France–Hong Kong — Tax Treaty

1The 2010 Paris agreement, and who counts as a Hong Kong resident under it

The agreement France and Hong Kong signed at Paris on 21 October 2010 is the treaty that governs. The France–China convention of 26 November 2013 does not reach Hong Kong or Macao at all: the French tax authority says so explicitly, and confirms that only the 2010 agreement applies to Hong Kong. The two treaties also differ in what they cover — the China convention stops at income tax, while the Hong Kong agreement covers income tax and wealth tax.

France approved the agreement by statute on 13 October 2011 and published it by decree on 5 December 2011. It entered into force on 1 December 2011, and applies in France from 1 January 2012 and in Hong Kong from the tax year beginning 1 April 2012. The administration's treaty list of 29 April 2026 records the same scope, and records that France and Hong Kong have no inheritance or gift treaty — an absence that decides section 6.

Who counts as a Hong Kong resident under the agreement

Hong Kong taxes only income arising in Hong Kong. That creates a problem the treaty had to solve: article 4 §1 excludes from the word "resident" anyone taxed in a state only on income sourced there. Read alone, that sentence would push most Hong Kong families out of their own treaty. The negotiators closed that gap twice, in express words — in paragraphs 1 and 5 of the protocol.

Paragraphs 1 and 5 of the protocol both state, in the same words, that taxing only local income does not stop someone being a resident. What paragraph 1 does remove is different, and it matters more than anything else here. The treaty was signed in two official languages, English and French, and on this point they disagree. The English text says you lose the benefit of the agreement "to the extent that" you run a business in a free zone or enjoy an offshore tax treatment — the offshore part of your affairs loses protection, the rest keeps it. The French text (« lorsqu'il ») says you lose the benefit altogether. Being taxed only on Hong Kong income (the ordinary position of everyone in Hong Kong) is protected under both texts. An offshore status is protected under neither. No other treaty in this collection contains such a rule.

If France and Hong Kong both claim you, article 4 §2 decides, in order: where your permanent home is, then where your personal and economic ties are strongest, then where you habitually live. Where the usual treaties then fall back on nationality, this one falls back on French nationality for France and the right of abode for Hong Kong, with the two administrations agreeing between themselves if nothing else settles it. French domestic law asks the same question through article 4 B of the tax code — your household, your main place of stay, the centre of your professional and economic interests. Residence is proved with day counts and documents, not asserted.

Sources considered: 2010 agreement arts. 2, 4 §§1–3, 28; protocol ¶¶1, 4, 5; CGI (the French tax code) art. 4 B; BOI-ANNX-000306 (29 April 2026); BOI-INT-CVB-CHN-20241120 §110; BOI-INT-CVB-HKG (2012 vintage — the treaty text prevails). Section 8 gives the Conseil d'État decision on the words "liable to tax". Scope note: the treaty text prevails over the older commentary, and every date here is re-checked at each edition.

Reviewed as at 9 August 2026 · 2010 agreement arts. 2, 4; protocol ¶¶1, 4, 5

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

Two things change for a Hong Kong resident: the 2010 agreement confirms the French wealth tax rather than leaving it to French law alone, and nothing in Hong Kong answers it.

Article 964 of the French tax code charges an annual tax on real-estate wealth above €1,300,000. If you are not domiciled in France, that tax reaches your French property and the property share of any company's shares (article 965, 2°). The 2010 agreement covers wealth taxes: it names the ISF and extends to later taxes of the same kind (article 2 §4). Hong Kong's Inland Revenue Department confirms that it applies to the IFI, the ISF's successor, from 1 January 2018. Article 21 §1 then gives France the right to tax French buildings, and shares drawing more than half their value from French buildings.

Hong Kong charges no wealth tax, so no credit ever arises on the Hong Kong side. The IFI is a French cost of holding the property — paid by you alone, but under a rule both governments signed. In the Japan, Denmark and Brazil relationships the treaties stop at income, so the same charge arrives with no treaty basis at all.

