The decisions a Singapore-resident family should settle before acquiring, financing, using or transferring French residential property — from the 2015 convention, 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 2026-08-13. 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
Level 1 · The decision brief
The answers assume you are an individual, resident in Singapore 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 |
|---|---|---|---|
| Convention of 15 January 2015, signed at Singapore | In force 1 June 2016, applying in France from 1 January 2017; replaced the 1974 text as amended in 2009. French and English texts equally authoritative — our agency holds both, with the Singapore revenue authority's own synthesised English edition. | Income taxes — with the CSG and the CRDS named in the French list (article 2); property income taxed where the property stands (article 6); gains on the property and on shares of property-rich companies taxed by France (article 13 §§1 and 3); and the limitation of relief that answers the Singapore system (article 22). | Wealth tax, successions and gifts — the text reaches none of them |
| Article 22, the limitation of relief | Present since the 2015 signature and untouched since. | Where the convention would exempt French-source income or tax it at a reduced rate, and Singapore taxes that income only on what is brought into Singapore, the French relief applies only to the part brought in. Paragraph 3 switches it off where Singapore is exempting the income to avoid double taxation. | Property income and gains, which France taxes as the country the property stands in whatever Singapore does |
| The BEPS multilateral instrument | Both states signed on 7 June 2017; in force for France on 1 January 2019 and for Singapore on 1 April 2019. Effects on this convention run from 1 January 2020 for withholding taxes and from periods beginning 1 October 2019 for the rest. | It rewrote the preamble, replaced article 28 with the principal-purpose test under which a treaty advantage can be refused where obtaining it was a principal object of an arrangement, adjusted the permanent-establishment articles and added arbitration. | Article 13 — the property-rich clause was NOT rewritten, and still carries no 365-day look-back |
| Succession or gift convention | None exists and none is under negotiation — the administration's treaty list of 29 April 2026 records the relationship for income tax alone. | Nothing. Singapore ended estate duty for deaths from 15 February 2008 and charges no gift duty (orientation), so the French assessment is the only assessment at death and on a lifetime gift alike. | Any credit: CGI article 784 A operates only in the worldwide cases and only for foreign duty on assets outside France — and Singapore levies nothing to credit anyway |
| The French tax administration's commentary, BOI-INT-CVB-SGP | One chapter, vintage 7 August 2017 — before the multilateral instrument took effect on this convention. | Interpretation only, and dated on every point the multilateral instrument moved. | Where the commentary and the treaty texts diverge, this brief follows the texts |
| Question | The general position | How much it matters | Does your own file need checking? |
|---|---|---|---|
| Will you pay French wealth tax on the property? | Yes above €1.3M — the 2015 convention covers income only, so the IFI runs on French domestic law alone; Singapore has no wealth tax, so the charge arrives without a counterpart and without a credit (§ 2) | High | Usually — valuation and debt |
| What happens to the property at your death? | French duty alone, and whole: 45% in the direct line beyond €1.8M per share, family companies counted in (article 750 ter) — Singapore ended estate duty in 2008, so there is no second charge and no credit question (§ 6) | Critical | Required — will, matrimonial regime, children's residence |
| Can you give the property away during your lifetime? | France taxes the gift of the French property on its own scale; Singapore charges no gift duty — the French figure is the whole figure (§ 6) | High | Yes — the calendar and the French scales |
| Who taxes the gain when you sell? | France, where the property stands (article 13 §1; CGI article 244 bis A). Singapore does not tax capital gains at all, so nothing follows on the other side and no credit is needed (§ 4) | High | Usually — duration and works records |
| You are selling the company rather than the property | Article 13 §3 sends the gain to France where the company draws more than half its value from French property, directly or indirectly — and unlike most modern treaties it carries NO 365-day look-back, so the test is read at the sale (§ 3) | High | Yes — the balance sheet on the day, with counsel |
| Are you a treaty resident of France or of Singapore? | Article 4 §2 runs the full cascade — permanent home, centre of vital interests, habitual abode, then agreement between the two administrations — with no nationality step; a person taxed by a state only on income sourced there is not a resident of it (§ 1) | High | Depends — dual-base years |
