The decisions a Danish, Swedish, Norwegian or Finnish resident should settle before buying, financing, using or transferring French residential property — from four separate conventions, the French tax code and the French government's official transaction records.
Written by Elena Agueeva — licensed French real-estate broker (CPI 06052023000000132), Cannes. First published 2026-07-19 · last reviewed 2026-08-14. Method: statutes and doctrine verified against Légifrance and BOFiP through the Chiron Legal Corpus; market figures from DVF (DGFiP), individually qualified. General information — personalised structuring requires your own counsel.
Editions: English · Français · Dansk · Norsk · Suomi · Svenska
Level 1 · The decision brief
The answers assume you are an individual, resident in Denmark, Sweden, Norway or Finland for the treaty and not in France, buying in your own name for private use, with no third country taxing your family. A company or a trust in the chain, a business use, or a third country changes answers — § 3 and § 6 say where.
| Instrument | Date and status | Taxes it covers | What it does not reach |
|---|---|---|---|
| Denmark — tax convention of 4 February 2022, signed at Paris | In force 29 December 2023, applying from 1 January 2024. It closed fifteen years with no treaty at all, after Denmark denounced the 1957 convention with effect from 2009. | Income taxes only. Article 2 lists French income tax, corporation tax, the contributions on it and the CSG and CRDS; article 13(5) sends gains on property-rich shares to France on a 365-day test; article 29 carries the principal-purpose test. | Wealth tax and death duty: the 2022 text has no fortune article, and no France–Denmark succession convention exists |
| Sweden — tax convention of 27 November 1990 | In force 1 April 1992. | Income and fortune. Article 2(3) names the French wealth tax; article 22 assigns French property, and the shares of a property-rich company, to France. | Deaths and gifts, which the 1994 convention below covers |
| Sweden — succession and gift convention of 8 June 1994 | In force 1 February 1996. | Successions of persons domiciled in either state, and gifts made by them (article 1). Article 5 assigns the property, and property-rich shares through any chain of companies, to France; article 9 assigns everything else to the domicile state alone. | It does not lift the French duty on French property — article 12 says who taxes what, then credits |
| Norway — tax convention of 19 December 1980 | In force 10 September 1981; amended by the avenants of 14 November 1984, 7 April 1995 and 16 September 1999. Norway left its France convention off the multilateral instrument, so the text stands as amended in 1999. | Income and fortune. Article 2(3) lists the French wealth tax; article 23(1) assigns French immovable wealth to France; article 24(2) makes Norway deduct the French wealth tax from its own. | Deaths and gifts: no France–Norway succession convention exists |
| Finland — tax convention of 11 September 1970, consolidated with the multilateral instrument | In force since 1971; the consolidation carries the BEPS preamble and the principal-purpose test. | Income and fortune. Article 22(1) assigns French immovable wealth to France; article 13(1) sends the gain to France, including shares that drew more than half their value from French property in the preceding 365 days. | Gifts. And its fortune chapter lapses when the 2023 convention enters into force |
| Finland — succession convention of 25 August 1958 | In force 2 June 1959, and still the oldest French succession convention in force. | Death duties. Article 3 taxes immovable property only where it stands; article 7 assigns everything the earlier articles do not reach to the state of the deceased’s last domicile. | Lifetime gifts, which it does not reach at all |
| Signed and not yet in force — the France–Finland convention of 4 April 2023 and the France–Sweden avenant of 22 May 2023 | French approval by law n° 2026-510 of 15 June 2026; entry into force follows the exchange of notifications. | The Finnish text is income-only and replaces the 1970 convention; the Swedish avenant adds the BEPS preamble and a principal-purpose article to the 1990 convention. | Neither changes an answer today — § 8 records what our agency is watching |
| The French tax administration's commentary — BOI-INT-CVB-DNK, -SWE, -NOR and -FIN | The Denmark pages are current at 21 May 2025; the Norway commentary dates from 2012 and predates the current French wealth tax. | Interpretation only. | Where the commentary and a treaty text disagree, this brief follows the text |
| Question | The general position | How much it matters | Does your own file need checking? |
|---|---|---|---|
| Which of the four conventions governs your file? | The one for the state you live in, and the four differ in age and in reach — Denmark’s runs from 2022, Finland’s succession text from 1958 (§ 1) | Critical | Yes — the state is the first fact, before any figure |
| Will you pay French wealth tax on the property? | Yes above €1.3M. The Danish convention says nothing about wealth, so French law applies alone; the Swedish, Norwegian and Finnish texts assign the charge to France (§ 2) | High | Usually — valuation and debt |
