France–United Kingdom — Tax Treaty

1The two conventions, and who counts as a United Kingdom resident under them

Two treaties run between France and the United Kingdom, and both are live. The convention on income and capital gains was signed at London on 19 June 2008. It came into force on 18 December 2009 and applies from 1 January 2010, replacing the convention of 22 May 1968 and the four amendments made to it between 1971 and 1987. The convention on succession duty was signed at Paris on 21 June 1963, came into force on 30 June 1964 and has never been amended. France has concluded only a handful of succession treaties, and this is one of them.

The two divide the ground cleanly. The 2008 text decides who taxes the rent, the gain and the rest of your income. The 1963 text decides who taxes the estate at death. Neither touches the wealth tax, and neither touches lifetime gifts.

An anti-abuse rule agreed internationally in 2017 now sits on top of the 2008 convention. Both countries signed it on 7 June 2017; it came into force on 1 October 2018 for the United Kingdom and on 1 January 2019 for France, which ratified it by statute on 12 July 2018. It adds a principal-purpose test: either country may refuse a treaty benefit where obtaining that benefit was one of the main reasons for an arrangement. The consolidated French text marks in footnotes which of the convention's own anti-abuse paragraphs the new rule replaced. It does not reach the 1963 succession convention at all.

Who counts as a resident of the United Kingdom under the 2008 convention

Two questions decide this, and the first is geographic. Paragraph 2 of the protocol states that “United Kingdom” does not include the Channel Islands, the Isle of Man, Gibraltar, the Sovereign Base Areas in Cyprus, or any overseas country or territory with special relations with the United Kingdom. A family resident in Jersey or Guernsey is therefore outside this treaty. They are outside the 1963 convention too: its own article 2 says that « Grande-Bretagne » covers England, Wales and Scotland and does not include the Channel Islands or the Isle of Man. Neither convention reduces the French tax, so France taxes the property under its own law alone. This is the most common misreading of the pair, because the residences concerned sit inside the British Isles and use British institutions.

That position is not fixed for ever. Article 9 of the 1963 convention lets it be extended to any territory whose international relations the United Kingdom is responsible for, provided that territory levies broadly similar duties — so whether a particular territory is inside it is a question to re-ask, not to assume.

France does have an agreement with each of those four, and it reaches more than income tax

Outside both conventions is not the same as outside everything. France has an agreement with each of the four territories, each published by decree, and none of them is a double-taxation treaty. What they do is let the two tax authorities ask each other for information — and the taxes they can ask about are wider than most owners expect.

Two things follow. The first is that what is said above still holds for the property: these agreements do not relieve double taxation, so French tax on the property runs under French law alone. The Jersey pension article is the single exception, and it applies to pensions, not to property.

The second is that French wealth tax and French inheritance duty are inside the information these authorities may exchange for three of the four, and inside Gibraltar's general clause for the fourth. An owner who assumed that being outside the treaties meant being out of sight has the position backwards.

The 3% tax turns on an information clause, and all four territories have one

Article 990 E, 3° of the tax code lifts the 3% tax of section 2 from an entity whose seat is in France, in an EU member state, or in a country or territory that has concluded an administrative assistance agreement with France against tax fraud and evasion. The entity must also meet one of the conditions at a) to e), which in practice means declaring who owns it, or undertaking to disclose that on request.

That is a different test from the one most owners ask about, and it has a published answer. The French tax authority keeps an annex setting out which provisions of French law need which kind of clause, and which countries have one. Article 990 E needs an exchange-of-information clause only — not assistance with collection. On the same annex's table, every one of the four has that clause for the wealth tax and for inheritance and gift duties.

From the tax authority's annex BOI-ANNX-000508, which records the agreements in force at 1 January 2025 and replaced the older 990 E list in October 2025. Read the answer for the year in question: the annex is refreshed, and a territory's line can move.

So where the entity sits does not by itself cost you the exemption. What still has to be met is one of the a) to e) conditions — in practice, telling the French authorities who owns the entity, or undertaking to tell them when asked. That is the condition to settle before the vehicle is chosen, and it is a disclosure decision as much as a tax one.

The last column repays a second look. France can ask all five for information, but only the United Kingdom for help collecting. That difference goes to enforcement, not to liability: it changes what the French authorities can do to recover a tax, never what you owe.

For a trust, one question — whether it counts as an owner at all — decides which territory is even looked at. The Conseil d'État held in 2019 that a trust is presumed, for article 990 E 3°, to have its seat in the state or territory under whose law it was created (CE n° 426431). A Jersey-law trust is therefore measured against Jersey, wherever its trustee sits.

The second question is the ordinary one. Article 4 §1 makes you a resident of a country if you are taxed there on your worldwide income by reason of domicile, residence, place of management or place of incorporation, and it excludes anyone taxed there only on income arising in that country. Where both countries would claim you, article 4 §2 breaks the tie in a fixed order: permanent home, then centre of vital interests, then habitual abode, then nationality, then agreement between the two tax authorities. The answer matters on both sides of the Channel, because it decides which country credits the other.

