France–India — The Riviera Private Wealth Brief

0Executive summary

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

1The France–India convention — 1992, income and wealth alike

The relationship rests on a single instrument of unusual breadth. The convention of 29 September 1992, signed at Paris with a protocol forming an integral part of it, replaced the 1969 text; approved by the loi n° 94-321 of 25 April 1994 and published by the décret n° 94-670, it entered into force on 1 August 1994, its provisions applying in France to income from 1 January 1995 and to wealth held at that date, and in India to fiscal years beginning 1 April 1995. It covers taxes on income and on wealth alike — on the French side the income tax, the corporation tax and the solidarity wealth tax are listed by name; on the Indian side the income tax with its surcharge, the surtax and the wealth-tax. Taxes established after signature that are identical or analogous in nature join the covered list by the convention's own terms, which is the footing on which the IFI, successor to the listed wealth tax, sits within the treaty. The administration's treaty list of 29 April 2026 records the relationship as covering income and wealth taxes, and no succession or gift convention — an absence that, as section I bis develops, leaves the death-and-gift questions to French law alone. The multilateral instrument, signed by both states on 7 June 2017, entered into force for France on 1 January 2019 and for India on 1 October 2019, on notifications lodged on 26 September 2018 and 25 June 2019: it added the principal-purpose test, under which a treaty advantage can be refused where obtaining it was a principal object of an arrangement, and rewrote the property-rich gains clause examined in section II. An avenant signed at New Delhi on 18 February 2026 will modernise the convention further once approved and ratified; it is not yet in force, and section 4 sets out what it changes. The convention was done in French, Hindi and English, the three texts equally authentic; this brief quotes the French text in the administration's consolidated presentation. A protocol clause of the relationship's vintage — its most-favoured-nation undertaking — has over the years imported lower withholding rates from India's later treaties with OECD members, a dividends-and- interest matter marginal to property holding but characteristic of this pairing.

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.

The Indian side keeps its own accents. Indian residence turns principally on days of presence — 182 in the fiscal year as the primary test, with special counts for citizens living and working abroad — and returning families benefit from a transitional "resident but not ordinarily resident" status that keeps most foreign income outside Indian tax for a period. India levies no inheritance tax and no net-wealth tax today, taxes certain gratuitous receipts as income in the recipient's hands while leaving close family and inheritances outside that charge, and requires its ordinarily-resident taxpayers to report foreign assets in the annual return's dedicated schedule. Outward capital moves under the exchange-control framework examined in section I. This brief states Indian law at orientation level only; its verified ground is the French side and the 1992 convention, and the Indian reading belongs with the family's advisers in Mumbai or Delhi.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1992 convention (CML consolidation) preamble, arts. 2, 4; BOI-ANNX-000306 (29 April 2026); BOI-INT-CVB-IND (2016 vintage — the text prevails); avenant of 18 February 2026 (signed, not in force)

2The market seen from India

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

Source: DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales ≥ €3M, 2014–2025, estate-deduplicated — the same convention as the published Riviera Intelligence hub, so this brief and the public pages cannot disagree. DVF through 2025-12-31.

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

IBuying in France as a resident of India

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 Indian 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.

Funding the purchase from India — the remittance ceiling

Before any French question arises, an Indian purchase answers to Indian exchange control. A person resident in India remits abroad under the Reserve Bank's Liberalised Remittance Scheme, which permits up to US$250,000 per individual per financial year for permitted purposes, the acquisition of immovable property abroad included; family members may combine their ceilings for a property purchase provided each complies with the scheme and the property is co-owned, and the scheme is closed to companies, family arrangements and trusts. At this market's price points the arithmetic is unforgiving: the median Cannes villa represents roughly two decades of one person's annual ceiling, so a purchase funded from India is in practice a multi-year, multi-member family programme, planned well before the compromis. Indian banks also collect a tax at source on large remittances under the scheme — at 20% above a cumulative threshold of ₹10 lakh per year at orientation level, creditable against the remitter's Indian tax — a cash-flow item rather than a final cost. In turn, members of the diaspora who are non-resident under Indian exchange-control law stand outside the scheme and fund the purchase from their own foreign resources; which family member signs the deed is therefore a planning decision in itself, and the Indian side of it belongs with the family's bankers and advisers at home. Indian law is stated here at orientation; the scheme's ceilings and collection rates have moved repeatedly and are re-verified at each edition.

