the split by age: on the scale of CGI article 669, bare ownership stands at 60% of full value where the usufructuary is between 61 and 70, and at 70% between 71 and 80. Duty falls on that fraction alone, at today's value, and the reunification of full ownership at the usufructuary's death is not taxed again where article 751's conditions are kept — a notarised gift, more than three months before death, valued on the article 669 scale. The wealth tax does not move: article 968 keeps the full value in the usufructuary's IFI base. With no gift convention and no Chinese gift tax, France alone reads the transmission, as the state where the property stands.

Borrowing against the French property cuts French wealth tax — within the code's three limits

Bank finance recurs in these files for one universal reason and one particular to this relationship. Universally, acquisition debt owed to a bank is deductible from the wealth-tax base (CGI article 974), and financial assets stand outside the IFI altogether, so a loan keeps liquidity invested while the debt shrinks the base. Particularly, credit raised in France or in an international banking centre reduces the volume of capital that must be assembled and documented offshore in the first place. The code sets three limits. A loan repaying capital at term is treated as amortising nonetheless, the deduction declining pro rata over its life and by one twentieth a year where no term is fixed. Above €5M of taxable property, debt beyond 60% of the property's value counts only as to half, unless the borrower shows a mainly non-tax purpose. And only genuine debt counts — drawn, serviced, priced at market; routed through an SCI's shareholder account it ceases to weigh in the valuation of the shares (article 973). The relief is strongest in the early years and recedes on the statute's own calendar — one more reason to settle the financing before the pre-sales contract rather than after it.

Sources considered: CGI arts. 669, 750 ter 2°, 751, 792-0 bis, 968, 973–974, 990 D–990 E, 990 J, 1649 AB; 2013 agreement arts. 13 §4, 23 §2 a, 24. Scope note: structures are questions, not recommendations, settled with counsel in France and in China; Chinese outbound-investment rules govern the holding as much as tax does.

Reviewed as at 10 August 2026 · CGI arts. 669, 750 ter, 751, 792-0 bis, 968, 973–974, 990 D–J, 1649 AB; 2013 agreement arts. 13 §4, 24

4What you pay when you sell

France taxes first, as the state where the property stands. Article 13 §1 assigns gains on French immovables to France, and paragraph 4 gives France the same right over gains on shares, interests or comparable rights in companies, partnerships, trusts and other entities that drew more than half their value, directly or through interposition, from French real estate at any time in the thirty-six months before the sale. That look-back is the agreement's own: the multilateral instrument added the partnership and trust breadth but left the three-year period standing, where conventions without such a clause receive the instrument's 365-day standard. Substantial shareholdings outside the property-rich case follow article 13 §5 — a 25% participation held at any time in the twelve months before the sale keeps the gain taxable in the company's state. The property side of this text is written firmly for the country the property stands in: even the sovereign funds the protocol names, the China Investment Corporation among them, take the treatment of their French real-estate gains from French domestic law, with no treaty shelter (protocol, point 5).

For the China-resident seller the French machinery is CGI article 244 bis A. The taxable gain shrinks by 6% for each year of ownership beyond the fifth and 4% for the twenty-second (article 150 VC); the income-tax component runs at 19% (article 200 B) and is extinct after 22 years, the social levies after 30; and taxable gains above €50,000 bear the progressive surcharge of article 1609 nonies G — 6% at the levels this market transacts. Per €1,000,000 of gross gain on a property sold at the Cannes median of €4.9M: after 10 full years the allowance is 30%, leaving €700,000 taxable, €133,000 of income tax and a €42,000 surcharge; after 15 years, 60%, €400,000, €76,000 and €24,000; after 22 years the income-tax component is extinct. Two features mark the third-country file. The social levies apply at the full combined 17.2%, the reduced solidarity rate belonging only to sellers within the European social-security coordination — an affiliation a China resident does not hold — though the administration counts the CSG, CRDS and solidarity levy among the taxes the agreement covers, so they enter the credit machinery as French tax. And 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 automatic exemptions — sales at €150,000 or less per seller, and sales fully exempt through the thirty-year clock — follow the administration's instruction of 22 January 2025, with the deed's notaire ordinarily arranging the appointment.

