France–United Arab Emirates — Tax Treaty

1The 1989 convention, and who counts as a UAE resident under it

A single instrument governs: the convention France and the Emirates signed at Abu Dhabi on 19 July 1989, in force since 1 July 1990, with an exchange of letters of the same day, completed by the avenant of 6 December 1993 — whose wealth-tax rules were applied retroactively to fortune held at 1 January 1989, with taxes already paid refunded. Its scope is broad by design: one text lists the income tax, the corporation tax, the wealth tax and the succession tax (article 2), and extends to identical or analogous taxes created later — which is what brings the IFI, successor to the ISF from 2018, inside the treaty. The multilateral instrument completes the consolidation, in force for France since 1 January 2019 and for the Emirates since 1 September 2019, adding the principal-purpose test: a treaty advantage can be refused where obtaining it was one of the principal objects of an arrangement.

Because the Emirates levy no personal income tax, no wealth tax and no inheritance tax, every charge this brief prices arises in France alone — and every relief the convention grants is a net saving with no home-side counterpart. That is why this convention does more work than most in this collection, and why the evidence of residence is the thing the whole position rests on.

Who counts as a UAE resident under the convention

The definition is drafted for a state without personal income tax. A French resident is defined by liability to tax in France; a UAE resident is any person domiciled or established in the Emirates (article 4 §1) — no liability test, because there is no personal income tax to be liable to. The Conseil d'État applied exactly that architecture on 20 March 2023 (n° 452718), and the same decision settles a practical point in the taxpayer's favour: the credit France grants under article 19 §1 does not depend on the income having actually borne tax in the Emirates.

For the international family established in Dubai, the practical meaning of that last pair of rows is direct: where the French home and the French school run stand, and for how long, decides more than any other single fact. Residence is proved with certificates and day counts, not asserted.

The authentic texts of the convention are French and Arabic, equally authoritative; there is no official English text, and this brief quotes the French consolidation. Emirates domestic law — the absence of the three personal taxes, the federal corporate tax on business profits since 2023, the federation's personal-status rules — is stated for orientation and belongs with your advisers there.

Sources considered: 1989 convention arts. 2, 4 §§1–2, 19 §§1–2; CE, 20 March 2023, n° 452718; CGI art. 4 B; BOI-ANNX-000306 (29 April 2026); BOI-INT-CVB-ARE (2012 vintage — the text prevails). Scope note: the treaty text prevails over the older commentary, and every date here is re-checked at each edition.

Reviewed as at 10 August 2026 · 1989 convention arts. 2, 4, 19; CE n° 452718

2What you pay to buy a property in France, and what it costs you every year

The purchase follows the standard French sequence: your offer; then the pre-sales contract (compromis de vente), with its ten-day cooling-off period and a deposit of usually 10%; then the conditions precedent. Last comes the deed itself (acte authentique), signed before the notaire, who collects the duties and registers your title. The notaire is a public officer. The law obliges him to advise both parties on the deed he draws up — what it covers, what it commits each side to, what its risks are. His duty stops at the deed: the planning around it belongs to your own advisers — and because both the article 16 A comparison and article 17's division of the estate turn on what the deed creates and what sits beside it, section 3 is best answered before you sign the pre-sales contract.

Worked example — the median Cannes villa (€4.9M, the 2014–2025 DVF median for Cannes and its hills):

These figures follow the published scales and are given for orientation; the notaire itemises the duties and fees on your actual deed. A new-build VAT regime, furniture excluded from the price, or a mortgage will change the arithmetic. The annual local property tax (taxe foncière) is set commune by commune, and communes in designated high-demand areas (zone tendue) may vote a surcharge (surtaxe) on second homes; our agency re-checks those rates at each edition rather than freezing them.

