France–Luxembourg — 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–Luxembourg conventions — 1958 and 2018

The relationship runs today on a single instrument: the convention of 20 March 2018, approved by the law of 25 February 2019, in force since 19 August 2019 and applying from 1 January 2020, from which date the convention of 1 April 1958 ceased to have effect (article 30). It has been modified twice — by the avenant of 10 October 2019, which rewrote the elimination mechanics on the French side, and by the avenant of 7 November 2022, in force on the French side since April 2025, which raised the frontier-telework tolerance of the protocol to thirty-four days, a commuter matter noted here for completeness only. The convention was concluded in French alone, so both editions of this brief quote the same authentic text.

The 1958 story explains why the 2018 text reads as it does. The old convention assigned the income of industrial and commercial enterprises to the state of the permanent establishment, and the Conseil d'État read that assignment as extending to a Luxembourg company's French property gains: absent a French establishment, the gain "n'était pas imposable en France" (CE, plenary tax formation, 25 October 2017, n° 396954, stating the pre-2007 position). On the reading then prevailing on the Luxembourg side, the same income belonged to France under the immovable-property article — with the result, well documented in the period's practice, that a Luxembourg company could hold and sell French real estate taxed by neither state. The correction came by instalments. The avenant of 24 November 2006, in force 27 December 2007, rewrote article 3 so that the income and gains an enterprise draws from immovable property answer to the situs state, from 1 January 2008. The avenant of 5 September 2014, in force 1 February 2016 and first applied on 1 January 2017, added the missing piece: gains on shares of companies deriving more than half their value from French real estate, through any chain of entities, taxable only where the property stands. The avenant of 3 June 2009 had meanwhile brought information exchange to the OECD standard. The 2018 convention completed the sequence with the modern clauses summarised above; the residual years of the old text were policed through the abuse-of-law procedure, the Conseil d'État holding in 2017 that a treaty's benefit can be withdrawn from an interposition serving no purpose other than tax — a line of litigation whose tail was still passing through the court in 2023 and 2024.

Residence does the sorting. A person taxable in both states is assigned by the cascade of article 4 §2: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. The same article withholds treaty residence from a person — a trustee or fiduciary notably — who is only the apparent beneficiary of income enjoyed in reality by someone who could not claim residence in their own name (article 4 §5), and article 28's principal-purpose test stands behind the whole text. In practice, a family established in Luxembourg that acquires a Riviera villa keeps its treaty residence in Luxembourg; the questions this brief answers are those of a Luxembourg resident owning, letting and eventually selling French property.

The Luxembourg side keeps its own accents. Luxembourg has levied no net wealth tax on individuals since 2006, retaining one for companies; its holding companies of the SOPARFI type are fully taxable entities relieved by participation exemptions; and it taxes the successions of its own residents under its own law. This brief states Luxembourg law at orientation level only — its verified ground is the French side and the convention, and the Luxembourg reading belongs with the family's advisers in the Grand Duchy.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 2018 convention (CML consolidation incl. avenants of 10 Oct 2019 & 7 Nov 2022) arts. 1–4, 28, 30; 1958 convention (final consolidation) arts. 3–4 + entry-into-force notes; CE n° 396954 (25 Oct 2017); BOI-INT-CVB-LUX (2021/2024 vintages, current)

2The market seen from Luxembourg

Seen from Luxembourg, 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.

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. Luxembourg-resident positions account for roughly 1% of those foreign-held positions — a marginal presence, and one held in corporate rather than personal form. That scarcity is itself the finding of this edition: the Luxembourg route into French villas was an architecture of the old income convention, and the registers this study reads carry almost no present-day trace of it. Section 1 dates its dismantling; section I bis states what the current texts leave to examine.