| Does article 22 reduce what France gives you? | Only where the convention exempts French-source income or cuts its rate AND Singapore taxes it on what is brought in: then the French relief covers only that part. It does not touch property income or gains, which France taxes in any event (§ 1) | Medium | Depends — on income other than the property |
| Must you appoint a tax representative to sell? | Singapore sits outside the EU and the EEA, so as a rule yes; sales at €150,000 or less and property held past the 30-year clock are exempt — thresholds a Riviera sale rarely meets (§ 4) | Medium | Usually — the notaire arranges it |
| 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 Singapore | What applies in Singapore. No figure in this brief is final until they confirm it. |
| The accredited tax representative (représentant fiscal) — required when you sell, because Singapore is outside the EU and the EEA | Answerable to the French tax administration for declaring and paying the tax on your sale gain (article 244 bis A, IV); the notaire handling the deed normally arranges the appointment. |
| 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 11 August 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus
Level 2 · What is different for a resident of Singapore
One instrument does the treaty work of this relationship. The convention of 15 January 2015, signed at Singapore, entered into force on 1 June 2016 and applies in France from 1 January 2017; it replaced the text of 1974 as amended in 2009. Its French and English versions are equally authoritative, and our agency holds both, together with the synthesised English edition the Singapore revenue authority publishes. Article 2 covers income taxes only — on the French side the income tax, the corporation tax, the contributions on it and, by name, the CSG and the CRDS; on the Singapore side the income tax. No article anywhere in the text reaches fortune, and the administration's treaty list of 29 April 2026 records no succession or gift instrument with Singapore.
The convention has NO PROTOCOL. Articles 1 to 30, nothing annexed, no exchange of letters — checked end to end at this edition against the signed text, the administration's consolidation and the Singapore synthesised edition. That is worth stating rather than assuming: on several relationships in this collection the operative rule for a property held through a company sits in a protocol paragraph and not in the article a reader would turn to. Here it does not, and nothing is hiding behind the articles.
Singapore taxes what arises in Singapore, and taxes some foreign income only on the part brought into the country. Article 22 is the convention's own response to that. Where the convention would exempt French-source income or tax it at a reduced rate, and Singapore charges that income only on what is "remitted to or received in Singapore" rather than on the whole of it, the French relief applies only to the part so brought in. Read plainly: France gives relief on what Singapore actually taxes, not on the rest. Paragraph 3 switches the limitation off where Singapore is exempting French income for the very purpose of avoiding double taxation. And it does not touch the two things that matter most to an owner — rental income and gains on the property — because France taxes those as the country the property stands in whatever Singapore does.
Where both states claim a person, article 4 §2 runs the full cascade: permanent home, then centre of vital interests, then habitual abode, then agreement between the two administrations — with no nationality step, which several older treaties carry and this one does not. A person a state taxes only on income sourced there is not a resident of that state at all. French domestic law asks its own prior question through CGI article 4 B, on the family's foyer, the principal place of stay and the centres of professional and economic interest.
The point was tested at cassation on this relationship. A taxpayer had contributed shares of a Strasbourg company to a Singapore company in 2006, taking the rollover deferral, and the 2010 sale of the new shares ended it; the fight was whether he had a permanent home in France. The appeal court had found one from three facts: he stayed at his sister's when in France, one letter reached him at her address, and a divorce petition gave a Strasbourg address. The Conseil d'État set the ruling aside, holding that any residence a person has at their durable disposal is a permanent home, but that those elements do not establish durable disposal (CE, 29 December 2020, n° 434257). Both directions of that are useful to an owner here: a property kept available to the family is a permanent home in France; a relative's spare room and a forwarding address are not. It was decided under the former 1974 text, whose cascade the 2015 article 4 §2 restates in like terms — and residence remains an appraisal of facts, never a form.
Four reported decisions of the Conseil d'État cite a France–Singapore convention and every one of them was decided under the 1974 text. The 2015 convention has produced no reported supreme-court decision in its first decade in force. That is an observation rather than a gap: the questions this brief answers have not needed a courtroom on this pair.