| Does any of the four give the French wealth tax back? | Norway does. Article 24(2) of the 1980 convention makes Norway deduct the French tax from the formuesskatt on the same property. Sweden, Denmark and Finland charge no wealth tax to deduct it from (§ 2) | High | Yes — for Norway, the deduction is claimed on the Norwegian return |
| Does holding through a company move the French charge? | No, and three of the four conventions say so: Sweden’s article 22(2), Norway’s protocol § 6 and, for the gain, Denmark’s article 13(5) and Finland’s article 13(1). Only Finland’s fortune chapter is silent (§ 3) | Critical | Yes — the balance sheet, and which state reads it |
| What happens to the property when you die? | France taxes it in all four cases. The Swedish 1994 and Finnish 1958 conventions settle that charge by treaty; for Denmark and Norway article 750 ter of the tax code does it alone (§ 6) | Critical | Yes — domicile, the heirs’ residence, and the home-state charge |
| Can you give the property away during your lifetime? | Only the Swedish convention of 1994 covers gifts. From Denmark, Norway and Finland the French gift duty applies with no convention beside it (§ 6) | High | Yes — the calendar of gifts, on both sides |
| Who taxes the gain when you sell? | France, as the state where the property stands, under the non-resident levy of article 244 bis A with the duration allowances. Denmark, Sweden and Norway then deduct the French tax from their own; Finland exempts the gain (§ 4) | High | Usually — years of ownership, works receipts |
| What do the social levies cost on a gain or on rent? | The reduced solidarity rate where you are covered by the European social-security coordination, which reaches all four states; the full rate otherwise (§ 4) | Medium | Depends — affiliation facts, verified on the file |
| Role | Responsible for |
|---|---|
| The notaire — the public officer who draws up the deed and registers your title | The title, the deed, the duties he collects, and the mechanics of inheritance. |
| The French tax lawyer (avocat fiscaliste) | The French tax position, and whether it survives an audit. |
| The adviser in Denmark, Sweden, Norway or Finland | What applies in Denmark, Sweden, Norway or Finland. No figure in this brief is final until they confirm it. |
| The lender | Assesses the buyer's ability to repay, approves and provides the financing, takes a mortgage or other security over the property, and releases the funds. |
| The valuation provider — Elena Agueeva Real Estate | Provides an independent estimate of the property's market value to support the sale negotiations, the financing decision, the values you declare for French tax, and the other requirements of the transaction. |
| The family office | The order of operations, the governance, and making both sets of advisers reach one answer. |
| Elena Agueeva Real Estate | Holds the written mandate, finds and negotiates the property, and carries the file to the notaire — and is paid only once the deed is signed. |
Law reviewed as at 10 August 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
Level 2 · What is different for a resident of Denmark, Sweden, Norway or Finland
Denmark, Sweden, Norway and Finland each have a separate tax convention with France, signed decades apart, and the differences between them decide most of what you will pay. Denmark’s convention was signed on 4 February 2022 and applies from 1 January 2024. Sweden has two: the income and fortune convention of 27 November 1990, and a succession and gift convention of 8 June 1994. Norway uses a text of 19 December 1980, amended three times. Finland has an income and fortune convention of 11 September 1970 and a succession convention of 25 August 1958. Each of the four states is its own case, and the one you live in is the first fact of your file.
| Resident of | Income and gains | Wealth tax (IFI) | Death | Lifetime gifts |
|---|---|---|---|---|
| Denmark | Convention of 4 Feb 2022 — in force 29 Dec 2023, applying from 1 Jan 2024 | No treaty cover: the 2022 text is income-only | No convention — CGI article 750 ter alone | No convention |
| Sweden | Convention of 27 Nov 1990 — in force 1 Apr 1992 | Covered: article 22 assigns French property, and property-rich shares, to France | Convention of 8 Jun 1994 — in force 1 Feb 1996 | Covered by the 1994 convention — a rarity |
| Norway | Convention of 19 Dec 1980, avenants 1984 · 1995 · 1999 | Covered: article 23 assigns it to France, and article 24(2) makes Norway credit the charge | No convention — CGI article 750 ter alone | No convention |
| Finland | Convention of 11 Sep 1970, as modified by the multilateral instrument | Covered today by the 1970 fortune chapter — which lapses with the 2023 convention | Convention of 25 Aug 1958 — in force 2 Jun 1959, still live | Not covered: the 1958 text reaches death duties only |
The Danish gap is worth its dates. Denmark denounced the convention of 8 February 1957 with effect from 1 January 2009, and for fifteen years no income-tax treaty bound the two states. French withholding applied in full to Danish residents, softened only by a published administrative doctrine refunding the excess over what a French resident would have borne — a mechanism the Conseil d’État confirmed in its decision n° 413935 of 24 October 2018. The 2022 convention closed the gap on the modern model, with the BEPS preamble, the principal-purpose article and the 365-day property-rich clause built in from the start.