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 settled rather than absent: the 1992 convention covers wealth taxes, and its article 24 assigns to France the fortune constituted by French immovables (§1) and by shares of companies whose assets consist principally, directly or indirectly, of French property (§2) — the charge runs on domestic law with the treaty's express confirmation, the opposite footing from the Japan and Brazil relationships, where the conventions stop at income. India levies no net-wealth tax of its own, having abolished it in 2015, so the IFI is a French cost of carry rather than a double charge; the convention's Indian credit for French wealth tax (article 25 §2 a) remains in the text, machinery with nothing currently to serve.

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. An ordinarily-resident Indian owner also reports the villa in the foreign-asset schedule of the Indian annual return, under a dedicated 2015 statute; the family's advisers in India keep that schedule aligned with the French title and filings.

Law reviewed as at 20 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965; 1992 convention arts. 24, 25 §2; cost scales stated for orientation, itemised at engagement; Indian exchange control at orientation (RBI published scheme)

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 an Indian buyer the analysis carries one organising fact: with no succession or gift convention, and no Indian charge at death, whatever the deed creates will be read at transmission by French law alone — the scale, the look-through and the reliefs are all French.

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). 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 for this relationship it writes it in one hand. 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. On the Indian side there is nothing to coordinate: India abolished its estate duty in 1985, and its income-tax treatment of gratuitous receipts leaves inheritances, and gifts from close family — lineal ascendants and descendants included — outside the charge, at orientation level. France's credit mechanism, article 784 A, operates only in the worldwide cases of 750 ter 1° and 3°, and even there credits foreign duty solely against the tax on foreign-situs assets; with no Indian death duty there is, in practice, nothing to credit. The transmission cost of a Riviera villa in Indian hands is therefore the French scale, in full, and the planning levers are the French ones.

One European instrument does speak, and for Indian families it cuts the other way from what is often assumed. Under Regulation 650/2012, which France applies to all successions, an Indian national habitually resident in France may elect Indian law for the succession as a whole. Indian succession law is a system of personal laws, and under several of them — the regime governing most Hindu testators' self-acquired property among the examples — a will disposes freely, with no reserved share for children. The compensatory levy French law added in 2021 arises precisely 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. An election of a freely-disposing personal law can therefore meet that levy on the French assets rather than escape the reserve — the reverse of the reading this series has given reserve-type systems elsewhere — while other Indian personal laws, with fixed shares of their own, sit differently. The point is assessed on the succession's actual facts, with counsel on both sides; the choice of law, the matrimonial regime carried into the purchase, and the calendar of any gifts are best settled 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 an Indian family the setting is unusually clean: the gift falls within no convention, France taxes it as the situs state on the French scale, and a gift between parent and child attracts no Indian charge at orientation level. The forced-heirship consequences of a gift to children belong with the family's counsel, alongside the choice-of-law reading set out 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 D, 990 J, 1649 AB; Code civil art. 913; EU Reg. 650/2012; 1992 convention arts. 14, 24, 25 §2

IISelling as a resident of India

France taxes first, as the state where the property stands: article 14 §1 assigns gains on French immovables to France, and paragraph 4 of the same article — rewritten by the multilateral instrument — reaches gains on shares and comparable interests, partnership and trust interests included, that drew more than half their value from French real estate at any time in the 365 days before the sale; a further paragraph keeps gains on participations of at least 10% in a French company within France's reach. For an India-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 an India-resident seller does not hold; how far India's credit reaches these levies is a question of Indian 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.

India then answers as the residence state. The convention leaves the situs allocation non-exclusive: India taxes the gain under its own law and credits the French charge against its own, within the limit of the Indian tax on that income (article 25 §2 a). 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 14 keeps with France on both routes; that choice is still best evaluated before marketing begins rather than in the course of negotiation. Where the purchase was funded from India under the remittance scheme, the return of the proceeds is a question of Indian exchange control, settled with the family's bankers at engagement.

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 · 1992 convention arts. 2, 14 §§1, 4–5, 25 §2; 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 convention then decide which state prevails. 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 convention 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: India taxes its resident on the same income under its own law and credits the French tax (article 25 §2 a), the mechanics of that credit belonging with the family's advisers in India, where the income and the villa itself are also reported in the annual return's foreign-asset schedule.