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 a Luxembourg 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 Luxembourg buyers typically retain their own advisers in addition. Because no succession convention frames the relationship and the French code decides transmissions by 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°). For a villa held directly, the treaty position is settled rather than absent: article 21 §1 of the 2018 convention assigns French-situs property wealth to France, and the administration's commentary names the impôt sur la fortune immobilière expressly among the taxes covered. Luxembourg, which has levied no wealth tax on individuals since 2006, exempts the same wealth with progression (article 22 §2 a), so the IFI is a French cost of carry rather than a double charge. Where the villa is held through a company, the fortune article's silence on property-rich shares raises the question stated in the executive summary; it is developed in section I bis and examined at engagement, never assumed in either direction.

The statute itself contains one planning window. A person who becomes French-domiciled after five years abroad is taxed for five years on French assets only (article 964-1°, al. 2); no clause of the 2018 convention hardens that window into a treaty right, so it remains a matter of French domestic law, worth dating precisely in any relocation plan. Recurring charges follow the property: taxe foncière 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 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965; 2018 convention arts. 2, 21 §1, 22 §2 a; BOI-INT-CVB-LUX-10 (taxes covered); 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 a Luxembourg buyer the analysis carries one organising fact: for sixty years the Luxembourg company was itself the structure, and the current texts were drafted precisely so that it would no longer decide the outcome. What each route now settles, and what it leaves open, is set out below.

The article 21 question — fortune, held through a company

The point deserves to be stated precisely, because it is the only place where the old Luxembourg conversation retains a live successor. Article 21 of the 2018 convention assigns to France the wealth constituted by French immovable property (§1) and by the movable assets of a French permanent establishment (§2), and assigns "all other elements" of a Luxembourg resident's fortune to Luxembourg alone (§4). Unlike the gains article, it contains no clause treating property-rich shares as the property itself, and the administration's commentary enumerates the situs-taxable categories without adding one. French domestic law, for its part, taxes the non-resident on the fraction of any company's value representing French real estate (CGI articles 964-2° and 965-2°). How the domestic base and the treaty allocation meet for a company-held villa is therefore a genuine question of treaty reading — one on which this brief takes no position, and which is examined with counsel at engagement in the light of article 6 §2's renvoi to situs-state law, of article 28's principal-purpose test, and of the Conseil d'État's willingness, recorded at section 1, to withdraw this relationship's treaty benefits from arrangements serving no purpose but tax. What can be stated without qualification is the perimeter: the question concerns the IFI alone. Income, gains and death duties read through the company in every case.

Debt against the IFI — what the code anticipates

The financing conversation runs here 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, since 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.

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, provided the conditions of article 751 are met — a notarised gift, made more than three months before death, valued on the article 669 scale. Article 968 keeps the full value within the usufructuary's IFI base, so the wealth tax is unmoved. With no gift convention in the relationship, the transmission is a French charge on the French fraction; any Luxembourg consequence belongs with the family's advisers in the Grand Duchy, as do the forced-heirship implications of a gift to children, alongside the choice-of-law election noted below.

What the acquisition decides for succession

No succession convention exists between France and Luxembourg — the administration's own list of conventions in force marks the relationship for income and fortune alone, and the Luxembourg register of instruments carries nothing further. Transmissions therefore run on CGI article 750 ter. For a Luxembourg-domiciled owner, French assets answer to French duty (750 ter 2°), and the provision is written for indirect holdings: an immovable is deemed indirectly possessed where the deceased or donor, alone or with spouse, ascendants, descendants or siblings, holds more than half of the interposed entity through any chain of participations, whatever the number of entities interposed — and shares of unlisted foreign companies whose assets are principally French real estate are themselves French assets in proportion. The company acquired in Luxembourg accordingly moves no French death duty. An heir who has been French-domiciled for six of the ten preceding years brings worldwide receipts within French duty on the beneficiary side (750 ter 3°), the unilateral credit of article 784 A then applying to foreign tax on foreign assets; the villa itself, standing in France, generates no such credit. 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, the surviving spouse exempt in succession — and the civil law decides first: both states apply the European succession regulation (EU Reg. 650/2012), under which a Luxembourg national habitually resident in France may elect Luxembourg law for the succession as a whole, the fiscal allocation above remaining unaffected by the election. 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.