The wealth tax — and the article 16 A comparison that can displace it

Article 964 of the tax code charges an annual tax on real-estate wealth above €1,300,000; for an owner not domiciled in France it reaches French property and the property share of any company's shares (article 965, 2°). Here the convention departs from France's ordinary practice. Article 16 A §1 lets France tax the French property of a UAE-resident individual only where its value exceeds the combined value of qualifying holdings that resident keeps in France: shares of French companies listed on a regulated market (but not substantial participations), approved investment companies, and claims on the French State, its territorial authorities, public institutions and public-capital companies, or on listed French companies. The administration reads the claims limb as covering all French credit institutions — so ordinary bank deposits count — and admits, by published concession, EU-listed shares and claims on EU member states into the same computation. Shares of a company more than half of whose assets are French property count as the property itself (article 16 A §2).

The conditions are three, and each is the text's own. The comparison runs on gross values, before deduction of debts — a mortgage on the property does not improve it. The qualifying holdings must be durable: kept more than eight months in aggregate during the calendar year before the 1 January tax date (article 16 A §6 a). And the exemption is claimed, not automatic: you file the wealth return and justify the conditions (article 16 A §6 d). Where the comparison succeeds, the charge displaced at the Cannes median is about €34,690 a year on the article 977 scale — over a decade, that approaches the acquisition costs themselves. Where it fails, the IFI applies in the ordinary way. Article 16 A §5 adds a most-favoured-nation undertaking: any better wealth-tax regime France later grants a third state outside the EU and EFTA extends automatically to UAE residents — worth keeping under review as France's Gulf instruments evolve.

For the family weighing a full move to France, the statute has its own window: a person who becomes French-domiciled after five years abroad is taxed for five years on French assets only (article 964, 1°, al. 2).

Borrowing against the French property cuts the IFI — and never helps the comparison

The financing conversation runs here as elsewhere on this coast: a loan secured on a pledged portfolio, so the liquidity stays invested while the debt reduces the taxable base. The code anticipates the pattern. Bank acquisition debt is deductible from the IFI base (article 974), and financial assets sit outside that base. Three limits apply. An interest-only loan, with the capital repaid at the end, is treated as if you were repaying it in equal yearly steps, so the deductible amount shrinks year by year — and by one twentieth a year where no term is fixed. Where your French property exceeds €5M and the debt exceeds 60% of its value, only half of the excess is deductible, unless you show the loan was not taken mainly for tax. And the debt must be real: actually drawn, actually serviced, at market terms; lent to a French property-holding company (an SCI) through its shareholder account, it no longer reduces the taxable value of the shares (article 973).

One interaction is specific to this pair, and worth stating twice: the article 16 A comparison runs on gross values, so borrowing changes the IFI arithmetic without ever changing the comparison. The two mechanisms are examined together, not as alternatives — with the lender and the French tax lawyer, before the offer.

Three filings fall due every year, and two of them need a value you declare yourself

None of these depends on the convention. They fall on the owner of French property whatever their residence, and they are the part a non-resident owner most often discovers late.

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: 1989 convention art. 16 A §§1–6 (created by the 1993 avenant); CGI arts. 964 (incl. 1°, al. 2), 965, 973–974, 977, 990 D–990 F, 1418; BOI-INT-CVB-ARE (2012, ISF-era — its bank-deposit and EU-wide concessions re-verified at each edition; the treaty text's own extension to analogous later taxes is what carries the mechanism to the IFI). Scope note: costs follow the published scales and are itemised on your deed.

Reviewed as at 10 August 2026 · 1989 convention art. 16 A; CGI arts. 964–965, 973–974, 977

3Five ways to own a French property, and what follows from each

These are questions to work through with your advisers, not recommendations. One organising observation comes from the drafting itself: the 1989 text reads through companies for the wealth tax at one half (article 16 A §2), for capital gains at four fifths (article 11 §1 b) — and for succession, not at all. Article 17 contains no property-company clause; what that silence means for a given estate is a question of treaty construction for the family's counsel, and the three thresholds are worth reading together before any vehicle is chosen.