One sentence in article 21 has no equivalent in most French treaties. Paragraph 5 says, in substance: if the treaty reserves an asset to your own state, and your own state does not tax it, then the other state may tax it instead. Hong Kong taxes none of your wealth, so on paper that hands France a permission. In practice France cannot use it: French law taxes a non-resident only on French real estate, and no French rule exists that could reach anything more. The clause costs you nothing today, and it has not lapsed — it is machinery waiting for a French rule that does not exist.

What the purchase costs on the day of the deed

The purchase follows the standard French sequence: your offer; then the pre-sales contract (compromis de vente), with its ten-day cooling-off period and a deposit of usually 10%; then the conditions precedent. Last comes the deed itself (acte authentique), signed before the notaire, who collects the duties and registers your title. The notaire is a public officer. The law obliges him to advise both buyer and seller on the deed he draws up — what it covers, what it commits each side to, what its risks are. His duty stops at the deed: the planning around it (tax, estate, structure) belongs to your own advisers, so Hong Kong buyers keep theirs alongside him. Because Hong Kong will tax neither the property nor its transmission, the planning that matters is French — which is why section 3 is best answered before you sign that contract, not after.

Worked example — the median Cannes villa at €4.9M (the 2014–2025 DVF median for Cannes and its hills):

These figures follow the published scales and are given for orientation; the notaire itemises the duties and fees on your actual deed. A new-build VAT regime, furniture excluded from the price, or a mortgage will change the arithmetic. The annual local property tax (taxe foncière) is set commune by commune, and communes in designated high-demand areas (zone tendue) may vote a surcharge (surtaxe) on second homes; our agency re-checks those rates at each edition rather than freezing them.

Borrowing against the French property cuts French wealth tax and nothing in Hong Kong

A loan from your bank, secured on a pledged portfolio, keeps your money invested while the debt reduces the taxable base. Article 974 of the tax code allows bank acquisition debt to be deducted from the IFI base, and financial assets sit outside that base entirely. Three limits apply. An interest-only loan, with the capital repaid at the end, is treated as if you were repaying it in equal yearly steps, so the deductible amount shrinks year by year — and by one twentieth a year where no term is fixed. Where your French property exceeds €5M and the debt exceeds 60% of its value, only half of the excess is deductible, unless you show the loan was not taken mainly for tax. And the debt must be real: actually drawn, actually serviced, at market terms. If instead the money is lent to a French property-holding company (an SCI) through its shareholder account, the debt no longer reduces the taxable value of the shares (article 973).

Two points belong to Hong Kong specifically. Hong Kong charges no wealth tax, so a loan arranged to cut the French bill brings no matching benefit in Hong Kong — the calculation is one-sided. And if your lender is a related company in Hong Kong, article 973's limits on in-house debt apply in full: a lender outside France is not a lender outside the rule.

Three filings fall due every year, and two of them need a value you declare yourself

None of these depends on the treaty. They fall on the owner of French property whatever their residence, and they are the part a non-resident owner most often discovers late.

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: 2010 agreement arts. 2 §§3–4, 21 §§1, 4, 5; CGI arts. 964, 965, 968, 973–974, 1418, 990 D–990 F; the Inland Revenue Department's statement that the agreement applies to the IFI from 1 January 2018. Scope note: no French court has ruled on article 21 §5; the reading above is the text's own, taken with the IFI as it now stands, and a change to the French base would change it. Costs follow the published scales and are itemised on your deed.

Reviewed as at 9 August 2026 · CGI arts. 964–965, 973–974; agreement arts. 2, 21

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

These are questions to work through with your advisers, not recommendations. One fact shapes all of them: whatever the deed creates will be taxed and inherited under French law alone, because Hong Kong taxes neither the holding, nor the gain, nor the transmission.

A trust changes which country may tax the property, not what France charges

Most French tax treaties name only companies, so whether a trust is covered is a question someone has to argue. This one names trusts outright, in three separate articles.