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, 784 A, 968, 973–974, 990 D–F, 990 J, 1649 AB; 2018 convention arts. 4 §5, 13 §4, 21, 28; EU Reg. 650/2012; CE n° 396954; BOI-ANNX-000306 (29 Apr 2026)

IISelling as a Luxembourg resident

France taxes first, on both routes out. Gains a Luxembourg resident draws from the sale of the villa itself are taxable in France as the situs state (2018 convention, article 13 §1); gains on shares, units or comparable interests that drew more than half their value from French real estate at any time in the 365 days before the sale follow the same allocation (article 13 §4), the property a company uses for its own business being alone carved out. For the 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, and taxable gains above €50,000 bearing in addition the progressive surcharge of article 1609 nonies G, which reaches 6% at the levels this market transacts.

Two French formalities resolve favourably for a Luxembourg seller. Sellers affiliated to a Luxembourg social-security scheme — and not charged to a French one — are exempt from CSG and CRDS on the gain and bear only the 7.5% solidarity levy (CGI art. 235 ter; CSS art. L. 136-7, I ter), the full 17.2% remaining the third-country rate. And as a resident of a member state of the European Union, the seller is dispensed from appointing an accredited fiscal representative (article 244 bis A, IV bis). Both points are verified to the seller's actual affiliation at engagement.

Luxembourg then relieves by exemption. Income and fortune that the convention makes taxable in France — the villa's gain included, and the gain on property-rich shares with it — are exempted by Luxembourg with progression, the credit method being reserved to dividends, royalties and directors' fees (article 22 §2). Whether the asset or the shares are sold, the French analysis of this section and the register of buyers change; the Luxembourg method does not. That choice is best evaluated before marketing begins rather than in the course of negotiation.

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 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. The 2018 convention adds one clause read alongside it: gains on a substantial participation — 25% or more of a company's profits — sold by a person who was a resident of the company's state within the five years before the sale remain taxable in that state (article 13 §5), so a departure does not of itself carry a French participation out of France's reach. For most sellers the exit tax is 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 · 2018 convention arts. 13 §§1, 4, 5, 22 §2; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 235 ter, 244 bis A (incl. IV bis), 1609 nonies G; CSS art. L. 136-7 I ter

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 cascade of article 4 of the convention then arbitrates, and the domestic five-year window on the wealth tax noted in section I gives the calendar of a genuine move its own value. 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, for Luxembourg-affiliated owners generally at the 7.5% solidarity rate described in section II, verified at engagement. The allocation is settled: article 6 of the convention makes income from immovable property, however exploited — direct use, letting or any other form — taxable in the state where the property stands, and extends the rule to property held through an enterprise (article 6 §4), the 1958 route staying closed. Luxembourg exempts the income with progression (article 22 §2 a); how the exemption is returned in the Grand Duchy belongs with the family's Luxembourg advisers.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A; 2018 convention arts. 6, 22 §2 a

4What changed

Edition 1 — baseline (July 2026). The instruments as they stand: the convention of 20 March 2018, in force since 19 August 2019 and applying from 1 January 2020, as modified by the avenant of 10 October 2019 (elimination mechanics; published in France 27 March 2021) and by the avenant of 7 November 2022 (the thirty-four-day telework threshold; applied by Luxembourg from 2023 and published in France on 29 April 2025 — an asymmetry of calendar, not of substance). The most recent movement on either side is administrative: Luxembourg's circular of 24 June 2026 on the thirty-four-day modalities, and, on the French side, the April 2026 refresh of the administration's list of conventions in force, which records the relationship as covering income and fortune alone. The commentary on the 2018 convention is young — the scope and income chapters date from February 2021, the elimination chapter from April 2024 — so this edition carries no text-versus-commentary caveat. The litigation tail of the 1958 text was still passing through the Conseil d'État in 2023 and 2024; those decisions adjudicate past years and make no new law for a present-day owner. Watch items for edition 2: annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; Luxembourg legislation on its own wealth and succession taxes; and any administrative position taken on the article 21 question stated in section I bis. 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 a Luxembourg resident pay French wealth tax on a Riviera villa?