Giving your children the ownership now, and keeping the use for life (démembrement)

The structure most often proposed alongside the loan divides ownership itself. You keep the right to use the property and take its income for life (the usufruit), and your children take the ownership now (the nue-propriété). The tax code values the split by your age: under article 669, bare ownership is worth 60% of the full value when you are between 61 and 70, and 70% between 71 and 80. The gift is taxed on that fraction alone, at today's value, and when you die the two halves rejoin with no further tax — article 751's conditions observed: a notarised gift, made more than three months before death, valued on the article 669 scale. Article 968 keeps the property's full value in your own IFI base, so your wealth tax does not move. The mechanics work for a Dubai family exactly as for a French one — but with no treaty credit or shelter behind them, because the convention does not cover gifts. Whether to transmit at death inside article 17, or during life outside it, is for this relationship a genuine design choice, best priced with counsel before the deed.

What an ownership structure changes, beyond tax

An ownership structure answers seven questions. Tax is one of them, and rarely the one that matters most.

Sources considered: 1989 convention arts. 11 §1 b, 16 A §2, 17; CGI arts. 669, 751, 777, 779, 968, 973–974, 990 D, 990 J, 1649 AB. Scope note: structures are presented as questions for analysis, not recommendations, settled with counsel in France and in the Emirates.

Reviewed as at 10 August 2026 · 1989 convention arts. 11, 16 A, 17; CGI arts. 669, 968, 990 J, 1649 AB

4What you pay when you sell

France taxes first, and the convention says so with an uncommon threshold. Gains on the property itself are taxable in France as the state where it sits (article 11 §1 a). Gains on shares are taxed in France in two cases: where the company's assets are more than 80% French property — a higher bar than the one-half test France usually negotiates — provided French law taxes such gains as property gains, which article 244 bis A does (article 11 §1 b); and, whatever the asset mix, where the seller's participation exceeds one quarter of the profits of a French-resident company (article 11 §3). Other gains stay with the residence state alone (§2) — which, for a UAE resident, taxes nothing.

The French mechanics run under article 244 bis A. The taxable gain falls by 6% for each year you have owned the property beyond the fifth, and by 4% in the twenty-second year (article 150 VC); income tax at 19% (article 200 B) disappears after 22 years, while the social levies run to their own extinction after 30. An Emirates social-security affiliation is outside the European coordination, so the levies run at the full 17.2%. Gains above €50,000 also bear the surcharge of article 1609 nonies G, which reaches 6% at the prices this market transacts.

Worked example — the two clocks, per €1,000,000 of gain:

Two clocks, two schedules: the income-tax allowance runs 6% a year from the sixth year; the social allowance 1.65%, then 9% a year beyond the twenty-second. On the holding periods this coast measures — frequently two decades and more — the income-tax half has often gone while the levies remain. Your actual base is itemised on the deed, works and purchase costs included.

The representative you must appoint

The Emirates sit outside the EU and the EEA, so a seller resident there appoints a representative accredited by the French tax administration, who is answerable for the filing and the payment (article 244 bis A, IV) — the buyer, a French bank or an accredited firm may serve. Two automatic exemptions exist: sales at €150,000 or less per seller, and sales fully exempt because the property has been owned thirty years. Where a representative is needed, the notaire handling the deed normally arranges it. No Emirates-side charge follows the sale; the French assessment is the final one.

If you leave France after selling: the exit tax

France's exit tax is narrower than its name suggests. Article 167 bis aims at shares, not property: it applies to people who were French-domiciled for at least six of the ten years before leaving, and taxes the unrealised gain on shareholdings worth more than €800,000, or on stakes of 50% or more of a company's profits. A property you have already sold has paid its own tax, and the sale proceeds are outside the charge. Shares in a family SCI are treated like the property itself rather than like a share portfolio: as long as the company keeps the ordinary income-tax regime, the gain on those shares stays inside article 150 UB and outside the exit tax. A company that has opted for corporation tax changes that answer, so the option belongs on the pre-departure checklist. A family that tried France for a few years and moved on typically departs untouched — six years of domicile in the previous ten is the entry condition. Where the exit tax does apply, payment is normally deferred, and the assessment lapses after two years — five if the portfolio exceeded €2.57M — or when you return to France.