Sources considered: 2015 convention (official consolidation and signed text) arts. 2, 4, 22, 29; the Singapore synthesised English edition of 19 July 2021; BOI-ANNX-000306 (29 April 2026); BOI-INT-CVB-SGP-20170807; CE n° 434257 — decision text read. Scope note: Singapore domestic law is stated at orientation level only and never carries a conclusion.
Reviewed as at 11 August 2026 · 2015 convention arts. 2, 4, 22; BOI-ANNX-000306 (29 April 2026); CE n° 434257 — decision text read
Buying is priced by French law and takes no notice of where the buyer lives. On the Cannes median of €4.9M, the transfer duties at 5.81% come to €284,526 and the notaire's scaled fee to roughly €61,250 — about €345,776 before any survey, agency or financing cost. Those duties are the largest single line of the purchase, and they are the reason the deed structure is settled before signature rather than after.
Above €1,300,000 of taxable French real-estate assets, CGI article 964 institutes the annual wealth tax; for a person not domiciled in France the base takes in property located in France and the fraction of any company's shares that stands for such property (article 965, 2°). The treaty position here is neither favourable nor unfavourable — it is missing. The 2015 convention covers income alone, so no article limits the charge, softens it or promises a credit; the Australian and Brazilian relationships sit on the same footing, while the German text of 1959, which covers fortune expressly, marks the contrast. Singapore levies no net-wealth tax, so the French charge arrives without a counterpart and rests entirely on French domestic law. The value declared each year is the owner's own detailed estimate of real market value (CGI article 973 I), which is why a dated written valuation resting on comparable sales is worth holding.
Acquisition debt owed to a bank is deductible from the wealth base under CGI article 974, while financial assets sit outside that base altogether. Three limits apply. A loan repaying capital only at term is treated as if it were being repaid gradually, the deduction declining over the loan's life — by one twentieth a year where no term is fixed. Where taxable property exceeds €5M and the debt exceeds 60% of that value, the excess counts only for half. And debt owed to the owner's own company or family is admitted only on proof that the loan is genuine and normal.
The annual local property tax (taxe foncière) follows the deed at communal rates; a surcharge can apply to furnished second homes in tension zones. Separately, CGI articles 990 D to 990 E charge 3% of market value each year on entities holding French property, with exemption routes that are a filing obligation rather than a favour: an entity that discloses its holders, or undertakes to on request, is outside the charge. A Singapore company holding a Riviera property meets this every year, and the exemption is lost by a missed filing rather than by any change in the facts.
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: CGI arts. 964, 965, 973 I, 974, 990 D–990 E; the notarial scale; DVF (the French government's transaction register). Scope note: the figures are the statutory scales applied to a median, not a quotation for a particular deed.
Reviewed as at 11 August 2026 · CGI arts. 964, 965, 973 I, 974, 990 D–990 E — texts read; DVF medians
French law prices each route on its own terms, and the convention barely enters the question. What follows is what each route does at purchase, each year, on a sale and at death.
Simplicity, and France taxes it at every stage. On a sale France taxes as the country the property stands in (article 13 §1), and Singapore charges nothing on the gain, so the French figure is the end of it. At death French duty attaches to the property and no Singapore assessment answers it.
The route most families reach for, and the one that changes least. The wealth tax reaches the property fraction of the shares in any event (article 965, 2°). On a sale of the shares, article 13 §3 sends the gain to France where the company draws more than half its value from French property, directly or indirectly. At death, CGI article 750 ter, 2° counts the holding as if it were held directly where the deceased, with spouse, ascendants, descendants or siblings, holds more than half the interests.
Article 13 §3 deserves reading on its own. It reaches shares, interests or comparable rights in a company, a trust or any other entity drawing more than half its value from French property, directly or indirectly, and excludes property the entity uses for its own business. What it does NOT carry is a look-back: most modern treaties, rewritten by the multilateral instrument, test the property share at any time in the 365 days before a sale. The multilateral instrument did not rewrite this article, so the test is read at the sale itself. Whether that helps or hurts a particular file depends on the balance sheet on the day, and it is a question for counsel rather than a planning assumption — the principal-purpose test of article 28 sits over any arrangement whose main object was the treaty advantage.