If the trust sells its shares and more than half their value comes from French property, France taxes the gain (article 13 §1 b). For wealth tax, France counts the property behind the trust, and keeps counting through however many companies or trusts are stacked in between (article 21 §1 b). If holding those shares is what gives you the use of the property, France taxes that use as income (article 6 §5).

Being named settles one thing only: which government may tax. France applies its own trust rules whatever the treaty says about that. The trustee files a return covering the trust, its terms, its beneficiaries and the value of its French assets (article 1649 AB). Article 990 J charges a back-up wealth tax on French assets the trustee fails to declare. Article 792-0 bis decides what happens at death. Check the trust against all three before the deed is signed, not after.

Paragraph 4 of the protocol does the opposite, and it concerns the French company rather than the trust. A family SCI is normally taxed on its partners rather than in its own name, so you would expect the treaty to ignore the company and look at the people behind it. It does the opposite: the SCI itself counts as a French resident. Two conditions attach — the SCI must be managed from France, and every partner must be personally taxed in France on their share of its profits.

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

There is a second route, often proposed alongside a loan, and it divides ownership itself. You keep the right to use the property and take its income for life (the usufruit), and your children take the ownership now (the nue-propriété). The tax code values that split by your age. Under article 669, bare ownership is worth 60% of the full value when you are between 61 and 70, and 70% when you are between 71 and 80. The gift is taxed on that fraction alone, at today's value, and when you die the two halves rejoin with no further tax. 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 property's full value in your own IFI base, so your wealth tax does not move.

For a Hong Kong family this is unusually simple: no treaty covers the gift, France taxes it because the property is in France, and Hong Kong charges your children nothing. The French gift duty on the discounted fraction is the whole cost of the transfer. What the gift does to your children's reserved share belongs with your notaire, alongside the choice of law explained in section 6.

What an ownership structure changes, beyond tax

An ownership structure answers seven questions. Tax is one of them, and rarely the one that matters most.

Sources considered: 2010 agreement arts. 6 §5, 13 §1 b, 21 §1 b; protocol ¶¶4, 10; CGI arts. 669, 751, 968, 973–974, 792-0 bis, 990 D, 990 J, 1649 AB. Scope note: no French court has ruled on how this agreement treats the fiducie, and when a treaty article says which country may tax a trust, that is all it decides. It does not change how France then taxes it. These are questions to settle with your advisers in France and in Hong Kong.

Reviewed as at 9 August 2026 · agreement arts. 6 §5, 13 §1 b, 21 §1 b; protocol ¶4; CGI arts. 669, 968, 1649 AB, 990 J

4What you pay when you sell

France taxes the gain first, because the property is in France. Article 13 §1 a) of the agreement gives France the gain on French buildings. Article 13 §1 b) goes further: it reaches the gain on shares or other rights in a société, a fiducie or a comparable institution, where more than half their value comes, directly or indirectly, from French real estate. That paragraph is the 2010 drafting, and the multilateral instrument left it untouched.

The French charge runs under article 244 bis A of the tax code. Your taxable gain falls by 6% for each year you have owned the property beyond the fifth, and by 4% in the twenty-second year (article 150 VC). Income tax then applies at 19% (article 200 B) and disappears entirely after 22 years, while the social levies disappear after 30. Gains above €50,000 also bear the surcharge of article 1609 nonies G, which reaches 6% at the prices this market transacts.

Worked example — what 22 years of ownership does, per €1,000,000 of gain:

Social levies apply on top until the thirtieth year, at the 17.2% rate borne by sellers outside Europe. Riviera properties are frequently held two decades or more, by which point the income-tax half of the bill has usually already gone. Your actual base is itemised on the deed — works and purchase costs included — when our agency takes the file.

The 17.2% social levies, and the representative you must appoint

You pay the social levies at the full 17.2%. The reduced rate belongs to sellers inside the European social-security system, which a Hong Kong resident is not. The agreement does list the CSG and CRDS among the taxes it covers. That changes nothing in money: Hong Kong taxes no part of the gain, so there is no double tax for the treaty to relieve.

