France–Italy — The Riviera Private Wealth Brief

0Executive summary

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

1The France–Italy conventions — 1989 and 1990

The relationship rests on two instruments of the same vintage. The convention of 5 October 1989, signed at Venice and in force since 1 May 1992, replaced a 1958 text and governs taxes on income and on wealth: the French list of article 2 names the impôt de solidarité sur la fortune alongside income and corporation tax, while the Italian list of 1989 — IRPEF, IRPEG and the local income tax — contained no wealth tax, Italy then levying none. The convention extends to identical or analogous taxes instituted after signature (article 2 §4), the footing on which the IFI, successor to the ISF from 2018, is examined — a reading the administration itself applies to ISF-era treaty provisions. Exchanges of letters completed the frame: those of 7 and 28 July 1998 confirmed the CSG and CRDS on the French side and the IRAP on the Italian, and that of 20 December 2000 settled the treatment of social-security pensions. The succession and gift convention of 20 December 1990, signed at Rome and in force since 1 April 1995, completes the relationship; its reach — estates and lifetime gifts alike — is examined in section I bis.

Neither instrument is modified by the multilateral instrument. Both states signed the BEPS multilateral convention on 7 June 2017; France deposited its ratification and has applied it since 1 January 2019, while Italy, as at the OECD's June 2026 status list, has not deposited its own. The 1989 convention accordingly continues to apply as signed, without the principal-purpose test the instrument would import — a point of difference from most of France's major treaty relationships, and a watch item of this brief's edition cycle.

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. Article 4 §1 adds a boundary worth noting: persons taxed in a state only on income arising there, or on wealth situated there, are not residents of that state for the convention.

The substitute-tax question

That boundary has acquired a contemporary edge. Italy's regime for new residents taxes foreign-source income by a fixed annual substitute — €100,000 at its creation in 2017, €200,000 for arrivals from August 2024, and €300,000, with €50,000 per family member, for transfers of residence from 1 January 2026 — while Italian-source income remains under the ordinary rules. Whether such a resident is a treaty resident under the 1989 convention is not a question the text answers. The comparison with Switzerland is instructive: the Swiss convention excludes persons taxed on an expenditure-based forfait expressly (article 4 §6 b), an exclusion the Conseil d'État has applied in terms; the Italian convention carries no analogous clause, and the general exclusion of article 4 §1 speaks of persons taxed only on source income, which a forfait resident, taxed on Italian income in full, is not in any literal sense. The administration has published no position on the Italian regime, and the question — of practical weight for treaty relief on French-source income — is examined case by case at engagement. What does not move is the villa: on French-situs property and its income, gains and transmissions, France taxes as the situs state whatever the owner's treaty position.

The Italian side keeps its own accents. Italy taxes successions and gifts at rates far below the French scale — 4% in the direct line above a €1,000,000 allowance per beneficiary, against a French direct-line scale that reaches 45% — and its new-resident regime leaves foreign assets outside Italian succession and gift tax while it runs. Private gains on real estate held beyond five years generally fall outside Italian income tax altogether. This brief states Italian law at orientation level only; its verified ground is the French side and the two conventions, and the Italian reading belongs with the family's Italian advisers.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1989 convention arts. 2, 4, 24; Protocol; EDL 1998/2000; BOI-ANNX-000306 (29 Apr 2026); OECD MLI status list 18 June 2026; CH convention art. 4 §6 b + CE n° 469789 for the comparison; BOI-INT-CVB-ITA (2012–2013 vintage — the text prevails)

2The market seen from Italy

Seen from Italy, the Riviera's €3M+ villa market begins at the border and runs west. The Near-Monaco arc — Roquebrune-Cap-Martin, Èze, Beaulieu, Cap-d'Ail, Villefranche and Beausoleil, the communes between the Principality and the Italian frontier — recorded 358 qualified sales for €2,758M across 2014–2025 at a €4.7M median. Saint-Jean-Cap-Ferrat is the coast's narrowest and most expensive register: 178 sales for €2,375M at a €6.5M median and a €200.0M ceiling, with 76% of value in eight-figure transactions. The Saint-Tropez peninsula remains the largest €3M+ register on the coast, at 1006 sales for €7,049M. The past 36 months alone account for €4,392M 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.

Ownership, in aggregate

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 20 Riviera communes, 29% of the ownership positions studied are held from outside France, while Italy accounts for roughly 2% of those foreign-held positions in the current study. For the nearest of France's neighbours, that is a modest footprint on these particular pockets; the Italian presence on this coast has historically run eastward, toward Menton and the border communes, and the Near-Monaco arc of section 2 is where the two markets meet.