The 3% annual charge of articles 990 D to 990 E applies, with the disclosure route out. French corporation tax reaches French property income, and the shares remain within article 13 §3 on a sale. The company adds an annual filing discipline; it removes no French charge.
French law meets trusts on its own terms and does not wait for the convention. The trustee reports to the French administration under CGI article 1649 AB; assets within scope enter the settlor's taxable estate, or that of a beneficiary treated as the settlor; and the dedicated levy of article 990 J, at the top wealth-tax rate, answers a failure to declare. Article 13 §3 names trusts expressly, so a sale of trust interests drawing their value from French property is taxed by France.
Giving the bare ownership while keeping the use for life is a French civil mechanism, and the values are fixed by statute rather than negotiated: CGI article 669 sets the split by the giver's age, and article 751 answers the case where the two halves are held within one family. It is a gift, so it is taxed as one, and it belongs with a notaire before it is done.
Sources considered: 2015 convention arts. 13 §§1 and 3, 28; CGI arts. 750 ter, 965, 990 D–990 E, 990 J, 1649 AB, 669, 751 — texts read. Scope note: structures are presented for analysis, never as recommendations; whether a particular trust or company counts as an owner for French purposes is a question of fact and instrument for counsel.
Reviewed as at 11 August 2026 · 2015 convention arts. 13, 28; CGI arts. 750 ter, 965, 990 D–E, 990 J, 1649 AB, 669, 751
France taxes the gain because the property stands in France (article 13 §1), and CGI article 244 bis A charges it: 19% income tax, plus the social levies at the full 17.2%, plus the surcharge of article 1609 nonies G on the larger gains. The taxable gain falls with holding time under CGI article 150 VC — the income-tax component clearing at 22 years, the social-levy component at 30. Works and acquisition costs enter the calculation on evidence, which is the practical argument for keeping invoices from the first year of ownership.
The reduced solidarity levy of 7.5% belongs to persons affiliated to a social-security scheme within the European coordination regulation. Singapore affiliation sits outside it, as the courts have confirmed for third countries, so the full 17.2% applies. This is the single assumption most often carried into a Riviera file from a European precedent, and it is worth nearly ten points of the gain.
Because Singapore sits outside the EU and the EEA, the sale ordinarily requires an accredited tax representative (représentant fiscal) to stand behind the filing and the payment (article 244 bis A, IV). The administration's instruction of 22 January 2025 grants automatic exemptions for sales at €150,000 or less per seller and for sales wholly exempt through the thirty-year clock — thresholds a Riviera sale rarely meets. The deed's notaire ordinarily arranges the appointment.
Singapore does not tax capital gains, so no charge follows on the other side and the elimination article of the convention has nothing to eliminate. A gain that would be relieved by credit on most relationships in this collection is simply taxed once here. The machinery of article 23 stays idle for a private owner and becomes live only for a family later resident in France with Singapore-source income — where the French credit is capped at the French tax on that income.
France's exit tax (CGI article 167 bis) concerns securities and company rights held on departure by a person leaving French residence after at least six of the previous ten years. It does not reach the property itself, and it is not triggered by selling one. It is named here because it is the charge most often confused with the property tax on a move, and because the ordering of a sale and a change of residence is a question for counsel on both sides.
Sources considered: 2015 convention arts. 13 §1, 23 §2; CGI arts. 244 bis A (incl. IV), 150 VC, 200 B, 1609 nonies G, 167 bis; BOI-RFPI-PVINR-20-20 on the solidarity levy; the administration's instruction of 22 January 2025 — texts read. Scope note: the Singapore treatment is orientation only.
Reviewed as at 11 August 2026 · CGI arts. 244 bis A, 150 VC, 200 B, 1609 nonies G, 167 bis; instruction of 22 January 2025
A family often rents on the coast for a season before buying, and the two positions are not symmetrical. As a tenant of a furnished seasonal let, you are a customer: the rent carries no French tax consequence for you, the deposit and inventory are governed by the lease, and the tourist tax is collected by the landlord.