You must also appoint a representative. A seller living outside the EU and the EEA appoints a representative accredited by the French tax administration, who is answerable for filing and paying (article 244 bis A, IV). Two automatic exemptions exist: sales at €150,000 or less per seller, and sales that are fully exempt because you have owned the property thirty years — under the administration's instruction of 22 January 2025. Where a representative is needed, the notaire handling the deed normally arranges it.

Hong Kong then does nothing. It charges no capital-gains tax, and its territorial system leaves a French gain outside its net in any event, so the French assessment is in practice the final one. Article 22 §2 of the agreement stands ready to give you credit for French tax in the rare case where Hong Kong does tax the proceeds. Choosing between selling the property and selling the company therefore changes who will buy it and what you file, more than it changes who taxes you — article 13 keeps that with France either way.

Selling the company instead: three exceptions, all narrow

A separate rule, article 13 §3, keeps gains on holdings of 25% or more of a company's profits taxable where the company is resident. If a sale falls outside article 13 §1 altogether, article 13 §5 gives the gain to your own state alone. Protocol ¶12 qualifies that: each state may tax its own residents anyway where the two states classify the income differently and nobody ends up taxing it. Hong Kong and France sort income into different categories, so a mismatch is a real possibility. The principal-purpose test added in 2017 sits above all of this, and applies to arrangements made long before it.

If you leave France after selling: the exit tax

France's exit tax is narrower than its name suggests. Article 167 bis of the tax code aims at shares, not at property. It applies to people who were French-domiciled for at least six of the ten years before leaving, and taxes the unrealised gain on shareholdings worth more than €800,000, or on stakes of 50% or more of a company's profits. A property you have already sold has paid its own tax, and the sale proceeds are outside the charge. Shares in a family SCI are treated like the property itself rather than like a share portfolio, because French property is most of what the company owns. So as long as the company keeps the ordinary income-tax regime, the gain on those shares stays inside article 150 UB and outside the exit tax. A company that has opted for corporation tax changes that answer, so the option belongs on your pre-departure checklist. Where the exit tax does apply, payment is normally deferred, and the assessment lapses after two years — five if your portfolio exceeded €2.57M — or when you return to France. For most sellers it affects the timing and the paperwork of leaving rather than the cost.

Sources considered: 2010 agreement art. 13 §§1–5, art. 22 §2; protocol ¶¶9, 12; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 219 I a sexies-0 bis, 244 bis A (incl. IV), 1609 nonies G; BOI-RFPI-PVINR-30-20 of 22 January 2025. Section 8 gives the two Conseil d'État decisions on measuring the property half. Scope note: the reductions follow the statutory scales, and your actual base is itemised on the deed.

Reviewed as at 9 August 2026 · agreement art. 13; protocol ¶¶9, 12; CGI arts. 244 bis A, 150 VC, 167 bis

5Renting before you buy, and renting your property out

Renting before you buy

A year's rental before buying is the usual first step. It carries one risk. French tax residence under article 4 B of the tax code depends on where your household is, where you mainly stay, and where your professional and economic interests sit — none of which depends on your lease. A Riviera property that becomes the family's real home can make you French-resident, and taxable in France on your worldwide income, well before you buy anything. Article 4 §2 of the agreement then decides which state wins. The same calendar runs the other way: protocol ¶5 keeps you Hong Kong-resident if you are there more than 180 days in a year of assessment, or more than 300 across two consecutive years. A family splitting its year between the two can find that the day count alone settles it. Choosing between a furnished seasonal rental and a one-to-three-year unfurnished lease (bail civil) also changes how easily you can leave.

Renting your property out

France taxes rental income of non-residents, furnished rentals included, at a minimum of 20% up to the second bracket and 30% above it (article 197 A of the tax code), unless you can show a lower worldwide effective rate. Social levies apply on top at the full 17.2% borne by owners outside the European system. The agreement gives the income to France because the property is here, however it is rented out (article 6 §§1 and 3), and reaches even the enjoyment of property held through shares of a société or a fiducie (article 6 §5). Hong Kong's own property tax reaches Hong Kong buildings only, and its territorial system leaves French rent outside the net, so French tax is all you pay on the rent.