Residence sorts the first question under every instrument in force. Each of the three income conventions, and both succession conventions, settles a double claim on the same cascade: permanent home, then centre of vital interests, then habitual abode, then nationality. The Swedish succession convention adds one rule of its own. Article 12(3) gives the other state a trailing right. It applies where the deceased or donor had been domiciled there for at least five of the preceding seven years and held that state’s nationality without holding both. That state may then tax the assets article 9 assigns to the domicile state, crediting the tax paid in the first. Any recent move is worth dating against it.
The multilateral instrument divides the bloc, and the division shows in the text you read. Finland listed its France convention, so the 1970 text is applied in the consolidated presentation that carries the BEPS preamble and the principal-purpose test. Norway and Sweden left theirs off. Norway’s instrument therefore stands as amended through 1999, while France and Sweden signed a bilateral avenant on 22 May 2023 to add the same preamble and article — approved on the French side by law n° 2026-510 of 15 June 2026 and awaiting entry into force. Denmark’s 2022 text was born with the clauses inside it.
What each of the four charges under its own law shapes everything below, and it is stated here at orientation level. Sweden has levied no inheritance or gift tax since 2005 and no wealth tax since 2007. Norway abolished its inheritance tax in 2014 and keeps its wealth tax, the formuesskatt — the only one of the four still charging one. Denmark levies an estate duty and Finland an inheritance tax. Iceland holds no position in the ownership study of § 8; as an EEA state it shares the social-levy and representation treatment described for Norway, and its conventions with France are outside this brief. Nordic domestic law belongs with the family’s advisers in that state.
Sources considered: Denmark convention 2022 arts. 1, 2, 4, 29; CE n° 413935 (24 Oct 2018); Sweden conventions 1990 art. 2 and 1994 arts. 1, 4, 9, 12(3); Norway convention 1980 arts. 2, 4; Finland conventions 1970 (consolidated) and 1958; Sénat rapport l17-410 for the multilateral-instrument lists. Scope note: Danish, Swedish, Norwegian and Finnish statutes are outside our agency’s verified corpus; nothing load-bearing here rests on them.
Reviewed as at 10 August 2026 · the four conventions, arts. 1–4; CE n° 413935
The purchase follows the standard French sequence: your offer; the pre-sales contract (compromis de vente), with its ten-day cooling-off period and a deposit of usually 10%; the conditions precedent; then the deed itself (acte authentique), signed before the notaire — the public officer who draws it up, collects the duties and registers your title. Nordic buyers usually keep their own advisers as well: the notaire is not the buyer’s counsel. Settle the structure questions of § 3 before the compromis, because the four conventions read a holding company four different ways.
Worked example — the median Cannes property in the DVF register (€4.9M, 2014–2025, sales of €3M and above):
| Item | Basis | Amount | Borne by |
|---|---|---|---|
| Transfer duties and land-registration taxes | ≈ 5.81% of price (standard-rate département; existing property) | €284,526 | Buyer |
| Notaire’s émoluments and disbursements | ≈ 1.1–1.4% at this price (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 on the actual deed; a new-build VAT regime, furniture carve-outs or mortgage security change the arithmetic. The figures state the published scales, for orientation.
Owning brings one French charge that matters at this level, and here the four flags separate. CGI article 964 levies the annual wealth tax (IFI) on French real-estate assets above €1,300,000 — for a non-resident, French property plus the French-property fraction of company shares (article 965). A Danish resident bears it on French law alone, because the 2022 convention covers income taxes and says nothing about wealth. A Swedish resident bears it inside a treaty: article 2(3) of the 1990 convention names the French wealth tax and article 22 assigns French property to France. A Finnish resident is inside the 1970 convention as well, though by a different route — that text is twelve years older than the first French wealth tax, so article 2(3) names no such tax and the charge arrives through the analogous-taxes clause of article 2(4).