The convention assigns the income to France as the country where the property stands, whatever the form of exploitation (article 6 §§1 and 3). France taxes it under its own rules — the progressive scale with a 20% minimum rate up to the second bracket ceiling and 30% beyond, unless a lower worldwide rate is demonstrated (article 197 A) — and the social levies add their full 17.2%, Singapore affiliation lying outside the European coordination.
Singapore then answers as the country of residence, and for a private owner it ordinarily answers with nothing: a Singapore resident individual's foreign-source income is as a rule exempt there, even when brought into the country. Article 22 is worth reading here for what it does NOT do — it limits French relief to the part brought into Singapore only where the convention would have exempted or reduced the French charge, and on rental income France is taxing in full, so there is no relief for it to cut. The Singapore reading belongs with the family's advisers there.
Renting furnished is a different French regime from renting unfurnished, with its own thresholds and its own allowances, and short-term seasonal renting on the coast now sits under communal registration and quota rules that vary from one commune to the next. Cannes, Antibes and Saint-Tropez do not answer the same way. The rules bear on the yield rather than on the deed, so they are checked before a purchase made for rental return, not after.
Sources considered: 2015 convention arts. 6 §§1 and 3, 22, 23 §1; CGI art. 197 A; BOI-RFPI-PVINR-20-20 — texts read. Scope note: communal registration rules change by commune and by year, and are stated at orientation level.
Reviewed as at 11 August 2026 · 2015 convention arts. 6, 22; CGI art. 197 A
At death the answer is French, and whole. No succession convention exists between France and Singapore, and none is needed for a relief that no Singapore charge could give: Singapore ended estate duty for deaths from 15 February 2008 and charges no gift duty. French duty attaches to the property because it stands in France, whatever the owner's domicile, for estates and for lifetime gifts alike, and it reads through interposed companies — a property held through entities in which the deceased or donor, together with spouse, ascendants, descendants or siblings, holds more than half the interests is taxed as if it were held directly (CGI article 750 ter, 2°). Where the deceased was French-domiciled, or an heir has been French-resident for six of the ten years before the transmission, French duty reaches the worldwide estate instead.
The scale of CGI article 777 runs to 45% in the direct line, after the allowance of article 779 — €100,000 per child, renewing every fifteen years, which is what makes the calendar of lifetime gifts worth planning rather than improvising. Between unrelated persons the rate reaches 60%. The credit of CGI article 784 A does not help here: it operates only where France is taxing the worldwide estate, and only against foreign duty on assets outside France, so it never relieves the French property — and Singapore levies nothing to credit in any event.
French forced heirship reserves a share of the estate for the children (Code civil articles 912 and 913), and it is not displaced by a will made under a law that allows free disposal. European Regulation 650/2012 lets a person choose the law of their nationality to govern the succession, which changes who inherits and in what shares; it does not move the tax. And where the family's European connections engage it, the compensatory levy of Code civil article 913, al. 3 can restore a child's reserved share out of assets located in France — its own condition being that the deceased or a child is a national of, or resident in, an EU member state.
A gift of the property, or of its bare ownership, bears French gift duty because the property is in France, on the same scales, with the splitting values of article 669 fixed by the giver's age. Singapore charges nothing on the donee. So the French figure is again the whole figure, and the only variable worth planning is the fifteen-year calendar.
Sources considered: CGI arts. 750 ter, 777, 779, 784 A, 669, 751; Code civil arts. 912–913 (incl. 913, al. 3); EU Regulation 650/2012; BOI-ANNX-000306 (29 April 2026) — texts read. Scope note: Singapore's abolition of estate duty is stated at orientation level; civil law runs before tax law in this section.
Reviewed as at 11 August 2026 · CGI arts. 750 ter, 777, 779, 784 A; Code civil arts. 912–913; EU Reg. 650/2012
Level 3 · The questions buyers ask, and the court decisions and sales figures behind every answer above
Yes — the IFI applies once French real-estate assets pass €1.3M, held directly or through the property fraction of company shares (CGI article 964). Because the 2015 convention covers income alone, no treaty article limits or softens the charge; Singapore levies no net-wealth tax of its own, so the cost arrives without a counterpart, resting entirely on French domestic law.