One clause matters if you route the income rather than receive it. Protocol ¶11 says that where the agreement gives a tax benefit on an item of income, and the other state taxes you only on what you actually bring into that state, the benefit applies only to the amount actually taxed there. That is the remittance rule, written in general terms rather than tied to a named regime. For an owner renting a property out it is usually academic, because France taxes the rent at source and gives no benefit for the clause to cut back. That changes if income is deliberately left outside Hong Kong and a treaty benefit is claimed on it.

Sources considered: 2010 agreement arts. 4 §2, 6 §§1, 3, 5; protocol ¶11; CGI arts. 4 B, 197 A; CSS art. L. 136-6. Scope note: no French court has ruled on protocol ¶11, and the paragraph above states the text's own terms without extending them. The answer turns on how the property is rented out and on which social-security system you belong to — both questions of fact.

Reviewed as at 9 August 2026 · agreement arts. 4 §2, 6; protocol ¶11; CGI arts. 4 B, 197 A

6What happens to the property when you die, or give it away

France taxes the inheritance, and Hong Kong does not. France and Hong Kong never signed an inheritance or gift treaty, and Hong Kong abolished estate duty for deaths from 11 February 2006, taxing neither inheritances nor gifts. Those two facts shape everything below.

French duty attaches to the property because it is in France, whatever your domicile, on death and on lifetime gifts alike — and a company in the way does not stop it. A building held through entities in which you, together with your spouse, parents, children or siblings, hold more than half the interests is treated as held by you directly (article 750 ter, 2° of the tax code). If you were domiciled in France, or if the child inheriting has lived in France for six of the ten preceding years, France taxes the worldwide estate instead (article 750 ter, 1° and 3°). The scale is that of article 777: rising to 45% in the direct line above €1.8M per child, after the €100,000 allowance per child of article 779, with your surviving spouse exempt.

Hong Kong adds no tax of its own — and no relief either. France's credit rule, article 784 A, sets foreign death duty only against French tax on assets outside France — and Hong Kong charges no death duty at all. The French bill is the whole bill. Everything that reduces it is French: the allowances, the timing of gifts, the split ownership described in section 3, the matrimonial regime you carry into the purchase, and is best arranged before you sign the pre-sales contract.

Your children's reserved share, and whether you can choose Hong Kong law

Hong Kong succession law follows the common-law model: you may leave your estate as you wish, subject to a court's power to provide for dependants. French law instead reserves a fixed share for your children. Under EU Regulation 650/2012, which France applies to every estate it handles, you may choose the law of your nationality to govern your whole estate. For a Chinese national connected with Hong Kong, the Regulation's rules for countries with more than one legal system point that choice toward Hong Kong law.

Choosing Hong Kong law does not end the matter. Since the French law of 24 August 2021 there is an exception. It applies where you, or one of your children, is a national or resident of an EU member state and the chosen law gives children no reserved share. Each child may then claim compensation out of your French assets, the property first among them, up to what French law would have given them (article 913, paragraph 3 of the Civil Code). Hong Kong law, which lets you leave your estate as you wish, is exactly the kind of law that triggers it — so the risk is real for families with European ties. Your will, your matrimonial regime and the timing of any gifts are questions for your notaire and your Hong Kong adviser together, answered before you sign the pre-sales contract.

Sources considered: CGI arts. 750 ter, 777, 779, 784 A; Code civil art. 913 al. 3; EU Regulation 650/2012; BOI-ANNX-000306 (29 April 2026), which records no inheritance or gift treaty between France and Hong Kong. Scope note: Hong Kong succession law is stated for orientation and belongs with your advisers there; the allowances follow the statutory scales.

Reviewed as at 9 August 2026 · CGI arts. 750 ter, 777, 779, 784 A; Code civil art. 913 al. 3; EU Reg. 650/2012

7The eight questions Hong Kong buyers ask most

Does the France–China tax treaty cover a Hong Kong buyer?