Norway is the exception worth planning around. Article 2(3) of the 1980 convention lists the French wealth tax by name, article 23(1) assigns French immovable wealth to France, and article 23(1)(b) requires France to allow mortgage debt on that property on the same terms as for a French resident. Then article 24(2) does the thing no other Nordic instrument does: on the tax Norway charges on that resident’s wealth, Norway allows a deduction equal to the French wealth tax paid on the same elements, capped at the Norwegian tax attributable to them. Norway still levies its formuesskatt, so the deduction is real money rather than a dormant clause. Sweden, Denmark and Finland charge no wealth tax for a French charge to be set against.
One French planning window is open to all four flags, and it is the statute’s rather than any treaty’s. A person who becomes French-domiciled after five years abroad is taxed for the next five years on French assets only (article 964-1°, second paragraph). No Nordic convention hardens that window into a treaty right, so it stands or falls on French domestic law, and the date of arrival is worth recording at the time rather than reconstructing later.
Two recurring local charges follow the property. The annual local property tax (taxe foncière) runs at communal rates. For furnished second homes, communes in designated high-demand areas (zone tendue) — including the marquee Riviera communes — may vote a surcharge (surtaxe) on the residence tax, and every owner files the annual occupancy declaration. These rates are communal and year-specific, so this brief re-verifies them at each edition.
Borrowing against the property belongs to the structure decision. A debt is deductible from the wealth-tax base only where actually incurred for the taxable asset; in-house and non-amortising arrangements are capped or reconstructed on a notional amortisation (CGI arts. 973–974). Where taxable property exceeds €5M and debts exceed 60% of its value, the excess is deductible only as to half unless you show the loan was not contracted mainly for tax. For a Norwegian owner the deduction runs twice: the French base falls, and the French tax that Norway credits under article 24(2) falls with it. Settle the facility with the lender and your French tax lawyer (avocat fiscaliste) before the offer.
Sources considered: CGI arts. 964, 965, 968, 973–974; Sweden 1990 convention arts. 2(3), 22; Norway 1980 convention arts. 2(3), 23(1), 24(2); Finland 1970 convention arts. 2(1), 2(4), 22(1). Scope note: the Norwegian deduction is read verbatim from article 24(2), which runs subject to Norway’s own foreign-tax-credit rules; the Norwegian return belongs with advisers in Norway.
Reviewed as at 10 August 2026 · CGI arts. 964–965, 973–974; NO 1980 arts. 23, 24(2); SE 1990 art. 22; FI 1970 art. 22
One question organises the structure decision on this pair, and the four conventions answer it four ways: does a company between you and the property move the French charge? For the wealth tax, Sweden’s article 22(2) taxes shares of a property-rich company where the property sits, leaving out property the company trades from. Norway’s protocol § 6 does the same for article 23, on one condition — that French law taxes such shares as it taxes immovable property, which it does. Denmark has no fortune article at all, so French law applies alone. And Finland’s article 22(4) assigns every other element of wealth to the residence state, with no property-rich paragraph anywhere in the chapter.
What follows is a map of questions for counsel, not a route.
| Route | What it offers | What it means for a Nordic owner |
|---|---|---|
| Direct ownership | Simplicity; taxed where the property stands, at every stage | The IFI applies above €1.3M on all four files; the gain on a sale is taxed in France; at death France taxes the property in all four cases, by treaty for Sweden and Finland and under article 750 ter for Denmark and Norway |
| A company in your own state | Confidentiality, consolidation | For a Swedish or Norwegian owner the shares stay inside the French wealth charge; for a Danish owner French law reaches them; for a Finnish owner the fortune chapter is silent and the question is genuinely open. The annual 3% tax and its filings apply throughout (CGI arts. 990 D–990 E; an EU or EEA entity is exempt on filing) |
| French SCI — a French property-holding company | Governance, co-ownership, French financing | The same French readings, plus one divergence at death: the Swedish convention treats its shares as the property itself through any chain of companies (article 5(3)), while the Finnish text of 1958 has no such rule and sends them to the deceased’s domicile (article 7) |
| A company that trades from the property | The carve-out written into three of the four texts | Sweden’s articles 13(2) and 22(2) and Norway’s protocol § 5 a leave out property the company uses for its own industrial, commercial, agricultural or professional activity. It requires a real activity carried on from the property, documented before it is relied on |
| Splitting use from ownership (usufruct / bare ownership) | Lifetime transmission at reduced values | Identical on the French side (CGI arts. 669, 751, 968). The treaty side splits: a Swedish donor stays inside the 1994 convention, while a Danish, Norwegian or Finnish donor makes a gift no convention divides between the two states |
The Finnish silence deserves its own line, because it is the one place where the four flags produce a genuinely open question rather than four different answers. Article 22 of the 1970 convention assigns immovable property to the state where it stands and then, at paragraph 4, assigns all other elements of a resident’s wealth to the residence state alone. It contains no paragraph on shares of a property-rich company. Whether the French wealth tax reaches the French-property fraction of an SCI held by a Finnish resident is therefore argued from the general articles rather than settled by a specific one, and our agency states it as a question and verifies it on the file rather than asserting an answer.