France, and only France. There is no succession convention, and Singapore ended estate duty in 2008. French duty attaches to the property because it stands in France, counts family-held companies in (CGI article 750 ter), and runs to 45% in the direct line after the €100,000 allowance per child.
By France, yes — gift duty on the French property at the French scales, with the splitting mechanics of § 3 available. Singapore charges no gift duty, so nothing follows there. The fifteen-year renewal of the allowance is the whole planning question.
For most owners, nothing. It cuts French treaty relief down to the part of the income brought into Singapore, and it only operates where the convention would have exempted the income or reduced its French rate. Rental income and gains on the property are taxed by France in full, so there is no relief for it to reach.
Yes, in France, whatever the form of exploitation (article 6). The progressive scale applies with a 20% minimum rate, unless a lower worldwide rate is demonstrated (article 197 A), and the social levies add 17.2% at the full rate.
No. Article 13 §3 sends the gain to France where the company draws more than half its value from French property, directly or indirectly. What changes is the pool of buyers and the filing mechanics, not the country. Note that this clause carries no 365-day look-back — a point for counsel on the day, not a planning assumption.
As a rule yes, because Singapore is outside the EU and the EEA. Sales at €150,000 or less per seller and sales wholly exempt through the thirty-year clock are dispensed by the instruction of 22 January 2025 — thresholds a Riviera sale rarely meets. The notaire ordinarily arranges it.
Not yet. Four reported Conseil d'État decisions cite a France–Singapore convention and all four were decided under the 1974 text — on treaty residence and on how a credit is computed for a bank. The 2015 text has produced no reported supreme-court decision in its first decade in force.
Sources considered: 2015 convention arts. 6, 13, 22, 23; CGI arts. 964, 750 ter, 777, 779, 197 A, 244 bis A; the instruction of 22 January 2025 — texts read. Scope note: these answers condense the sections above and inherit their scope notes.
Reviewed as at 11 August 2026
Every legal statement in this brief was checked against the text it comes from, in the Chiron Legal Corpus, at the date on each section stamp. The convention was read end to end at this edition — both authoritative versions, French and English, plus the Singapore revenue authority's synthesised edition — and it carries no protocol.
Four reported Conseil d'État decisions cite a France–Singapore convention, all under the 1974 text. Two are worth an owner's attention. On residence, CE, 29 December 2020, n° 434257 held that any residence a person has at their durable disposal is a permanent home, while a relative's spare room and a forwarding address do not establish durable disposal — retold in § 1. On the machinery of credits, CE, 10 July 2019, n° 418108 held that interest arises where the permanent establishment that contracted the debt and bears its cost stands, the Singapore, Indian, Philippine and Thai conventions being drafted in similar terms; and CE, 10 December 2021, n° 449637 construed article 24 of the 1974 Singapore text to cap the credit at the French tax computed on the income NET of the charges incurred to earn it, even where the text does not say "net". Both are banking disputes on the former text, and neither decides anything about property income, gains or successions on this relationship. For a private owner the credit machinery stays idle; it becomes live only for a family later resident in France with Singapore-source income.
The sales figures come from DVF, the French government's register of property transactions, covering twelve years. The observatory of ownership our agency maintains records no Singapore-resident position on the coast to date: an honest absence rather than a finding, and the column opens with the first recorded position.
It states the general position on the French side and reads the Singapore side at orientation level only. It is not advice on a particular file, and it does not replace a notaire, a French tax counsel or an adviser in Singapore. Write to us directly for a file-specific reading.
Sources considered: 2015 convention (official consolidation, signed text and the Singapore synthesised edition); BOI-ANNX-000306 (29 April 2026); BOI-INT-CVB-SGP-20170807; BOI-RFPI-PVINR-20-20; CGI and Code civil articles cited in each section; CE n° 434257, n° 418108, n° 449637 — decision texts read; DVF. Scope note: where the administration's commentary predates the multilateral instrument, this brief follows the treaty texts.
Reviewed as at 11 August 2026 · CE n° 434257, n° 418108, n° 449637 — decision texts read; DVF
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Law reviewed as at 11 August 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · v5-NV
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