No. The French tax administration states that the France–China convention of 2013 applies neither to Hong Kong nor to Macao; Hong Kong is governed only by the agreement signed at Paris on 21 October 2010. The two also differ in scope — the China convention covers income tax only, while the Hong Kong agreement covers income tax and wealth tax.

Does a Hong Kong resident pay French wealth tax on a Riviera property?

Yes, once your French property exceeds €1.3M, whether you hold it directly or through the property share of a company (article 964 of the tax code). The 2010 agreement covers wealth taxes and has applied to the IFI since 1 January 2018, and its article 21 confirms France's right to tax property in France. Hong Kong charges no wealth tax, so nothing offsets the French bill.

Which country taxes the inheritance of a French property?

France alone. France and Hong Kong have no inheritance or gift treaty, and Hong Kong abolished estate duty for deaths from 11 February 2006. French duty attaches to the property because it is in France, reaches it through family-held companies (article 750 ter), and rises to 45% in the direct line — with no foreign duty anywhere to set against it.

Who taxes the gain when a Hong Kong resident sells a French property?

France, because the property is in France (article 13 §1 of the agreement), under article 244 bis A of the tax code with its reductions for years of ownership — income tax disappearing after 22 years and the social levies after 30. Hong Kong charges no capital-gains tax and taxes only Hong Kong income, so the French bill is in practice the final one.

Does the sale require a fiscal representative?

As a rule, yes. A seller living outside the EU and the EEA appoints a representative accredited by the French tax administration, who is answerable for the filing and the payment (article 244 bis A, IV). Two automatic exemptions apply: sales at €150,000 or less per seller, and sales fully exempt because the property has been owned thirty years.

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

Yes. France taxes it first because the property is here (article 6 of the agreement), at a minimum of 20% and then 30% (article 197 A of the tax code), plus social levies at 17.2%. Hong Kong's territorial system leaves French rent outside its own tax, so French tax is all you pay on the rent.

Can your children claim a share of the property despite your Hong Kong will?

They can. Hong Kong law lets you leave your estate as you wish, subject to provision for dependants. EU Regulation 650/2012 lets you choose the law of your nationality. But since 2021, where you or a child is an EU national or resident and the chosen law gives children no reserved share, each child may claim compensation out of your French assets (article 913, paragraph 3 of the Civil Code).

Does a French exit tax apply after selling and leaving?

Rarely, and never on the property itself. Article 167 bis of the tax code reaches only people who were French-domiciled for six of the ten years before leaving, and only their unrealised gains on shares — above €800,000, or stakes of 50% or more of a company's profits. The property you sold and its proceeds are outside it, as are family-SCI shares kept under the ordinary income-tax regime (article 150 UB).

Sources considered: CGI arts. 167 bis, 197 A, 244 bis A, 750 ter, 964; Code civil art. 913; 2010 agreement arts. 6, 13 §1, 21; EU Regulation 650/2012; BOI-INT-CVB-HKG. Scope note: these answers condense the sections above and inherit their scope notes.

Reviewed as at 9 August 2026

8The court decisions, the sources and the sales figures

Why an exemption in your own country can cost you the treaty — CE n° 394518

French treaties define a resident as someone who, under that country's law, is liable to tax there because of domicile, residence, place of management or a similar test. The Conseil d'État reads those words strictly. It ruled on the identical wording in the France–Germany convention. Someone the law does not subject to the tax in question, because of their status or their activity, is not liable to it — and so is not a resident for the treaty at all. A German pension institution, exempt from corporation tax in Germany, was refused the reduced French withholding rate it claimed.

Applied to Hong Kong, that reasoning would be a serious problem if the 2010 agreement had not dealt with it in advance. It is why paragraphs 1 and 5 of the protocol, set out in section 1, matter more here than their equivalents do in other treaties.

CE, 9e ch., 27 July 2016, n° 394518 — full decision read. Scope note: the decision was given on the France–Germany convention of 21 July 1959, not on this agreement; what carries across is its reading of the words "liable to tax", which article 4 §1 of the Hong Kong agreement also uses. No French court has yet ruled on article 4 of this agreement.