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 19 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 an Italian resident

The process and its costs

The acquisition follows the standard French sequence: offer, compromis de vente with a ten-day cooling-off period, deposit of customarily 10%, conditions precedent, and the authentic deed before the notaire, who collects the duties and registers title. The notaire acts as a public officer rather than as the buyer's counsel, and Italian buyers, accustomed to a notarial system of their own, typically retain their own advisers in addition. Because the 1990 convention settles succession and gift questions largely by reference to what the deed creates, 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.

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 964-2°), and the treaty position is settled rather than absent: article 23 §1 of the 1989 convention makes the fortune constituted by French immovables taxable in France, and point 11 a of the Protocol extends the rule to shares of companies whose assets are principally French real estate. An Italian-resident owner therefore bears the IFI with the treaty's confirmation rather than its shelter. Italy being a member state of the European Union, no French fiscal representative is required for the IFI's declarations (article 983).

The same property may answer to a second wealth charge at home. Since 2012 Italy has taxed the foreign real estate of its residents through the IVIE, at 1.06% of the relevant value from 2024; the 1989 convention, drafted when Italy levied no wealth tax, runs its fortune credit in one direction only — toward France, for French residents holding Italian-taxable fortune (article 24 §1 b) — and the Protocol's undertaking that the two states would consult to adapt the convention should Italy institute a wealth tax (point 11 c) has produced no amending instrument. Relief on the Italian side accordingly rests on Italy's own credit rules for foreign property taxes, and its measure for a French villa — which French charges qualify, and to what extent — belongs with the family's Italian advisers.

For the family weighing a full move to France, the convention improves on the domestic statute. French law taxes any new resident arriving after five years abroad on French assets only, for five years (article 964-1°, al. 2); point 11 b of the 1989 Protocol grants Italian nationals without French nationality the same five-year exclusion of non-French assets as a treaty right — one France cannot narrow unilaterally — and renews it where the person, having ceased to be a French resident for at least three years, later returns. Drafted for the ISF, the clause is examined under the IFI on the analogous-taxes footing of article 2 §4, the reading the administration itself applies to ISF-era provisions; the domestic rule gives the same five-year result in any event. Recurring charges follow the property: taxe foncière at communal rates, the possible surtaxe on second homes in zone-tendue communes — a category that includes the marquee Riviera communes — and the annual occupancy declaration required of all owners. These rates being communal and year-specific, this brief's edition cycle re-verifies them rather than freezing them.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965, 983; 1989 convention art. 23 §1 + Protocol points 11 a, b, c, art. 24 §1 b; cost scales stated for orientation, itemised at engagement

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 Italian buyer the analysis carries one organising fact: the 1990 convention names the French property-rich company in terms, and reads through it at death.

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). The 1990 convention adds a succession counterpart: debts secured on the villa, and debts contracted for its acquisition, transformation, repair or maintenance, are deducted from its value for the duty the treaty allocates (article 10 §1), the domestic law applying instead wherever it is more favourable (article 10 §5).

What the acquisition decides for succession — and for gifts

The 1990 convention governs succession duty and gift duty alike, a reach most French succession treaties lack and one it shares, within this series, with the German and Swedish instruments. Its architecture is settled. The villa answers to French duty as the state where it stands, for estates and for gifts alike (article 5 §1); shares of a company whose assets consist principally of French immovables are treated, for France, as the immovables themselves (article 5 §3); securities follow situs rules of their own, the 1990 text assigning shares to the state where the issuing company is domiciled (article 8); and assets outside articles 5 to 8 are taxable only in the state where the deceased or donor was domiciled (article 9). The domicile state then credits the tax the situs state has levied (article 11 §1), and the situs state computes its charge at the rate its own law commands on the whole (article 11 §2).

Article 9's exclusive wording carries a consequence worth stating precisely. French law reaches, through article 750 ter 3° of the code, the worldwide receipts of an heir who has been French-domiciled for six of the ten preceding years; the 1990 convention contains no heir-residence clause, and for the estate of an Italian-domiciled person the assets article 9 reserves to Italy are taxable only there — the treaty allocation, which prevails over the domestic rule, leaves the beneficiary-side reach without purchase on those assets. For families whose heirs study or settle in France, that is one of the relationship's quiet strengths, and a reason the deed's geography deserves attention before it is signed.