Sources considered: 1989 convention art. 11; CGI arts. 150 UB, 150 VC, 167 bis, 200 B, 244 bis A (incl. IV), 1609 nonies G; BOI-RFPI-PVINR-30-20 (22 January 2025). Scope note: the allowances follow the statutory scales, and your actual base is itemised on the deed.

Reviewed as at 10 August 2026 · 1989 convention art. 11; CGI arts. 244 bis A, 150 VC, 167 bis

5Renting before you buy, and renting your property out

Renting before you buy

A year's rental before buying is the usual first step, and for this relationship it carries a caution sharper than most. French tax residence under article 4 B of the tax code depends on where your household is, where you mainly stay, and where your professional and economic interests sit — none of which defers to a lease. Article 19 §2 of the convention then provides that a person who remains French-domiciled on those criteria is taxable in France even so, convention or no convention — and the carve-out protects UAE citizens alone. A Riviera property that becomes the family's real home can establish full French exposure well before any purchase, and the protection many treaty relationships would offer at that point is here reserved to one nationality. The choice between a furnished seasonal rental and a one-to-three-year unfurnished lease (bail civil) also changes how easily you can leave.

Renting your property out

France taxes the rental income of non-residents, furnished rentals included, at a minimum of 20% up to the second bracket and 30% above it (article 197 A of the tax code), unless you can show a lower worldwide effective rate. Social levies apply on top — at the full 17.2% for an Emirates affiliation. The convention gives the income to France as the state where the property sits, however it is rented out (article 5), and extends the same rule to enjoyment held through company shares (article 5 §4). Nothing follows on the Emirates side; the French assessment stands alone. One further provision deserves note: article 18 §3 exempts UAE residents who keep a French home for private use, without French fiscal domicile, from any income tax assessed on the dwelling's rental value — a guarantee that outlived the domestic mechanism it addressed, which France repealed in 2016.

Sources considered: 1989 convention arts. 5, 18 §3, 19 §2; CGI arts. 4 B, 197 A. Scope note: the treatment turns on the form of exploitation and on affiliation, both questions of fact.

Reviewed as at 10 August 2026 · 1989 convention arts. 5, 18 §3, 19 §2; CGI arts. 4 B, 197 A

6What happens to the property when you die, or give it away

The convention covers successions and not gifts — the tax list of article 2 names the French succession tax alone — and that asymmetry is the planning. At death, the division is short and exclusive. By lifetime gift, the picture reverses entirely.

At death: what article 17 gives each state

For a UAE-resident owner the practical answer is plain: French duty on the property, at the article 777 scale after the €100,000 per-child allowance of article 779, with the surviving spouse exempt — and no French duty on French bank accounts, portfolios or other movables, which answer to the Emirates alone. The exclusive wording of article 17 §3 also leaves no room, for movables within its scope, for the beneficiary-side rule of article 750 ter, 3°, under which France otherwise taxes a France-resident heir on worldwide inherited assets. Few French treaty relationships carry a succession article at all; this one does.

By gift, the picture reverses

A gift of the property, of SCI shares or of movables kept in France falls under article 750 ter — including its indirect-holding rule for family-controlled companies — with no treaty rule to displace it, and gift duty runs on the article 777 scale. The démembrement of section 3 illustrates the difference: mechanics that work for a Dubai family exactly as for a French one, but with no treaty behind them. Whether to transmit at death inside article 17, or during life outside it, is a genuine design choice, priced with counsel before the deed.

The civil law beneath the tax law

Before either state taxes a succession, the civil law decides who inherits. Under EU Regulation 650/2012, which France applies to every estate it handles, the law of the deceased's habitual residence governs by default, and a UAE national habitually resident in France may instead choose the law of their nationality for the whole estate (article 22). French law adds a guard of its own: where the deceased or a child is an EU national or EU-resident and the chosen law gives children no reserved share, each child may claim compensation out of the assets in France (article 913, paragraph 3 of the Civil Code). Whether a given personal-status regime amounts to such a protection is examined case by case, with the family's counsel, alongside the matrimonial regime carried into the purchase.