Our agency prepares a free valuation for owners at valuation.elenaagueeva.com. An agent contacts you within 48 hours to arrange a visit.
It rests on the same official records a French property valuer (expert immobilier) works from: the government's register of recorded sale prices, the cadastre, and the planning permits granted on the parcel. The agent then visits to appraise the view, the garden, and the quality of the construction and the finishes. The valuation report (avis de valeur) is produced within 48 hours of the visit.
The same figure carries your French filings. Wealth tax, the 3% company tax and gift duty are all declared at the property's market value. The law takes that value from your own detailed estimate (articles 761 and 973 of the tax code), and asks no particular valuer to produce it. A court-appointed expert (expert judiciaire) belongs to litigation, not to a declaration. If the administration challenges your figure, a dated, written valuation resting on comparable sales is what supports it.
The first valuation of a property is free for its owner or seller. A repeat valuation of the same property, or one commissioned by a family office, a bank or another adviser for a client, is a billable engagement — ask us for terms.
Sources considered: Sweden 1990 convention arts. 13(2), 22(2); Sweden 1994 convention art. 5(3); Norway 1980 protocol §§ 5 a, 6; Finland 1970 convention art. 22(4); Finland 1958 convention art. 7; CGI arts. 669, 751, 968, 990 D–990 E. Scope note: the trading-use carve-out turns on what the company actually does, a question of fact settled on the file, and the Finnish wealth question is open on the text.
Reviewed as at 10 August 2026 · SE 1990 arts. 13(2), 22(2); NO protocol §§ 5, 6; FI 1970 art. 22(4)
France taxes first, and all four instruments in force say so. Gains on the property itself go to the state where it stands under each text. Gains on the shares of a property-rich company follow by two different drafting routes: the Danish convention (article 13(5)) and the Finnish consolidation (article 13(1)) carry the modern 365-day clause, reaching shares — and interests in partnerships and trusts — that drew more than half their value from French property at any moment in the 365 days before the sale; the Swedish convention (article 13(2)) and the Norwegian protocol (§ 5 a) assign such gains to France on the condition that French law taxes them as real-estate gains, which it does.
For every Nordic seller the French charge then runs under CGI article 244 bis A: the taxable gain falls by 6% for each year of ownership beyond the fifth and 4% for the twenty-second (art. 150 VC); the income-tax component applies at 19% (art. 200 B) and ends after 22 years; the social levies end after 30 and follow your affiliation. Gains above €50,000 bear the surcharge of article 1609 nonies G, reaching 6% at the levels this market transacts.
Worked example — the duration clock, per €1,000,000 of gross gain on a property sold at the Cannes median of €4.9M:
| Ownership | Allowance (150 VC) | Taxable gain | Income tax at 19% | Surcharge (1609 nonies G) |
|---|---|---|---|---|
| 10 full years | 30% | €700,000 | €133,000 | €42,000 |
| 15 full years | 60% | €400,000 | €76,000 | €24,000 |
| 22 full years | 100% | — | — | — |
Two French formalities land the same way for all four flags, and one of them reaches Norway by an EEA route worth naming. Sellers covered by a Danish, Swedish, Finnish or Norwegian social-security scheme, and not charged to a French one, pay no CSG or CRDS on the gain and bear the 7.5% solidarity levy alone (CGI art. 235 ter; CSS art. L. 136-7, I ter), because the coordination regulation the exemption refers to covers the European Economic Area as well as the Union; 17.2% remains the third-country rate. And none of the four needs an accredited fiscal representative: the dispensation of article 244 bis A, IV bis covers EU sellers and, among EEA states, those bound to France by assistance and recovery conventions — the administration names Iceland and Norway, and excludes Liechtenstein.