Where French duty applies, the scale is that of CGI 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. The Italian scale runs at 4% in the direct line above €1,000,000 per beneficiary, so the two systems price the same transmission very differently, and the 1990 Protocol's domicile window — treaty domicile remaining Italian below five of the preceding seven years, where the intention to keep it is manifest — gives a family's first French years a considered answer at death. Before either state determines the duty, the civil law determines who inherits: both states apply EU Regulation 650/2012, so an Italian national habitually resident in France may elect Italian law for the succession as a whole — an election that exchanges one reserved-share system for another, Italian law organising its own legittima, so the compensatory mechanism French law aims at reserve-less successions has in principle no purchase here. The choice of law, the matrimonial regime carried into the purchase, and the calendar of any gifts are questions for counsel on both sides, best answered before the compromis.

The démembrement — bare ownership gifted, use retained

The structure commonly proposed alongside the loan divides ownership itself: the buyer retains the usufruct, the use of the villa and its income for life, and gifts the bare ownership to the next generation. The code values the split by age. Under the scale of CGI article 669, bare ownership represents 60% of full value where the usufructuary is between 61 and 70, and 70% between 71 and 80; the gift bears duty on that fraction alone, at today's value, and the reunification of full ownership at the usufructuary's death is not a further taxable transmission. Article 751 sets the conditions — a notarised gift, made more than three months before death, valued on the article 669 scale — and article 968 keeps the full value within the usufructuary's IFI base, so the wealth tax is unmoved. For an Italian family the treaty setting is tidier than in most relationships: the gift of the bare ownership falls within the 1990 convention, France taxes it as the situs state, and Italy's credit follows the machinery of article 11. The forced-heirship consequences of a gift to children belong with the family's counsel, alongside the choice-of-law election noted above.

Law reviewed as at 19 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; 1990 convention arts. 5, 8, 9, 10, 11 + Protocol point b; 1989 Protocol points 8 a, 11 a; EU Reg. 650/2012

IISelling as an Italian resident

France taxes first. Article 13 §1 of the 1989 convention assigns gains on French immovables to the state where they stand, and point 8 a of the Protocol extends the rule to gains on shares of property-rich companies wherever domestic law taxes them as real-estate gains — which French law does. For an Italian-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 and follow the seller's social-security affiliation — for owners within the European social-security coordination, generally at the reduced solidarity rate, verified at engagement. 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. Italy being a member state of the European Union, the accredited fiscal-representation requirement borne by third-country sellers does not arise (article 244 bis A, IV bis).

Italy then answers by the credit method. Article 24 §2 permits Italy to include the gain in its own base and requires it to deduct the French tax, within the proportion of Italian tax the gain represents. In practice the Italian charge is often narrower than the clause suggests: Italian law generally leaves private gains on real estate outside income tax once the property has been held beyond five years, so on the holding periods this coast records the French tax is frequently the only one — a point of Italian law stated at orientation and confirmed with the family's Italian advisers. The choice between selling the asset and selling the shares of a property-rich company changes the buyer pool and the deed mechanics more than the allocation, France taxing both under the texts above.

Leaving after the sale — a note on the exit tax

Families who sell and then move away from France — to Italy not least, given the regime described in section 1 — 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 reaching 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 condition 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 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1989 convention arts. 13 §1, 24 §2 + Protocol point 8 a; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A (incl. IV bis), 1609 nonies G

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; the treaty windows described above — the five-year wealth shield of the 1989 Protocol and the succession-domicile clause of the 1990 Protocol — then give the calendar of those first years a value of its own. 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; social levies apply in addition, at a rate that depends on the owner's social-security affiliation, for Italian-affiliated owners generally the reduced solidarity rate, verified at engagement. The convention assigns the income to France as the situs state, whatever the mode of exploitation (article 6 §§1 and 3); Italy, taxing its residents on their worldwide income, then credits the French tax under article 24 §2. How the income is returned on the Italian side — and how it sits within a substitute-tax election, where foreign income is covered by the forfait rather than credited — belongs with the family's Italian advisers.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A; 1989 convention arts. 6, 24 §2

4What changed

Edition 1 — baseline (July 2026). The instruments as they stand: the convention of 5 October 1989 with its Protocol and the exchanges of letters of 1998 and 2000, and the succession and gift convention of 20 December 1990 with its Protocol — neither amended since, and neither modified by the multilateral instrument, which Italy has signed but not ratified. Watch items for edition 2: Italy's deposit of its MLI ratification, which would import the principal-purpose test into the 1989 convention; the Italian substitute-tax regime, raised to €300,000 with €50,000 per family member for transfers of residence from 1 January 2026 by the 2026–2028 budget law, earlier entrants keeping their entry terms; 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 2012–2013-vintage commentary on the Italian conventions, which predates both the IFI and the Italian regime — in each case this brief follows the treaty texts. The ownership aggregates of section 2 are refreshed with each edition.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

5Questions, answered

Does an Italian 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 1989 convention makes French-situs property wealth taxable in France (art. 23 §1, with Protocol point 11 a for property-rich shares), so the IFI applies with treaty confirmation. Italy's own IVIE on foreign real estate may apply in addition, relief resting on Italian domestic rules rather than on the convention.