China then answers as the residence state, on its own law. France taxing the gain does not stop China taxing it: the gain enters Chinese taxation where the family's residence history brings it there — domiciled individuals as a matter of course, non-domiciled residents from the seventh consecutive year — and the tax paid in France in accordance with the agreement is set against the Chinese charge, within the limit of the Chinese tax on that income (article 23 §2 a). The mechanics of the Chinese credit, like the treatment of proceeds under the exchange administration should they return to the mainland, are stated at orientation and belong with the family's advisers in China. As for the route — selling the property or selling the shares of a property-rich company — article 13 keeps both within France's charge on three years of history, so the choice moves the pool of buyers and the filing mechanics more than it changes which country taxes the gain.

The 1984 credit for tax that was never paid, litigated for a decade after the 2013 agreement abolished it

Every reported Conseil d'État decision on a France–China text turns on the 1984 accord — chiefly its development-era tax-sparing clause, which credited French residents with Chinese tax on interest fixed forfaitarily at 10% of the gross, whatever China had actually collected. French banks litigated that arithmetic long after the accord was gone, and the court settled it in both directions: the credit is computed on a gross reconstituted by adding back the Chinese tax treated as paid (CE, 20 November 2017, n° 396595, Sté Natixis), and the same clause binds the claimant symmetrically — the reconstituted gross must enter the French taxable base before the credit is taken upon it (CE, 31 May 2022, n° 461519, HSBC Bank PLC Paris Branch). A third decision closed the machinery's boundary in time: treaty credits, whether for tax paid or tax merely treated as paid, are lost with a deficit year, none of the fifteen conventions before the court — the 1984 China accord among them — providing any carry-forward (CE, 8 March 2023, n° 456349). The 2013 agreement ended the era it fed on: the elimination article now credits only the Chinese tax actually and definitively borne (article 23 §1 b ii), and the administration records in terms that the forfaitary credits of 1984 are suppressed (BOI-INT-CVB-CHN ¶320). Two readings remain for the seller: credit clauses perform what their text provides and nothing beyond it — a discipline worth assuming of the Chinese credit of article 23 §2 a as well — and no reported decision of the court yet construes the 2013 text: across four decades and two successive instruments, the property articles have produced no dispute at that level.

Leaving after the sale — what the exit tax does and does not reach

France's exit tax (CGI article 167 bis) concerns securities, not property: it reaches persons who were French-domiciled for at least six of the ten years before leaving, and taxes the unrealised gains on securities holdings above €800,000 in value, or stakes of 50% or more of a company's profits, as they stand on the day of departure. A property already sold has settled its own tax under the regimes above, and the sale proceeds 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. A family that leaves before six years of French domicile stands outside the latent-gains charge altogether. Where the machinery does apply, payment is generally deferred, and the assessment lapses where the securities are still held two years after departure — five where the portfolio exceeded €2.57M — or upon a return to France.

Sources considered: 2013 agreement arts. 13 §§1, 4–5, 23 §§1–2, protocol pt 5; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A (incl. IV), 1609 nonies G; BOI-RFPI-PVINR-30-20 (22 January 2025); CE n° 396595, n° 461519, n° 456349 — decision texts read. Scope note: the tax-sparing decisions arise on banking facts under the abrogated accord and are retold for what they establish about credit machinery generally.

Reviewed as at 10 August 2026 · 2013 agreement arts. 13, 23, protocol pt 5; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A, 1609 nonies G; CE n° 396595, n° 461519, n° 456349

5Renting before you buy, and renting your property out

A rental year before buying remains the classic first step, and it deserves one plain caution: French tax domicile under CGI article 4 B rests on the foyer, the principal place of stay and the centres of professional and economic interest, none of which yields to the label on a lease. A property that becomes the family's effective home can found French residence, with worldwide consequences, before any purchase; the cascade of article 4 §2 then decides which state prevails. The Chinese side gives the trial year its particular shape: 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 close the Chinese worldwide assessment even as it may open the French one; and where the family is non-domiciled and inside the six-year window, the residence question carries the further wrinkle the case law of § 1 describes. The choice between furnished seasonal rentals and the one-to-three-year civil lease sets the exit flexibility, and is best matched to what the trial is actually for.

