The implications of buying, selling and renting French Riviera property for residents of Ireland — from the 1968 convention, the tax code, and the succession convention the two states do not have.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
The relationship rests on a single instrument of 1968 vintage — among the older conventions France keeps in force — and on its modern overlay. The convention of 21 March 1968, in force since 15 June 1971, was modified by the multilateral instrument with effect for the two states from 2019–2020, and the consolidated text now carries the principal-purpose test, under which a treaty advantage can be refused where obtaining it was a principal object of an arrangement. Both states publish an official consolidated presentation — France its CML consolidation, Ireland its synthesised text — and this brief quotes each edition's own language from its own official text.
What the convention covers, and what it does not. The 1968 text applies to income taxes alone. It never extended to wealth taxation, and no succession convention was ever concluded between the two states — a gap that places the relationship in the opposite situation to France's treaties with Monaco and the United Kingdom, and that gives the acquisition-day decisions of section I bis unusual weight. One nuance of the same vintage deserves note: Irish capital gains tax post-dates the convention's signature, and the extent to which it stands within the treaty as an analogous later tax is a question examined at engagement rather than assumed.
The Irish side retains its own particularity. Ireland continues to operate a remittance basis for its resident non-domiciled taxpayers — the regime the United Kingdom abolished in 2025 — and the interaction between that basis, Irish credit relief and French source taxation belongs with the family's Irish advisers. This brief states Irish law at orientation level only; its verified ground is the French side and the convention's two official texts.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1968 convention as MLI-modified, arts. 1, 3, 21 (both official consolidated texts); BOI-INT-CVB-IRL-10/-20 (2012 vintage — the text prevails)
Seen from Dublin, the Riviera's €3M+ villa market leads with the same three registers that anchor these briefs. Saint-Jean-Cap-Ferrat is the narrowest and most expensive on the coast: 159 qualified sales for €2,132M across 2016–2025, at a €6.5M median and a €200.0M ceiling. Cannes and its hills contributed 284 sales for €1,949M at a €4.9M median, while the Saint-Tropez peninsula remains the largest €3M+ register on the coast, at 920 sales for €6,472M. The past 36 months alone account for €3,970M across the three.
| Market | Decade sales | Total €M | Median €M | Ceiling €M | 36-mo sales | 36-mo €M | ≥€10M (36-mo) |
|---|---|---|---|---|---|---|---|
| Saint-Jean-Cap-Ferrat | 159 | 2,132 | 6.5 | 200.0 | 53 | 555 | 19 |
| Cannes & its hills | 284 | 1,949 | 4.9 | 46.5 | 98 | 697 | 16 |
| Saint-Tropez & the Gulf | 920 | 6,472 | 4.9 | 85.5 | 353 | 2,718 | 68 |
Source: DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales ≥ €3M, 2016–2025, 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.
The public record itself describes how the Riviera is held. This brief reads it in aggregate — the State's transaction register alongside the public company registers, all of it already published, anonymised in processing, and with no individual holding ever identified. Across 10 Riviera communes, 29% of the ownership positions studied are held from outside France, and 60% of all positions are held through a company. The Irish sample sits below this study's reporting threshold, so this edition publishes the general aggregates alone; the Irish line will appear as the register deepens — one of the ways each edition differs from the last.
Aggregates only, drawn from public sources under their re-use conditions; no individual holding is identified or published. Residence attribution follows the address of record. Figures refresh with each edition.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · DVF register, estate-deduplicated · ownership aggregates from public registers only
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 Irish buyers typically retain their own advisers in addition. Because the two states have no succession convention, the structure questions of section I bis deserve to be settled before the compromis with particular care: here more than in treaty pairs, the deed decides.
| Item | Basis | Amount | Borne by |
|---|---|---|---|
| Transfer duties & land-registration taxes | ≈ 5.81 % of price (standard-rate département; existing property) | €284,526 | Buyer |
| Notaire's émoluments & disbursements | ≈ 1.1–1.4 % at this price point (regulated sliding scale) | ≈ €61,250 | Buyer |
| Indicative all-in acquisition costs | ≈ 7 % on an existing property | ≈ €345,776 | Buyer |
| Agency fee | Per mandate; conventionally included in the advertised price | — | Per mandate |
The notaire itemises duties and émoluments precisely on the actual deed structure; a new-build VAT regime, furniture carve-outs or mortgage security will alter the arithmetic. The figures above reflect the standard published scales and are stated for orientation.