Does moving to France expose an Italian national's worldwide assets immediately?

Not for wealth tax, and not for the first five years. Point 11 b of the 1989 Protocol keeps assets situated outside France out of the French wealth-tax base for the five years following the move, for Italian nationals without French nationality, and the window renews after at least three years of non-residence. The 1990 convention adds its own clause at death: below five years' French domicile in the preceding seven, with a manifest intention to keep the Italian domicile, treaty domicile for succession remains Italian (1990 Protocol, point b).

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

France, as the state where the property stands (1989 convention, art. 13 §1), under CGI article 244 bis A with the ownership-duration allowances — the income-tax component extinguishing after 22 years and the social levies after 30. Italy may tax the gain as the residence state with a credit for the French charge (art. 24 §2), though Italian law generally leaves private real-estate gains untaxed after five years' holding, so the French tax is often the only one in practice.

Which country taxes the succession on a French villa?

France, as the situs state (1990 convention, art. 5 §1), and for France the treaty treats shares of a company whose assets are principally French immovables as the immovables themselves (art. 5 §3). Italy, where it also taxes, credits the French duty (art. 11 §1). Assets the convention reserves to the domicile state are taxable only there (art. 9).

Are lifetime gifts covered by the France–Italy treaty?

Yes. The 1990 convention applies to successions and gifts alike — a reach most French succession conventions lack, recorded as "S - D" in the administration's own convention list. A gift of the villa, or of its bare ownership, is taxed by France as the situs state, with Italy crediting under the machinery of article 11.

Can a French-resident heir be taxed by France on an Italian estate?

Not on the assets the convention reserves to Italy. French law reaches the worldwide receipts of an heir French-domiciled for six of the ten preceding years (CGI art. 750 ter 3°), but the 1990 convention contains no heir-residence clause, and its article 9 makes assets outside articles 5 to 8 taxable only in the state where the deceased was domiciled. The treaty allocation prevails; French-situs assets remain French-taxed under article 5.

Does Italy's flat tax for new residents affect the treaty?

The question is open. The 1989 convention excludes from treaty residence only persons taxed solely on source income (art. 4 §1); unlike the Swiss convention, which excludes its forfait residents expressly, the Italian text carries no substitute-tax clause, and the administration has published no position on the regime. Treaty relief for a forfait-taxed resident is examined at engagement; French taxation of French-situs property is unaffected either way.

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

Yes, by France first as the situs state (1989 convention, art. 6), under the minimum-rate regime of CGI article 197 A — no less than 20% and 30% — with social levies in addition. Italy taxes its residents on worldwide income and credits the French tax (art. 24 §2); how the income sits within a substitute-tax election is a question for Italian advisers.

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 19 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 19 July 2026 covered Légifrance (CGI arts. 4 B, 150 UB, 150 VC, 167 bis, 197 A, 200 B, 244 bis A, 669, 750 ter, 751, 777, 779, 784 A, 964–965, 968, 973–974, 983, 990 J, 1609 nonies G, 1649 AB — consolidated texts) and both treaty instruments in their official French presentations: the convention of 5 October 1989 with its Protocol and exchanges of letters, and the succession and gift convention of 20 December 1990 with its Protocol. The administration's commentary on the Italian conventions (BOI-INT-CVB-ITA) dates from 2012–2013 and predates the IFI as well as Italy's substitute-tax regime; where the commentary is silent, this brief follows the treaty texts and the administration's general doctrine, including its published list of conventions in force at 1 January 2026. The multilateral-instrument position is taken from the OECD's status list of 18 June 2026; Italian domestic law — the substitute tax, the IVIE, the succession scale, the legittima — 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 19 July 2026. Items flagged "at engagement" — communal rates, social-levy affiliation, the treaty position of a substitute-tax resident, the Italian return of French-taxed income, the deed-level gain base — are stated at mechanism level pending case-specific verification.

Qualification. This brief documents published law and public transaction data; it is research rather than personalised legal or tax advice, and individual circumstances — residence history, nationality, matrimonial regime, the chain of title — change outcomes. For a live transaction, this office coordinates the appropriate French counsel (avocat fiscaliste, notaire) and executes the property side.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus

Further intelligence

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

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

France–Luxembourg — the convention pair

France–Canada — the convention pair

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