Then the four states relieve differently, and the difference is money rather than paperwork. Denmark deducts the French tax from its own on the same income (2022 convention, article 22(1)); Sweden does the same (1990 convention, article 23(2)); Norway likewise, for income and for wealth (article 24(2)). Finland instead leaves the French income out of its base altogether and keeps the right to tax the rest at the rate the whole would have borne (1970 convention, article 23(2)). A deduction is capped by the home state’s own tax on that income and shrinks if its rates fall; leaving the income out removes it. The same French assessment therefore ends at a different final cost depending on which of the four states you return to.
Families who sell and then leave France sometimes ask about the exit tax. CGI article 167 bis reaches only people French-domiciled for six of the ten years before departure, and only their unrealised gains on securities — holdings above €800,000, or stakes of 50% or more. A property already sold has settled its own tax, and the proceeds are outside the charge; shares of a family SCI on the ordinary income-tax regime stay in the real-estate regime (art. 150 UB) and outside it.
Sources considered: 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; Denmark 2022 convention arts. 13(5), 22(1); Sweden 1990 convention arts. 13(2), 23(2); Norway 1980 protocol § 5 a and convention art. 24(2); Finland 1970 convention arts. 13(1), 23(2); BOI-RFPI-PVINR-30-20 (22 Jan 2025). Scope note: how each state returns the deduction or the exemption belongs with advisers in that state.
Reviewed as at 10 August 2026 · CGI arts. 150 VC, 244 bis A; DK art. 13(5); SE art. 13(2); NO protocol § 5 a; FI art. 13(1)
A rental year before purchase remains the classic first step, with one caution: French tax residence under CGI article 4 B turns on the household (foyer), the principal place of stay and the centres of professional and economic interests — none of which defers to a lease. A property that becomes the family’s effective home can establish French residence, with worldwide consequences, well before any purchase. The tie-breakers of the four conventions then arbitrate on the cascade of § 1, and for a Swedish family the five-of-seven-years clause of the 1994 convention gives the same calendar a second reading.
Renting the property out reverses the flow, and here the four conventions agree. French-source rental income of non-residents — furnished rentals included — is taxed under the minimum-rate regime of CGI article 197 A: no less than 20% up to the second-bracket ceiling and 30% above it, unless you demonstrate a lower worldwide effective rate. Social levies apply in addition, at the rate your affiliation commands. All four texts assign income from immovable property to the state where the property stands (article 6 of each), and the home state then relieves by its own method — Denmark, Sweden and Norway by deducting the French tax, Finland by leaving the income out of its base and taxing the rest at the rate the whole would have borne.
Sources considered: CGI arts. 4 B, 197 A; article 6 of the Denmark 2022, Sweden 1990, Norway 1980 and Finland 1970 texts; Finland 1970 convention art. 23(2). Scope note: treatment turns on the form of exploitation and on affiliation, both questions of fact.
Reviewed as at 10 August 2026 · CGI arts. 4 B, 197 A; art. 6 of the four conventions
This is where the bloc splits hardest. France taxes the property at death in all four cases, as the state where it stands. What differs is whether a convention says so, and what the other state does next. Sweden and France concluded a succession and gift convention on 8 June 1994, in force since 1 February 1996. France and Finland run on a succession convention of 25 August 1958, the oldest still in force. Denmark and Norway have none, so those successions are settled on CGI article 750 ter alone.
The Swedish convention is the most complete instrument on this pair. Article 1 covers successions of persons domiciled in either state and gifts made by them — a reach most French succession treaties lack. Article 5(1) assigns immovable property to the state where it stands, and article 5(3) treats shares in a company whose assets are principally immovables as the immovable itself, reading through however many companies are stacked in between. Article 9 assigns everything the earlier articles do not reach to the domicile state alone. Article 12 then makes the domicile state tax the whole estate and credit the tax paid in the other. Sweden has levied no inheritance or gift tax since 2005, so today the split runs and Sweden collects nothing: French duty on the property applies in full, and the portfolio assets article 9 assigns to Sweden pass untaxed.
The Finnish convention of 1958 divides differently, and its age is the reason. Article 3 taxes immovable property only in the state where it stands. Article 7 assigns everything articles 3 to 6 do not reach to the state of the deceased’s last domicile. A text of that vintage was written before property-rich clauses existed and contains none, so where a Finnish family holds the property through a company, the shares are not converted into immovable property by anything in that convention and follow the deceased’s Finnish domicile instead. Finland taxes them under its own inheritance tax. That does not remove a charge; it changes which state collects it, and it is the kind of split that reads as an opportunity from one side and as an exposure from the other. The convention reaches death duties only: a lifetime gift from Finland falls outside it.