CGI article 964 institutes the annual tax on real-estate wealth above €1,300,000 of taxable assets. For persons not domiciled in France the base comprises French-situs property together with the fraction of any company's shares representing French property (article 964-2°), and the 1968 convention never extending to wealth taxation, the IFI applies to an Irish-resident owner without treaty mediation. The exposure is one-sided by design: Ireland levies no comparable tax, so the IFI is a French cost of carry rather than a double charge. The statute contains one planning window of note — a person who becomes French-domiciled after five years abroad is taxed for five years on French assets only (article 964-1°, al. 2), of direct relevance to a family contemplating the move.
Recurring charges follow the property. Taxe foncière runs at communal rates; for furnished secondary residences, communes in the zone tendue — a category that includes the marquee Riviera communes — may vote a surtaxe on the taxe d'habitation for second homes, and the annual occupancy declaration is required of all owners. Because these rates are communal and year-specific, this brief's edition cycle re-verifies them rather than freezing them.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965; cost scales stated for orientation, itemised at engagement
Holding structures are presented here, in keeping with this line's doctrine, as questions for analysis rather than as recommendations. For the Irish buyer every row of the table below carries one further consideration: with no succession convention between the states, whatever the deed creates will one day be read by two domestic laws at once.
| Question | What it decides | The Irish-specific twist |
|---|---|---|
| Direct ownership? | Simplicity; situs taxation for gains and for succession | The baseline against which everything else is measured — French situs rules apply undiluted, and the Irish reading follows the beneficiaries |
| Irish or other foreign company? | Confidentiality, consolidation | The annual 3% tax question and its disclosure regimes; property-fraction IFI in any event |
| French SCI? | Governance, co-ownership, French financing | Cross-border classification of the SCI on the Irish side is a counsel question — the French side taxes the property fraction regardless |
| Trust anywhere in the chain? | Dynastic control, a familiar Irish instrument | French law names the trust: trustee reporting under CGI article 1649 AB and the dedicated levy of article 990 J the moment French assets or French residents are touched |
| Usufruct / bare-ownership split? | Lifetime transmission at reduced values | Works identically on the French side; with no convention, gift and succession alike answer to French domestic rules — and to the Irish reading beside them |
This is the relationship's distinctive terrain, and it is best stated plainly. On the French side, succession duty attaches to the villa as French-situs property under domestic law (CGI article 750 ter): the scale of article 777 runs progressively to 45% in the direct line beyond €1.8M per share, after the €100,000 per-child allowance of article 779, and the surviving spouse is exempt. On the Irish side, capital acquisitions tax follows the residence of the disponer and of the beneficiary rather than the situs of the asset, so the same transmission may fall within both systems; each state then relieves, if at all, under its own unilateral rules rather than under a treaty. Nothing here is unusual — but where the Monaco and UK briefs could point to a convention's allocation and credit machinery, this relationship has only the arrangements the family makes for itself. In practice that elevates four decisions taken at acquisition: the matrimonial regime carried into the purchase; the choice-of-law election that France recognises under EU Regulation 650/2012 for the succession as a whole; the holding structure, each row of the table above; and the calendar of any lifetime gifts, which no convention covers either. The two readings — French and Irish — are best obtained together, before the compromis, from counsel on each side.
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.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 669, 750 ter, 751, 777, 779, 968, 973–974, 990 J, 1649 AB; no succession convention — French domestic rules apply throughout
Two states are engaged, and the convention's old text is precise on the point. Article 3 of the 1968 convention, which assigns income from immovable property to the state where the property is situated, provides in terms that its rules "shall likewise apply to profits from the alienation of immovable property"; the multilateral instrument has since added the modern clause reaching gains on shares and comparable interests deriving their value principally from immovable property. France therefore taxes the sale as situs state, under CGI article 244 bis A for Irish-resident sellers, with the standard ownership-duration allowances — the income-tax component extinguishing after 22 years of ownership and the social levies after 30. Ireland sitting within the European Union, the accredited fiscal-representation requirement borne by third-country sellers does not arise.
Ireland then taxes its residents under its own rules, and the convention's article 21 provides the relief: French tax payable on French-source income is allowed as a credit against the Irish tax on the same income. A nuance of the convention's age accompanies the credit — Irish capital gains tax post-dates the convention, and its place within the treaty as an analogous later tax is examined at engagement rather than assumed. Where the property is held through a company, the choice between selling the asset and selling the shares alters the pool of buyers and the analysis on both sides; that choice is best evaluated before marketing begins rather than in the course of negotiation.