Renting the property out reverses the flow of the same rules. French-source rents of a non-resident owner — the furnished rentals usual at this price point included — are assessed under the minimum-rate regime of CGI article 197 A, at no less than 20% up to the second-bracket ceiling and 30% beyond, unless a lower worldwide effective rate is demonstrated; the social levies add their full 17.2%, on the third-country footing of § 4. The agreement gives the income to France as the state where the property stands, whatever the form of exploitation (article 6 §§1 and 3) — and France taxing it does not stop China: China assesses its resident on the same income under its own law and credits the French tax (article 23 §2 a), the reach 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.

Sources considered: CGI arts. 4 B, 197 A; 2013 agreement arts. 4 §2, 6 §§1 and 3, 23 §2 a. Scope note: treatment turns on the form of exploitation and on affiliation, both questions of fact.

Reviewed as at 10 August 2026 · CGI arts. 4 B, 197 A; 2013 agreement arts. 4 §2, 6, 23 §2

6What happens to the property when you die, or give it away — and why French law alone decides

This is the section the missing convention writes, and it writes an unusual page: one assessment at death, French, and whole. French duty attaches to the property itself because it stands in France, whatever the owner's domicile, for estates and for lifetime gifts alike, and it reads through interposed entities — an immovable held through companies in which the deceased or donor, with spouse, ascendants, descendants or siblings, holds more than half the interests is taxed as if it were held directly (CGI article 750 ter, 2°). Where the deceased was French-domiciled, or where an heir has been French-resident for six of the ten preceding years, France taxes the worldwide transmission instead (750 ter, 1° and 3°). The scale is article 777's, progressive to 45% in the direct line beyond €1.8M per share after the €100,000 per-child allowance of article 779, the surviving spouse exempt in succession. China assesses nothing on its side, so no credit question ever arises; what the family goes without is any treaty ceiling on the French reach — and the residence condition of 750 ter 3° accordingly deserves attention wherever children study or settle in France. The values declared for the duty are the owner's own detailed estimate of market value (CGI articles 761 and 1897).

A Chinese-law election is open — and the French levy on it is unsettled

One European instrument does speak: under Regulation 650/2012, which France applies to every succession, a Chinese national habitually resident in France may elect Chinese law for the succession as a whole. That election meets French forced heirship on ground less settled than in most relationships. Chinese succession law reserves no general share for children; it protects only an heir who lacks both the capacity to work and a source of income, stated here at orientation. The compensatory levy France added in 2021 operates where the law applicable to the succession permits no protective reserve mechanism for children (Code civil, article 913, al. 3), and only where the deceased or a child is an EU national or habitual resident; whether China's narrow necessary portion satisfies the statutory test has not been decided by the courts, and both conditions are weighed on the succession's actual facts. The choice of law, the matrimonial regime carried into the purchase — the Chinese statutory community of acquisitions among them — and the calendar of any gifts belong with counsel on both sides, before the pre-sales contract.

Sources considered: CGI arts. 750 ter, 761, 777, 779, 1897; Code civil arts. 912–913; EU Reg. 650/2012. Scope note: Chinese succession law is stated at orientation; no court has ruled on whether it satisfies the article 913 al. 3 test.

Reviewed as at 10 August 2026 · CGI arts. 750 ter, 761, 777, 779, 1897; Code civil art. 913 al. 3; EU Reg. 650/2012

7The eight questions Chinese owners ask most

Does a China resident pay French wealth tax on a Riviera property?

Yes, once French real-estate assets exceed €1.3M, held directly or through the property fraction of company shares (CGI article 964). The 2013 agreement covers income only, so no treaty article limits or softens the charge. China keeps no net-wealth tax of its own: the cost is one-sided in practice, and it rests on French domestic law alone.

Which country taxes the succession on a French property?

France, and only France — but without a ceiling. No succession convention exists and China levies no inheritance or gift tax. French duty attaches to the property because it stands in France, reads through family-held companies (CGI article 750 ter), and runs to 45% in the direct line beyond €1.8M per share; where an heir has been French-resident for six of the ten preceding years, it 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 reaches neither the special administrative regions of Hong Kong and Macau nor Taiwan. France's relationship with Hong Kong runs on a separate 2010 agreement with its own scope and terms. This brief reads the mainland relationship only.

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

France first, as the state where the property stands (article 13 §1), under CGI article 244 bis A with the duration allowances — the income-tax component extinct after 22 years, the social levies after 30. China then assesses the gain under its own law and credits the French charge (article 23 §2 a). Shares of property-rich entities follow the same rule wherever French real estate supplied more than half their value at any time in the 36 months before the sale (article 13 §4).