For Denmark and Norway there is no convention to consult, and the consequences are precise. CGI article 750 ter 2° brings assets located in France into French duty whether they are held directly or through a company. Where an heir has been French-domiciled for six of the ten preceding years, article 750 ter 3° brings that heir’s worldwide receipts into charge, relieved by the unilateral credit of article 784 A. That credit is confined to foreign tax on assets situated outside France, so it never reaches the French property itself. Denmark levies its estate duty and Norway abolished its inheritance tax in 2014 — so a Danish family faces two charges with no treaty between them, while a Norwegian family faces the French one alone.
On the French side the scale is CGI article 777: progressive to 45% in the direct line above €1.8M per share, after the €100,000 per-child allowance of article 779, with the surviving spouse exempt in succession. Lifetime gifts follow the same scale, valued under article 669 where use and ownership are split. Only the Swedish file has a convention dividing the gift between the two states; from Denmark, Norway and Finland the French duty applies with the home-state charge answered separately by the family’s advisers there.
Before either state computes a duty, the civil law decides who inherits. For a succession opened in France the courts apply EU Regulation 650/2012, under which a national of another state habitually resident in France may elect the law of nationality for the succession as a whole. Denmark stands outside that regulation and Norway outside the Union, so how the election is received differs by state. The election, 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.
Sources considered: Sweden 1994 convention arts. 1, 5(1), 5(3), 9, 12; Finland 1958 convention arts. 3, 7; CGI arts. 669, 750 ter, 751, 777, 779, 784 A, 968; EU Regulation 650/2012. Scope note: the absence of a property-rich clause in the 1958 text is a reading of that text and not a ruling — no reported French decision construes it on company shares; Danish, Finnish, Norwegian and Swedish domestic succession law is stated at orientation level only.
Reviewed as at 10 August 2026 · SE 1994 arts. 1, 5, 9, 12; FI 1958 arts. 3, 7; CGI arts. 750 ter, 777, 784 A
Level 3 · The questions buyers ask, and the court decisions and sales figures behind every answer above
Yes, once French real-estate assets exceed €1.3M (CGI art. 964). The setting differs by state: the Danish convention of 2022 is income-only, so the charge rests on French law alone, while the Swedish, Norwegian and Finnish texts assign it to France by treaty. Norway alone deducts the French tax from its own wealth tax (1980 convention, art. 24(2)).
Yes, since recently: the convention of 4 February 2022, in force 29 December 2023 and applying from 1 January 2024. It ended fifteen years without a treaty, which followed Denmark’s denunciation of the 1957 convention. It covers income taxes only, and no France–Denmark succession convention exists.
France, in all four cases, as the state where the property stands — under the 1994 convention for Sweden, the 1958 convention for Finland, and CGI article 750 ter alone for Denmark and Norway. What each state charges differs: Sweden and Norway levy no inheritance tax, while Denmark and Finland charge under their own law.
Not on the property. The 1994 convention still assigns French property, and property-rich shares, to France, so French succession duty applies in full; what Sweden abolished in 2005 is its own side of the split. The portfolio assets article 9 assigns to Sweden do pass untaxed.
France, as the state where the property stands, under CGI article 244 bis A with the duration allowances — the income-tax component ending after 22 years and the social levies after 30. Denmark, Sweden and Norway then deduct the French tax from their own; Finland leaves the gain out of its base.
No. The dispensation of article 244 bis A, IV bis covers sellers resident in the EU — Denmark, Sweden and Finland — and, among EEA states, those bound to France by assistance and recovery conventions, which the administration confirms for Norway and Iceland. Sellers covered by a Nordic social-security scheme also bear the 7.5% solidarity levy in place of the full 17.2%.
Yes, by France first: all four conventions assign income from immovable property to the state where it stands (article 6), and France applies the minimum-rate regime of CGI article 197 A — no less than 20%, 30% above the second-bracket ceiling — with social levies in addition. Denmark, Sweden and Norway relieve by deduction; Finland by leaving the income out of its base.
Rarely, and never on the property itself. CGI article 167 bis reaches only people French-domiciled for six of the ten years before departure, and only their unrealised gains on securities — above €800,000, or stakes of 50% or more. The sold property and its proceeds stand outside, as do family-SCI shares kept on the ordinary income-tax regime (art. 150 UB).
Sources considered: the sections above; these answers condense them and inherit their scope notes.