Sources considered: 1989 convention arts. 2, 17; CGI arts. 750 ter, 777, 779; Code civil art. 913 al. 3; EU Regulation 650/2012 art. 22. Scope note: Emirates succession practice follows the federation's personal-status rules and belongs with your advisers there; the allowances follow the statutory scales.

Reviewed as at 10 August 2026 · 1989 convention arts. 2, 17; CGI arts. 750 ter, 777, 779; Code civil art. 913 al. 3

7The eight questions UAE owners ask most

Does a Dubai-resident owner pay French wealth tax on a Riviera property?

Only where the property's gross value exceeds the qualifying French holdings the owner keeps — listed French shares, approved investment companies, claims on the French State and public bodies, bank deposits, extended by concession to EU-listed shares and public debt (article 16 A). The holdings must have been kept more than eight months of the preceding year, and the exemption is claimed on the wealth return. Where the comparison fails, the IFI applies from €1.3M in the ordinary way.

Which investments count toward the article 16 A comparison?

Shares of French companies listed on a regulated market (substantial participations excluded), approved investment companies, and claims on the French State, its public institutions and listed French companies; the administration reads the claims limb as covering all French credit institutions — so ordinary bank deposits count — and admits EU-listed shares and claims on EU member states by published concession. Values compare gross, before debts, and the eight-month permanence condition applies.

Who taxes the gain when a UAE resident sells a French property?

France alone, as the state where it sits (article 11 §1), under article 244 bis A: 19% income tax extinguishing after 22 years of ownership, social levies at the full 17.2% extinguishing after 30, and the surcharge above €50,000 of gain. The Emirates add nothing.

Which country taxes the succession of a UAE-resident owner?

The convention answers asset by asset — a feature few French treaty relationships carry. The property is taxed only in France (article 17 §1); movables, securities and deposits expressly included, only in the deceased's state of residence (article 17 §3) — so French portfolios and accounts of a UAE-resident deceased pass free of French duty, and the Emirates levy no inheritance tax.

Are lifetime gifts covered by the France–UAE convention?

No. The convention names the succession tax but not gift duty, so a gift of French assets — the property, SCI shares, French movables — falls under French domestic law alone (article 750 ter), at the ordinary scale. The choice between transmitting at death, inside the treaty, and by gift, outside it, is structural.

How does the treaty define UAE residence if the Emirates levy no income tax?

By domicile or establishment rather than by liability to tax (article 4 §1) — the Conseil d'État applied that definition in 2023 (n° 452718). Article 19 §2 adds the French reservation: a person who stays French-domiciled under French domestic law remains taxable in France even so, convention or no convention, unless a UAE citizen.

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

Yes, by France alone (article 5), at a minimum of 20% and then 30% (article 197 A), plus social levies at the full 17.2%. No home-side tax follows. Article 18 §3 separately guarantees that a UAE resident keeping a French home for private use pays no income tax on its rental value.

Does a French exit tax apply after selling and leaving?

Rarely, and never on the property itself. Article 167 bis reaches only people French-domiciled six of the ten years before leaving, and only their unrealised gains on shares — above €800,000, or stakes of 50% or more. The property you sold and its proceeds are outside it, as are family-SCI shares kept under the ordinary income-tax regime (article 150 UB).

Sources considered: 1989 convention arts. 4, 5, 11, 16 A, 17, 18 §3, 19 §2; CGI arts. 150 UB, 167 bis, 197 A, 244 bis A, 750 ter, 964; CE n° 452718. Scope note: these answers condense the sections above and inherit their scope notes.