Has the France–China tax treaty ever been litigated in France?

Extensively — but only the old one. Every reported Conseil d'État decision on a France–China text concerns the 1984 accord, chiefly its flat 10% credit for Chinese tax on interest whether or not China collected it, a clause banks litigated into the 2020s (n° 396595 of 2017, n° 461519 of 2022, n° 456349 of 2023 among them). The 2013 agreement abolished that credit — only Chinese tax actually and definitively borne now counts — and has itself produced no reported decision at that level.

Can the purchase be paid for from mainland China?

Not in the ordinary course. The individual foreign-exchange facility of US$50,000 a year serves current items, does not extend to residential property abroad, and the rules exclude relatives pooling their facilities toward a single acquisition. Purchases at this level are funded in practice from capital already held offshore, documented before the pre-sales contract; 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 state where the property stands (agreement, article 6), under the minimum-rate regime of CGI article 197 A at no less than 20% and 30% beyond the second-bracket ceiling, with social levies at 17.2% in addition. China assesses 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?

Less settled than for most nationalities. Under EU Regulation 650/2012 a Chinese national habitually resident in France may elect Chinese law for the whole succession; 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 is 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 decided by the courts. The point is weighed on the succession's actual facts.

Sources considered: these answers condense the sections above and inherit their scope notes.

Reviewed as at 10 August 2026

8The court decisions, the sources and the sales figures

The market first, because every figure above traces to it. The coast opens, seen from China, on the Saint-Tropez peninsula — the largest €3M+ villa register of the arc, 1,006 qualified sales for €7,049M across 2014–2025 at a €4.9M median. Cannes and its hills remain the most international register of the three, 306 sales for €2,066M at the same €4.9M median, and Saint-Jean-Cap-Ferrat the narrowest and most expensive address, 178 sales at a €6.5M median. Together the three registers cleared €11.5 billion over twelve years, each line traceable in the state's own transaction data — DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales of €3M and above, 2014–2025, duplicate estate records removed. Across 20 Riviera communes, 34% of the ownership positions studied are held from outside France, and mainland China accounts for 2% of those foreign-held positions — aggregates only, drawn from public sources under their re-use conditions, no individual holding identified.

The legal method. Legal statements are verified against the Chiron Legal Corpus — the research library maintained by our agency's offshore legal-research partner — re-checked against the official sources at each edition. The review of 10 August 2026 covered Légifrance (CGI articles 4 B, 150 UB, 150 VC, 167 bis, 197 A, 200 B, 244 bis A, 669, 750 ter, 751, 761, 777, 779, 968, 973–974, 990 D–990 E, 990 J, 1609 nonies G, 1649 AB, 1897; Code civil article 913 — consolidated texts), the agreement of 26 November 2013 in its official French consolidation with the multilateral instrument incorporated, the administration's commentary 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 jurisprudence was read in the decision texts: on the 1984 accord's residence article, CE n° 434972 of 9 June 2020; on its credit for tax treated as paid, CE n° 396595 of 20 November 2017, n° 461519 of 31 May 2022 and, on the absence of credit carry-forward, n° 456349 of 8 March 2023. No reported decision construes the 2013 text.

The agreement's French and Chinese texts are equally authentic (testimonium read). The corpus holds the French official consolidation at statutory force; the Chinese authentic text is not yet held — an open item our agency records rather than leaves implicit. Chinese domestic law — the individual income tax and its six-year rule, the absence of inheritance, gift and net-wealth taxation, the necessary portion of succession law, and the foreign-exchange administration — is stated at orientation level from secondary sources and is never load-bearing for a legal claim.

What our agency is watching for the next edition: annual budget law (Loi de finances) movements on the IFI and transfer duties; communal surcharge 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; any first decision on the 2013 text; and any refresh of the November 2024 commentary. An inheritance tax has been discussed in China at intervals without being enacted; a first Chinese death duty, or a first France–China succession instrument, would rewrite § 6 entirely.

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, our agency coordinates the appropriate French counsel (avocat fiscaliste, notaire) and executes the property side.

Reviewed as at 10 August 2026 · decision texts read; DVF register, duplicate estate records removed

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

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