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 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1968 convention arts. 3, 21 + MLI capital-gains clause; CGI arts. 150 UB, 167 bis, 244 bis A
A rental year before purchase remains the classic first step, and it carries one caution worth stating clearly: French tax domicile under CGI article 4 B turns on the location of the foyer, the principal place of stay, and the centres of professional and economic interest — none of which defers to a lease. A Riviera villa that becomes the family's effective home can establish French residence, with worldwide consequences, well before any purchase. The 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.
French-source rental income of non-residents is taxed under the minimum-rate regime of CGI article 197 A, at no less than 20% up to the second-bracket ceiling and 30% above it, unless the taxpayer demonstrates a lower worldwide effective rate; social levies apply in addition, at a rate that depends on the owner's social-security affiliation — owners within the EU coordination typically at the reduced rate, verified at engagement. The convention assigns the income to France as situs state (article 3), and Ireland, taxing the same income in its residents' hands, allows the French tax as a credit under article 21. The interaction of that credit with Ireland's remittance basis for non-domiciled residents belongs with the family's Irish advisers.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A; 1968 convention arts. 3, 21
Edition 1 — baseline (July 2026). The instruments as they stand: the convention of 21 March 1968 as modified by the multilateral instrument, with effects for the two states from 2019–2020 (principal-purpose test included), read in both official consolidated presentations — the French CML consolidation and Ireland's synthesised text. No succession convention exists, and none is under announced negotiation as at 17 July 2026. Watch items for edition 2: any Franco-Irish renegotiation announcement; Irish Finance Act movements on capital acquisitions tax and capital gains tax; annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; and any refresh of the administration's 2012-vintage commentary on the convention. The ownership aggregates of section 2 are refreshed with each edition.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
Yes, once French real-estate assets exceed €1.3M, whether held directly or through the property fraction of company shares (CGI art. 964). The 1968 convention covers income taxes only, so no treaty relief applies — but Ireland levies no wealth tax, so the charge is never doubled.
France first, as situs state: the 1968 convention's article 3 extends expressly to profits from the alienation of immovable property, and CGI article 244 bis A applies with the ownership-duration allowances. Ireland then taxes its residents and allows the French tax as a credit (art. 21); the treaty position of Irish capital gains tax, which post-dates the convention, is examined at engagement.
Both may. France and Ireland have no succession convention: France taxes the villa as French-situs property under its domestic rules, and Irish capital acquisitions tax follows the residence of disponer and beneficiary, with relief on each side unilateral rather than treaty-based. The coordination is built at acquisition — matrimonial regime, choice-of-law election, structure and the calendar of gifts.
Yes. France taxes first under the minimum-rate regime of CGI article 197 A, at no less than 20% and 30%, with social levies in addition; Ireland taxes the same income as residence state and credits the French charge (1968 convention, arts. 3 and 21).
Yes, expressly. The trustee must declare the trust — its terms, parties and asset values — once the settlor or a beneficiary is French-domiciled or the trust holds French property (CGI art. 1649 AB), and article 990 J holds a dedicated levy at the top IFI rate in reserve for trusts whose French assets go undeclared. A properly declared trust does not bear the levy; an undeclared one does.
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.
Yes. Acquisition debt owed to a bank is deductible from the IFI base under CGI article 974, and pledged financial assets remain outside the tax altogether. The deduction is bounded: interest-only loans are deemed to amortise each year, and where property exceeds €5M and debt exceeds 60% of its value, the excess counts only as to half unless a mainly non-tax purpose is shown.
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 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
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 17 July 2026 covered Légifrance (CGI arts. 4 B, 150 UB, 167 bis, 197 A, 244 bis A, 669, 750 ter, 751, 777, 779, 964–965, 968, 973–974, 990 J, 1649 AB — consolidated texts) and the treaty instrument in both official consolidated presentations (the French CML consolidation and Ireland's synthesised text of the 1968 convention as modified by the multilateral instrument). The administration's commentary on the convention (BOI-INT-CVB-IRL) dates from 2012 and predates the multilateral instrument; where commentary and consolidated text diverge, this brief follows the text. Irish law is stated at orientation level from secondary sources and is never load-bearing for a legal claim. Market data: DVF (DGFiP), villa sales ≥ €3M, estate-deduplicated, register through 2025-12-31. Ownership aggregates: compiled from public land and company registers, anonymised, as at 17 July 2026. Items flagged "at engagement" — communal rates, social-levy affiliation, the treaty position of Irish capital gains tax, the remittance-basis interaction — 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, domicile, 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.
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© 2026 Elena Agueeva · Riviera Intelligence · Confidential: for the addressee's professional use; not for onward distribution.
Law reviewed as at 17 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus