France–Switzerland — 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–Switzerland conventions — 1966 in force, 1953 denounced

The relationship now rests on a single convention and on the visible absence of a second. The convention of 9 September 1966, amended by the avenants of 3 December 1969, 22 July 1997 and 27 August 2009, governs taxes on income and on fortune; it is one of the relatively few French conventions to cover wealth taxation expressly, and its article 2 §4 extends it to taxes of identical or analogous nature instituted after signature — the footing on which the IFI, successor to the ISF from 2018, is examined. The succession convention of 31 December 1953, by contrast, is gone: France denounced it by note of 17 June 2014, the denunciation was published by decree 2014-1270 of 30 October 2014, and under its own article 6 §2 the text applied for the last time to successions of persons dying before 1 January 2015. Two narrower instruments complete the frame — the accord of 30 October 1979 on gifts made for charitable purposes, and the frontier-worker accord of 11 April 1983, which concerns employment income and not the questions of this brief.

Residence does the sorting, and the convention polices its own definition. A person within the tax of both states is assigned by article 4 of the 1966 convention, whose first paragraph adopts the familiar liability-based definition. The provision peculiar to this relationship follows at paragraph 6: a person taxable in a state only on a forfait basis measured by the rental value of the residences held there is not considered a resident of that state for treaty purposes. The two administrations agreed an interpretation, published on the French side in 1972, under which a lump-sum taxpayer nonetheless keeps treaty residence where the assessment base exceeds five times the rental value of the home (or one and a half times the pension price) and does not diverge notably from the base used for the federal direct tax, covering in any event French-source income the convention privileges — the reinforced assessment Swiss practice knows as the forfait majoré. The Conseil d'État has applied the exclusion strictly, in 2021 and again in 2023, to families taxed d'après la dépense on the ordinary basis. The consequence deserves plain statement: an ordinary forfait places its holder outside the convention altogether, so France taxes French-source income and French-situs wealth under domestic law alone, without treaty mediation, and the residence attestation of article 31 §2 becomes the practical key to any treaty claim.

Nationality, for once, matters at the margin. Article 26 §1 of the convention carries an equal-treatment clause under which Swiss nationals are subject in France to no taxation other or heavier than French nationals in the same situation — the basis on which French family-situation rules extend to Swiss citizens taxed in France. The decisive questions of this brief nonetheless turn on residence and on situs, not on the passport.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1966 convention arts. 2, 4 §§1 & 6, 26, 31 §2; BOI-INT-CVB-CHE-10-10/-50; BOI-INT-CVB-CHE-20; decree 2014-1270; DB 14 B-2211 interpretation; CE n° 442790, n° 469789

2The market seen from Switzerland

Seen from Geneva or Zurich, the Riviera's €3M+ villa market concentrates on the Saint-Tropez peninsula and the western shore, with established positions further east. The peninsula remains the largest €3M+ register on the coast: 1006 qualified sales for €7,049M across 2014–2025, at a €4.9M median and a €85.5M ceiling. Cannes and its hills contributed 306 sales for €2,066M at a €4.9M median. On the eastern coast, Saint-Jean-Cap-Ferrat is the narrowest and most expensive register — 178 sales for €2,375M at a €6.5M median — while the Near-Monaco arc, which includes the Roquebrune corniche where Swiss positions also appear, recorded 358 sales for €2,758M. The past 36 months alone account for €5,089M across the four registers.

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, and Switzerland accounts for 9% of those foreign-held positions — a presence led by the Saint-Tropez peninsula at Ramatuelle and the Esterel shore at Théoule-sur-Mer, with further positions at Cannes, on the Roquebrune corniche and at Saint-Jean-Cap-Ferrat. The Swiss sample in the current study is small, and its shares are read with that caution. One structural preference is nonetheless legible: 89% of Swiss-resident positions are held in direct personal ownership, without a company in the chain — a pattern whose fiscal logic, on both the wealth and the succession side, is examined in section I bis.

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 Swiss 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 Swiss-based buyers typically retain their own advisers in addition. Where a holding structure is contemplated, it is prudent to settle the questions of section I bis before the compromis is signed, since the acquiring vehicle is difficult to change once the process is under way.

The cost of owning

CGI article 964 institutes the annual tax on real-estate wealth above €1,300,000 of taxable assets. For persons not domiciled in France the base comprises French-situs property together with the fraction of any company's shares representing French property (article 964-2°), and here the 1966 convention confirms rather than constrains: article 24 §1 assigns the wealth constituted by French immovables to France, the property-linked categories the 1997 avenant added to articles 6, 15 and 24 keep holdings that stand for the villa within the same allocation, and article 25 B has Switzerland exempt the French-taxed fortune while retaining it for the progression of its own cantonal and federal rates — on justification, for the property-linked categories, that France has actually taxed. The charge is settled rather than doubled. The statute contains one planning window of note — a person who becomes French-domiciled after five years abroad is taxed for five years on French assets only (article 964-1°, al. 2), of direct relevance to a family weighing a later move across the border in either direction.

Recurring charges follow the property. Taxe foncière runs at communal rates; for furnished secondary residences, communes in the zone tendue — a category that includes the marquee Riviera communes — may vote a surtaxe on the taxe d'habitation for second homes, and the annual occupancy declaration is required of all owners. Because these rates are communal and year-specific, this brief's edition cycle re-verifies them rather than freezing them.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 964–965; 1966 convention arts. 6, 24 §1, 25 B; BOI-INT-CVB-CHE-10-30/-40; 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 Swiss-connected buyer the succession vacuum reframes each of them: with no treaty to allocate taxing rights at death, the structure decides reporting and governance on the French side, while the Swiss side of the sums belongs with the family's Swiss advisers.

Debt against the IFI — what the code anticipates

The financing conversation runs in Geneva as it does in Monaco: a loan from the buyer's bank, secured on a pledged portfolio, so that liquidity remains invested while the debt reduces the taxable base. The mechanics are lawful and the code anticipates them. Acquisition debt owed to a bank is deductible from the IFI base under CGI article 974, while financial assets sit outside that base altogether. The boundaries are three. Loans repaying capital at term are deemed to amortise, the deduction declining pro rata over the loan's life, and by one twentieth a year where no term is fixed. Where taxable property exceeds €5M and debts exceed 60% of its value, the excess is deductible only as to half, unless the borrower shows the loan was not contracted mainly for tax. And the debt must be real — actually drawn, actually serviced, at market terms; routed through a shareholder account of an SCI it ceases to count for valuing the shares (article 973). Leverage moderates the IFI in its early years and fades by design — a calendar best examined before the compromis rather than after.

What the acquisition decides for succession

Since 1 January 2015 the allocation at death is made by French domestic law alone, and its architecture is short. Under CGI article 750 ter, the villa is within French succession duty in every configuration: where the deceased was French-domiciled, on the worldwide estate (1°); where the deceased was Swiss-domiciled, as French-situs property, held directly or indirectly through entities the family controls above one half (2°); and where an heir has been French-domiciled for at least six of the ten years preceding the transmission, on everything that heir receives, wherever situated (3°) — a clause of direct consequence for the Geneva family whose adult child has settled in Paris. The unilateral credit of article 784 A then relieves less than its reputation suggests: it operates only in the worldwide cases (1° and 3°), and only for foreign tax paid on assets situated outside France, so the French charge on the villa itself is never reduced by it. Whether the relevant canton relieves or exempts on its side is a question of cantonal law, examined with the family's Swiss advisers. Where French duty applies, the scale of CGI article 777 runs progressively to 45% in the direct line beyond €1.8M per share, after the €100,000 per-child allowance of article 779; the surviving spouse is exempt in succession. Before France determines the duty, the civil law — matrimonial regime, EU Regulation 650/2012 and its professio juris, Switzerland's position outside that Regulation, French forced heirship — determines who inherits, a question for the family's counsel as much as for its tax adviser.

Lifetime transmission stands on the same domestic footing. The 1953 convention concerned succession duty alone, and the only surviving instrument on gratuitous transfers is the 1979 accord on gifts made for charitable purposes; the family gift of a villa or of SCI shares is therefore governed by French rules in full. The démembrement examined in this line's Monaco edition works identically here, and the absence of any treaty gives it the same interest: the gift of bare ownership bears duty on the age-scale fraction of article 669 at today's value, the reunification at death is not taxed again where the conditions of article 751 are observed, and the wealth tax is unmoved, article 968 keeping the full value in the usufructuary's IFI base. The arithmetic rewards a decision taken at acquisition, since the age scale runs against delay.

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 J, 1649 AB; BOI-INT-CVB-CHE-20 §40; 1979 accord (BOI-INT-CVB-CHE-30)

IISelling as a Swiss resident

France taxes first, as situs state, and the treaty makes the computation a matter of equality. Article 15 §1 of the 1966 convention assigns gains on French immovables to France, where CGI article 244 bis A levies the non-resident charge at 19% with the standard ownership-duration allowances, under which the income-tax component extinguishes after 22 years of ownership and the social levies after 30. Article 15 §4 then requires both the gain and any withholding-type levy to be computed in the same conditions whether the seller is resident of France or of Switzerland, and the jurisprudence has given the clause practical content: the levy applied to a Swiss resident may not exceed the rate borne by a French resident (Conseil d'État, 20 November 2013, n° 361167), and a Swiss seller who meets the conditions of the code's own exemptions — notably the first-sale-of-a-dwelling exemption of article 150 U II-1° bis — may claim them on the same terms (Conseil d'État, 12 February 2020, n° 415475). Property-rich holdings do not change the analysis: the convention's property-linked clauses keep interests that stand for the villa within France's reach, and article 244 bis A reaches them under domestic law. Two practical points follow. Sellers resident outside the European Economic Area — Switzerland among them — should, above the statutory threshold, budget for accredited fiscal representation. And the social charges divide by affiliation: a seller within the Swiss social-security system, which the coordination regulation covers under the agreement on the free movement of persons, is exempt from CSG and CRDS and bears the 7.5% solidarity levy alone (CGI article 235 ter), while a seller outside the coordination rules bears the full 17.2%; affiliation is verified at engagement.

The register's own trajectory puts that machinery in proportion. Across the Saint-Tropez peninsula, the median €3M+ villa sale stood at €4.56M over 2016–2017 (57 sales) and €5.0M over 2024–2025 (232 sales). A villa acquired at the earlier median and resold at the later one, after roughly eight full years of ownership, shows no taxable gain at all: the statute raises the acquisition base by 7.5% for costs and, beyond five years of ownership, by a further 15% for works (CGI article 150 VB), and the uplifted base of €5,586,000 exceeds the €5,000,000 resale figure before any duration allowance is reached. On the median trajectory, the French capital-gains charge falls on outperformance rather than on ownership.

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 clock matters equally: a person who leaves before six years of French domicile within the preceding ten stands outside the latent-gains charge altogether, so the family that tried France for a few years and moved on typically departs untouched; gains already placed under a tax deferral follow their own rules and are reviewed at engagement. Where the machinery does apply, payment is generally deferred, and the assessment lapses automatically where the securities are still held two years after departure — five where the portfolio exceeded €2.57M — or upon a return to France. For most sellers the exit tax is therefore a question of calendar and paperwork rather than of cost; the destination-specific mechanics of the deferral for a move to Switzerland are settled at engagement.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · 1966 convention art. 15 §§1, 4; CGI arts. 150 U, 150 UB, 150 VB, 150 VC, 167 bis, 235 ter, 244 bis A, 1609 nonies G; CSS L. 136-7 I ter; CE n° 361167, n° 415475, n° 430189, n° 422780

IIIRenting — as tenant and as owner

Renting as a tenant

A rental year before purchase remains the classic first step, and for a Swiss family 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; and for a family taxed on a forfait basis in Switzerland, the treaty's residence article offers no tie-breaker shelter at all where the assessment is set on the ordinary basis. 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 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. The 1966 convention assigns the income to France as situs state (article 6), and Switzerland exempts it while preserving the progression of its own rates (article 25 B §1). Social levies apply in addition, on the affiliation logic set out in section II: the 7.5% solidarity levy for an owner within the Swiss coordination rules, the full charges otherwise. For a lump-sum taxpayer outside the convention under article 4 §6, the French position is unchanged in substance — France taxes its own source — while any Swiss-side consequence of the income belongs to the design of the forfait itself.

Law reviewed as at 19 July 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · CGI arts. 4 B, 197 A, 235 ter; 1966 convention arts. 6, 25 B

4What changed

Edition 1 — baseline (July 2026). The instruments as they stand: the convention of 9 September 1966 on income and fortune, as amended by the avenants of 3 December 1969, 22 July 1997 and 27 August 2009; the accord of 30 October 1979 on gifts for charitable purposes; the frontier-worker accord of 11 April 1983; and, on the succession side, no convention — the 1953 text having ceased to apply to deaths from 1 January 2015 following the French denunciation of 17 June 2014 (decree 2014-1270). Watch items for edition 2: any resumption of negotiations towards a new succession convention, a subject raised publicly on both sides since the denunciation; the forfait jurisprudence after the strict applications of 2021 and 2023; annual Loi de finances movements on the IFI and transfer duties; communal surtaxe votes on the Riviera arc; and the coordination framework behind the 7.5% solidarity-levy position. 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

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

France, under its domestic law alone. The France–Switzerland succession convention of 1953 was denounced by France in 2014 and has not applied to deaths since 1 January 2015. The villa is within French succession duty whatever the family's domicile (CGI art. 750 ter), and the French credit of article 784 A never relieves the French-situs property itself; any relief on the Swiss side is a matter of cantonal law.

Does a Swiss resident pay French wealth tax on a Riviera villa?

Yes, once French real-estate assets exceed €1.3M, whether held directly or through the property fraction of company shares (CGI art. 964). The 1966 convention confirms the allocation: article 24 §1 assigns the villa's wealth to France, and Switzerland exempts it with progression under article 25 B. The charge is settled by treaty, not doubled.

Is a lump-sum (forfait) taxpayer in Switzerland covered by the convention?

Not on the ordinary basis. Article 4 §6 excludes from treaty residence a person taxable in Switzerland only on an expenditure-based assessment computed from the rental value of their residences; the agreed interpretation preserves residence where the assessment is set on the reinforced basis, and the Conseil d'État applied the exclusion strictly in 2021 and 2023. The framing of the forfait therefore decides access to the treaty.

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

France, as situs state (1966 convention, art. 15 §1), under the non-resident levy of CGI article 244 bis A with the ownership-duration allowances. By article 15 §4 the computation must equal a French resident's — the rate may not exceed the resident rate, and the code's own exemptions remain open to a Swiss seller who meets their conditions. Switzerland exempts the gain with progression.

Do French social charges apply to a Swiss-resident owner?

At a reduced rate, in the usual case. An owner within the Swiss social-security system falls under the European coordination rules, is exempt from CSG and CRDS on property gains and income, and bears the 7.5% solidarity levy alone (CGI art. 235 ter); outside the coordination rules the full 17.2% applies. Affiliation is verified at engagement.

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

Yes. France taxes first under the minimum-rate regime of CGI article 197 A, at no less than 20% and 30%, with social levies on the affiliation logic above; the 1966 convention assigns the income to France (art. 6), and Switzerland exempts it while preserving its progressive rates (art. 25 B).

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.

Does a bank loan reduce French wealth tax on a Riviera villa?

Yes. Acquisition debt owed to a bank is deductible from the IFI base under CGI article 974, and pledged financial assets remain outside the tax altogether. The deduction is bounded: interest-only loans are deemed to amortise each year, and where property exceeds €5M and debt exceeds 60% of its value, the excess counts only as to half unless a mainly non-tax purpose is shown.

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 U, 150 UB, 150 VB, 150 VC, 167 bis, 197 A, 235 ter, 244 bis A, 669, 750 ter, 751, 777, 779, 784 A, 964–965, 968, 973–974, 990 J, 1609 nonies G, 1649 AB; CSS art. L. 136-7 — consolidated texts), BOFiP (BOI-INT-CVB-CHE-10 tree including the chapters on scope, capital gains, fortune, elimination and equal treatment; BOI-INT-CVB-CHE-20 on the denounced 1953 convention; BOI-INT-CVB-CHE-30; BOI-RFPI-PVINR), the decree 2014-1270 of 30 October 2014 publishing the denunciation, and the jurisprudence of the Conseil d'État (n° 361167 of 20 November 2013 as restated in the administration's commentary; n° 415475 of 12 February 2020; n° 439606 of 19 April 2021; n° 442790 of 25 June 2021; n° 469789 of 18 September 2023; n° 430189 of 20 September 2019 and n° 422780 of 1 July 2019 on the social-levy framework). The BOFiP commentary on the fortune article predates the 2014 denunciation on one point of cross-reference; the treaty texts and later chapters prevail, and this brief follows them. Swiss federal and cantonal 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-security affiliation, fiscal-representation thresholds, the cantonal succession position, the framing of a forfait — 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, the form of a Swiss assessment, 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–Germany — the convention pair

France–Belgium — the convention pair

Deutsche Ausgabe