Reviewed as at 10 August 2026

8The court decisions, the sources and the sales figures

How residence works for a state with no income tax — CE n° 452718

The Conseil d'État ruled on 20 March 2023 on precisely the architecture this brief turns on: UAE residence under article 4 §1 is a matter of domicile or establishment, not of liability to tax — there being no personal income tax to be liable to — and the credit France grants under article 19 §1 is not conditional on the income having actually borne tax in the Emirates. The decision anchors both the residence table of section 1 and the credit mechanics, and it is why this brief insists on evidence: a definition this generous is policed through its facts.

CE, 20 March 2023, n° 452718 — full decision read. Scope note: the decision construes articles 4 and 19 of the 1989 convention.

What changed, and what our agency is watching

Edition 2 — the position in August 2026. The instruments as they stand: the convention of 19 July 1989 with its exchange of letters, in force since 1 July 1990; the avenant of 6 December 1993, in force since 1 June 1995, its wealth-tax rules retroactive to 1 January 1989; and the multilateral instrument, in force for France since 1 January 2019 and for the Emirates since 1 September 2019.

The sales figures behind this brief

Seen from Dubai or Abu Dhabi, the Riviera's €3M+ villa market leads with Cannes — the Super Cannes quarter included. Across the three registers this brief measures, 1,490 villa sales of €3M and above cleared €11.5 billion over the twelve DVF years.

Source: DVF (« Demandes de Valeurs Foncières », DGFiP), villa sales ≥ €3M, 2014–2025, duplicate estate records removed — the same method as the published Riviera Intelligence pages. Register complete to 31 December 2025.

Where the owners live, in aggregate. The public record counts owners, it does not identify them. Across the 20 Riviera communes studied, the aggregates record, at this edition, no ownership position held from an address of record in the Emirates — residence follows the address on the public file, and a property held by a family whose papers still show a European address is counted there. The figures refresh with each edition, and the Emirates column will open with the first recorded positions.

Aggregates only, drawn from public sources under their re-use conditions; no individual holding is identified or published.

How this brief was checked, and its limits

Every statement of law is checked against the Chiron Legal Corpus — the research library maintained by our offshore legal-research partner — and re-checked against the official sources at each edition. The review of 10 August 2026 covered four sources.

• Légifrance — CGI arts. 4 B, 150 UB, 150 VC, 167 bis, 197 A, 200 B, 244 bis A, 669, 750 ter, 751, 777, 779, 964–965, 968, 973–974, 977, 990 D–990 J, 1418, 1609 nonies G, 1649 AB; Code civil art. 913.
• The treaty in both official French presentations — the 1989/1993 consolidation and the consolidation carrying the multilateral instrument — read in the raw text.
• The tax authority's commentary — BOI-INT-CVB-ARE (September 2012, before the IFI and the multilateral instrument; its ISF-era concessions re-verified at each edition).
• Conseil d'État n° 452718 (20 March 2023), read in full.

The authentic texts of the convention are French and Arabic, equally authoritative; there is no official English text. This brief quotes the French consolidation, and both authentic texts are held and were read — the convention and the 1993 avenant in the UN Treaty Series record (volumes 1858 and 2086), Arabic included. On one clause the two texts phrase differently what they do alike: the most-favoured-nation undertaking of article 16 A §5 names the Gulf Cooperation Council states expressly in the Arabic text, where the French speaks only of third states outside the European communities and EFTA — a Gulf state is such a third state, so the scope converges. Emirates domestic law is stated for orientation from secondary sources and never carries a legal conclusion on its own. Market data: DVF (DGFiP), villa sales ≥ €3M, duplicate estate records removed, register complete to 31 December 2025.

This brief sets out published law and public transaction data. It is research, not advice on your own situation: your residence history, nationality, matrimonial regime and chain of title all change the answer. For an actual purchase or sale, our agency brings in the French tax lawyer and the notaire you need, and handles the sale or purchase itself.

Reviewed as at 10 August 2026 · full decision read; DVF register, duplicate estate records removed

Further intelligence

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

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

France–Singapore — the convention pair

France–India — the convention pair

النسخة العربية