Yes, once French real-estate assets exceed €1.3M (CGI art. 964). The 2018 convention assigns French-situs property wealth to France (art. 21 §1) and its commentary names the IFI expressly, while Luxembourg — without a wealth tax on individuals since 2006 — exempts the same wealth with progression, so the charge is never doubled. For company-held property, the fortune article carries no property-rich clause, and how the IFI's share-fraction base meets it is examined with counsel at engagement.

Can a Luxembourg company still hold French property out of reach of French tax?

No. The 1958 convention once left a Luxembourg company's French property gains taxable in neither state, but that architecture was dismantled in dated steps: enterprise property income and gains answer to France since 1 January 2008, sales of the property company itself since 1 January 2017, and the 2018 convention added a 365-day property-rich clause and a principal-purpose test. The Conseil d'État has, in addition, withdrawn the treaty's benefit from interpositions serving no purpose but tax (25 October 2017, n° 396954).

Who taxes the gain when a Luxembourg resident sells a French villa?

France, as the state where the property stands (2018 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. Selling the shares of a property-rich company instead changes nothing in the allocation (art. 13 §4), and Luxembourg exempts the gain with progression in either case (art. 22 §2 a).

Which country taxes the succession on a French villa owned from Luxembourg?

France, under its domestic law: no succession convention exists between the two states, so CGI article 750 ter applies to French assets of a Luxembourg-domiciled deceased. The provision deems an immovable indirectly possessed through any chain of companies where the deceased and close family hold more than half, so a holding company — Luxembourg or otherwise — moves no French death duty; the Luxembourg side of the transmission follows Luxembourg's own law.

Does a Luxembourg seller need a fiscal representative, and at what rate do social charges apply?

No representative: as an EU resident, a Luxembourg seller is dispensed by article 244 bis A, IV bis. Sellers affiliated to the Luxembourg social-security scheme are exempt from CSG and CRDS on the gain and bear the 7.5% solidarity levy in place of the full 17.2% social charges (CGI art. 235 ter; CSS art. L. 136-7, I ter).

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

Yes, by France first: article 6 of the 2018 convention makes income from immovable property taxable in the situs state, however the property is exploited. France applies the minimum-rate regime of CGI article 197 A, at no less than 20% and 30%, with social levies in addition; Luxembourg exempts the income with progression (art. 22 §2 a).

What is the 3% tax sometimes mentioned for company-held villas?

An annual tax of 3% of the property's market value (CGI art. 990 D), owed by entities in a holding chain that do not disclose their ownership. Entities seated in the European Union — Luxembourg companies included — are exempt where they declare, or undertake to declare, the property and their shareholders (art. 990 E 3°), so in practice the tax prices opacity rather than the wrapper itself.

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, 235 ter, 244 bis A incl. IV bis, 669, 750 ter, 751, 777, 779, 784 A, 964–965, 968, 973–974, 990 D, 990 E, 990 F, 990 J, 1609 nonies G, 1649 AB — consolidated texts; CSS art. L. 136-7), the treaty instruments in their official French presentations — the 2018 convention in the consolidation carrying the avenants of 10 October 2019 and 7 November 2022, and the 1958 convention in its final consolidated state, the source for the dated account of section 1 — together with the administration's commentary on the convention (BOI-INT-CVB-LUX, scope and income chapters of 23 February 2021, elimination chapter of 8 April 2024 — current for the text in force), its list of conventions in force of 29 April 2026, and the decisions of the Conseil d'État cited in these pages (25 October 2017, n° 396954; 31 March 2017, n° 389573 and 389577; 18 September 2023, n° 466868 and 466871; 26 April 2024, n° 466062). The convention's authentic text is French alone; both editions of this brief quote it directly. The Luxembourg treaty position was checked against the Luxembourg administration's own register of conventions in force, including its circular of 24 June 2026; Luxembourg domestic 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 19 July 2026. Items flagged "at engagement" — communal rates, social-levy affiliation, the article 21 reading for company-held property, 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–Spain — the convention pair

France–Italy — the convention pair