Reviewed as at 10 August 2026 · condensed from §§ 1–6
Edition 2 baseline, August 2026. The instruments stand as § 1 records them. One calendar item leads the file: law n° 2026-510 of 15 June 2026 authorised French approval of both the France–Finland convention signed 4 April 2023 — an income-only text that replaces the 1970 convention and retires with it the fortune chapter that gives a Finnish resident’s wealth tax its treaty frame — and the France–Sweden avenant of 22 May 2023, which adds the BEPS preamble and a principal-purpose article to the 1990 convention. Neither is in force; entry follows the exchange of notifications, and the next edition will record the decrees and effective dates. Further watch items: annual Loi de finances movements on the wealth tax and transfer duties; communal surcharge votes on the Riviera arc; Nordic legislation on wealth and death taxation; and the commentary vintages, since the Norway pages date from 2012 and predate the current French wealth tax.
Seen from the Nordic capitals, the Riviera’s €3M+ villa market leads with Cannes. Cannes and its hills — the Super Cannes quarter on the Vallauris side included, with the Théoule shore immediately west — contributed 306 qualified sales for €2,066M across 2014–2025, at a €4.9M median and a €46.5M ceiling. The Saint-Tropez peninsula remains the largest €3M+ register on the coast at 1,006 sales for €7,049M, while Saint-Jean-Cap-Ferrat is the 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.
| Market | Sales (12 yrs) | Total €M | Median €M | Ceiling €M | 36-mo sales | 36-mo €M | ≥€10M (36-mo) |
|---|---|---|---|---|---|---|---|
| Cannes & its hills | 306 | 2,066 | 4.9 | 46.5 | 98 | 697 | 16 |
| Saint-Tropez & the Gulf | 1,006 | 7,049 | 4.9 | 85.5 | 353 | 2,718 | 68 |
| Saint-Jean-Cap-Ferrat | 178 | 2,375 | 6.5 | 200.0 | 53 | 555 | 19 |
Source: DVF (« Demandes de Valeurs Foncières », the French government’s official record of property transactions, published by the tax administration), villa sales ≥ €3M, 2014–2025, each sale counted once — the same method as the published Riviera Intelligence pages. Register through 2025-12-31.
The public record describes how the Riviera is held, and this brief reads it in aggregate: the state’s transaction register alongside the public company registers, all of it already published, anonymised in processing, with no individual holding identified. Across 20 Riviera communes, 34% of the ownership positions studied are held from outside France, and the four Nordic flags together account for 14% of those — a bloc of the same order as the largest single European residences. Within it, Norway and Sweden each represent 47% of Nordic-held positions and Denmark the remainder; no Finland-resident and no Iceland-resident position appears in the current study. The concentration is sharp: Cannes and its hills, the Vallauris side included, with the Théoule shore just west, carry nearly all of it. And 94% of Nordic-resident positions are held in direct personal ownership, without a company in the chain — a directness § 6 reads against four very different succession regimes.
Legal statements are verified against the Chiron Legal Corpus — the research library maintained by our legal-research partner — and re-checked against the official sources at each edition. The review of 10 August 2026 read all seven Nordic instruments in their official French presentations: the Denmark convention of 2022, the Sweden conventions of 1990 and 1994 with the avenant of 22 May 2023 (signed, not in force), the Norway convention of 1980 consolidated through the 1999 avenant with its protocol, and the Finland texts of 1970 (in the consolidation carrying the multilateral instrument) and 1958 — together with the consolidated CGI articles cited section by section, the administration’s commentary and the Conseil d’État’s decision n° 413935 of 24 October 2018 on the Danish interval. Where the commentary predates an instrument or the current wealth tax, this brief follows the treaty text. Nordic domestic law is stated at orientation level from secondary sources and is never load-bearing. Market data: DVF, villa sales ≥ €3M, each sale counted once, register through 2025-12-31. Ownership aggregates: compiled from public land and company registers, anonymised. Items flagged “when our agency takes the file” — communal rates, social-levy affiliation, the Finnish reading of company shares, the deed-level gain base — are stated at mechanism level pending case-specific verification.
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, our agency coordinates the French counsel the file needs (avocat fiscaliste, notaire) and executes the property side.
Sources considered: the review record above; the DVF register. Scope note: where this section and a numbered section differ, the numbered section governs.
Reviewed as at 10 August 2026 · full review record above
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© 2026 Elena Agueeva · Riviera Intelligence · Published for reference: quotation with attribution and a link to elenaagueeva.com is permitted; wholesale reproduction is not.
Law reviewed as at 10 August 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · v5-NV
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