What counts as "more than half in French property" — CE n° 494888 and n° 432053

The "more than half" test looks like arithmetic. In practice two questions settle it: on what date the half is measured, and what belongs in the count. French law answers the first expressly. The company's assets are taken at the date of the sale, or at the end of the previous financial year, on more than 50% of their real value rather than their book value (article 219, I, a sexies-0 bis of the tax code). It answers the second by leaving out property the company uses for its own business. The second question still reaches the Conseil d'État: in September 2025 it overturned an appeal ruling which had held that quarry deposits were not buildings because the stone would eventually be dug out. Quarries, the court held, are immovable by their very nature, and belonged in the count.

CE, 8e-3e ch. r., 17 September 2025, n° 494888; CE, 8e-3e ch. r., 22 November 2019, n° 432053 — full decisions read. Scope note: both construe the French domestic definition, not article 13 of this agreement, and are given for the method they establish (real value, a fixed measuring date, own-use property left out) rather than as rulings on the treaty.

What changed, and what our agency is watching

Edition 1 — the position in August 2026. The agreement of 21 October 2010 has been in force since 1 December 2011 and has never been amended. The anti-abuse rule reached it late. It came into force for France on 1 January 2019 and for Hong Kong on 1 September 2022, on notifications China lodged for Hong Kong on 25 May 2022. It applies to tax periods from 23 September 2023, and to French withholding tax from 1 January 2024.

Sources considered: BOI-INT-CVB-HKG. Scope note: nobody can promise when a treaty will be ratified; our agency re-checks the position at each edition.

The sales figures behind this brief

Hong Kong charges no tax on the gain when you sell, none on the wealth while you hold, and none on the estate when you die. Every euro of tax on the property is therefore French. Across Cannes and its hills, the Saint-Tropez peninsula and Saint-Jean-Cap-Ferrat, 1,490 villas sold at €3M and above for €11.5 billion over the twelve years to 2025.

Source: DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales ≥ €3M, 2014–2025, duplicate estate records removed — the same method as the published Riviera Intelligence pages. Register complete to 31 December 2025.

Where the owners live, in aggregate. The figures below count owners, they do not identify them. They are totals, never single sales, and no percentage here can be traced back to a person. They come from the French government's own record of property transactions and from the public company registers — both already public. No owner is named anywhere in this brief. Across 20 Riviera communes, 34% of the ownership positions studied are held from outside France, and Hong Kong accounts for 3% of those.

Aggregates only, drawn from public sources under their re-use conditions; no individual holding is identified or published. Residence follows the address on the register. These figures are refreshed at each edition.

How this brief was checked, and its limits

Every statement of law is checked against the Chiron Legal Corpus — the research library maintained by our offshore legal-research partner — and re-checked against the official sources at each edition. The review of 9 August 2026 covered four sources.

• Légifrance — CGI arts. 4 B, 150 UB, 150 VC, 167 bis, 197 A, 200 B, 219 I a sexies-0 bis, 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.
• The agreement of 21 October 2010, in the official French text, with the anti-abuse rule incorporated.
• The tax authority's treaty list of 29 April 2026.
• Its commentary on the China convention.

The commentary on the Hong Kong agreement dates from September 2012, before the multilateral instrument; where the two disagree this brief follows the treaty text. The rules on fiscal representatives follow the instruction of 22 January 2025. Hong Kong law (the territorial system, the absence of capital-gains, wealth and death taxes, and the succession model) is stated for orientation from Hong Kong's own published sources, and never carries a legal conclusion on its own. Market data: DVF (DGFiP), villa sales ≥ €3M, duplicate estate records removed, register complete to 31 December 2025.

This brief sets out published law and public transaction data. It is research, not advice on your own situation: your residence history, nationality, matrimonial regime and chain of title all change the answer. For an actual purchase or sale, our agency brings in the French tax lawyer and the notaire you need, and handles the sale or purchase itself.

Reviewed as at 9 August 2026 · full decisions 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–India — the convention pair

France–China — the convention pair

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