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; 1992 convention arts. 4 §2, 6, 25 §2

4What changed

Edition 1 — baseline (July 2026). The instruments as they stand: the convention of 29 September 1992 with its integral protocol, in force since 1 August 1994, modified by the multilateral instrument — in force for France since 1 January 2019 and for India since 1 October 2019, on notifications lodged on 26 September 2018 and 25 June 2019. No succession or gift convention exists, and none is recorded as under negotiation. The standing watch item is the avenant signed at New Delhi on 18 February 2026, which the administration publishes with the express notice that it must now pass parliamentary approval and ratification and is not yet in force. As signed, it replaces the preamble and articles 5, 11, 12, 13, 14, 25 and 28: the new gains article keeps the situs rule and the 365-day property-rich clause but extends France's right to gains on shares of French companies without the current 10% participation floor, with a grandfathering line in the protocol for business-use property in holdings acquired before 1 April 2026; the elimination article is rewritten to the modern credit method; the wealth article — article 24 — is left untouched. Its permanent- establishment and gains articles apply only after a two-year deferral from entry into force, so the transition will be gradual; edition 2 will restate section II when ratification completes. The administration's commentary on the convention (BOI-INT-CVB-IND) dates from November 2016 — before the multilateral instrument — and this brief follows the treaty text where the two diverge. Further watch items: annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; and the Indian budget cycle's repeated adjustments to the remittance scheme's ceilings and collection rates, which moved in 2023 and again in 2025. 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

5Questions, answered

Does an India 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 1992 convention covers wealth taxes and assigns French immovables, and property-rich company shares, to France (art. 24), so the charge is treaty-confirmed rather than merely uncontested. India abolished its own wealth-tax in 2015, so the cost is one-sided in practice.

Which country taxes the succession on a French villa?

France alone, in practice. No France–India succession convention exists; 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; and India has levied no inheritance tax since its estate duty was abolished in 1985. The transmission cost is the French scale in full, and the planning levers — choice of law, matrimonial regime, lifetime gifts — are the French ones.

Are lifetime gifts covered by the France–India treaty?

No. The 1992 convention covers income and wealth taxes only, and France's treaty list records no gift instrument with India. A gift of the villa, or of its bare ownership, bears French gift duty as situs-state taxation; on the Indian side, gratuitous receipts from close family — lineal ascendants and descendants included — and inheritances stay outside the income-tax charge on recipients, at orientation level.

Can the purchase be funded from India?

Within limits. A person resident in India remits under the Liberalised Remittance Scheme — up to US$250,000 per individual per financial year, property purchases included, with family ceilings combinable only where each member complies and the property is co-owned. Large remittances also bear a tax collected at source, creditable in India. Non-resident members of the family stand outside the scheme and fund from their own foreign resources; who signs the deed is therefore a planning decision, taken with the family's bankers before the compromis.

Who taxes the gain when an India resident sells a French villa?

France first, as the state where the property stands (art. 14 §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. India then taxes the same gain under its own law and credits the French charge against its own (art. 25 §2 a). Property-rich company shares follow the same allocation under the 365-day clause the multilateral instrument added.

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.

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

Yes — France taxes it first as the situs state (convention, 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. India taxes the same income in the resident owner's hands and credits the French tax under article 25 §2 a) of the convention.

Does French forced heirship bind an Indian family?

More closely than the choice of law suggests. Under EU Regulation 650/2012, an Indian national habitually resident in France may elect Indian law for the succession; but where the applicable personal law leaves property freely disposable by will — the position for much self-acquired property under Hindu law, at orientation — it offers no reserve, and the compensatory levy of Code civil article 913, al. 3 can then operate on the French assets for children who are EU nationals or residents. The election is therefore weighed, not assumed; 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 D, 990 J, 1609 nonies G, 1649 AB; Code civil art. 913 — consolidated texts), the convention of 29 September 1992 in its official French consolidation — the multilateral instrument incorporated, as published by the administration — the avenant of 18 February 2026 as published by the administration with its not-in-force notice, and the administration's treaty list of 29 April 2026, which records the France–India relationship as covering income and wealth taxes with no succession or gift instrument. The administration's commentary on the convention (BOI-INT-CVB-IND) dates from November 2016 and predates the multilateral instrument; this brief follows the treaty text. The non-resident representation and dispense mechanics follow the administration's instruction of 22 January 2025. Indian domestic law and exchange control — the residence rules, the remittance scheme and its ceilings and collection rates, the foreign-asset reporting regime, the taxation of gratuitous receipts, and the personal-law succession systems — are stated at orientation level from the Reserve Bank's published scheme and secondary sources, and are 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 Indian return of French-taxed income, the exchange-control mechanics of funding and repatriation, 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.

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

Further intelligence

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

France–UAE — the convention pair

France–Hongkong — the convention pair