Residence and domicile mean different things: the 2008 convention turns on residence, the 1963 convention on domicile

The 2008 convention asks where you are resident. The 1963 convention asks where you were domiciled when you died. You can be resident in one country and domiciled in another — that gap is what the old British non-domiciled regime was built on — so it is worth ten minutes now rather than a surprise later.

Residence, under article 4 §1 of the 2008 convention, means a country taxes you on your worldwide income because you live there, are based there, or are run from there. Domicile, under the 1963 convention, is not defined by the treaty at all: whether you were domiciled in the United Kingdom is decided by United Kingdom law, and whether in France, by French law. Each country answers for its own word.

Where both countries claim you, the two treaties then break the tie the same way, and in the same order.

So the two treaties start from different questions and finish on the same ladder. In practice that means a family with one home in each country usually lands in the same place under both — and a family whose domicile and residence genuinely diverge does not.

One thing did change, and it is on the United Kingdom side. In April 2025 the United Kingdom moved its own inheritance tax off domicile and onto long-term residence. The 1963 convention still says domicile. United Kingdom law is stated here for orientation only — what this brief verifies is the French side and the two treaty texts — but that mismatch is real, and it belongs with your United Kingdom counsel rather than in an assumption.

Sources considered: n° 426431; BOI-ANNX-000508; article 2; article 10; article 990; article 4 §2; article 4 §1. Scope note: Treaty text prevails over earlier commentary; dates are re-verified each edition. The IFI is covered by neither convention; nothing is doubled.

Reviewed as at 9 August 2026 · 2008 convention arts. 2, 4, 24, 29 + protocol ¶2; 1963 convention; BOI-INT-CVB-GBR-10/-20

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

What the purchase costs on the day of the deed

The purchase follows the ordinary French sequence: an offer, the pre-sales contract (compromis de vente) with a ten-day cooling-off period, a deposit of usually 10%, conditions precedent, and then the deed itself (acte authentique) before the notaire — the public officer who draws up the deed, collects the duties and registers your title. He owes both parties advice on the deed he draws — its reach, its effects, its risks — and none on your wider arrangements, so United Kingdom buyers keep their own advisers alongside him. Settle the questions of section 3 before the compromis is signed: the vehicle that buys is hard to change once the process is running.

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

The notaire itemises duties and fees on the actual deed. A new-build VAT regime, a furniture carve-out or mortgage security changes the arithmetic. The figures above follow the published scales and are given for orientation.

What the property costs you every year

Article 964 of the tax code charges an annual wealth tax on French real estate above €1,300,000. If you are not domiciled in France the base is your French property, plus the share of any company's shares that represents French property (article 964-2°). Neither treaty covers this tax, so no relief runs through either of them.

That sounds worse than it is, and the reason is worth stating plainly: the United Kingdom charges no wealth tax. Nothing is being taxed twice, and there is nothing for the United Kingdom to credit. The French charge is simply an annual cost of owning the property, and you should budget it as one.

There is a five-year shelter for a family that moves the other way. Anyone who becomes domiciled in France after five years abroad is taxed for five years on French assets only (article 964-1°, second paragraph). The 2008 convention carries its own version at article 29 §3, for United Kingdom nationals who are not also French nationals. That one is narrower on every count, and it was drafted for the ISF, the wealth tax the current one replaced in 2018. The code is what you would rely on.

Borrowing against the French property cuts French wealth tax and nothing in the United Kingdom

A loan secured on the property, often against a pledged portfolio, reduces the wealth-tax base while the money stays invested. The mechanics are lawful and the code expects them. Acquisition debt owed to a bank is deductible under article 974, and financial assets sit outside the base altogether. Three limits apply. A loan that repays capital only at the end is treated as if it amortised, so the deduction falls each year — by one twentieth a year where no term is fixed. Where the taxable property is worth more than €5M and the debts exceed 60% of that value, the excess counts only by half, unless you show the loan was not mainly for tax. And the debt must be real: actually drawn, actually serviced, at market terms. Routed through a shareholder account in an SCI it stops counting when the shares are valued (article 973).

The one-sidedness matters here too. Because the United Kingdom levies no wealth tax, the loan has no mirror effect in the United Kingdom — it reduces a French charge and nothing else. And a sterling borrower against a euro asset carries the currency risk himself. Settle this with the lender and the French tax lawyer (avocat fiscaliste) together, before the offer: a facility agreed on its own terms is often the wrong facility for the wealth-tax base.

Three filings fall due every year, and two of them ask for a valuation of your property

None of these depends on either treaty. 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.

Two recurring local charges complete the picture. The annual local property tax (taxe foncière) runs at rates each commune sets for itself. For a furnished second home in a designated high-demand area (zone tendue) — which includes the marquee Riviera communes — the commune may vote a surcharge on the residence tax. Both are communal and change year by year, so this brief re-verifies them each edition rather than freezing them.

Sources considered: article 964; article 29 §3; article 974; article 973; article 1418; articles 990. Scope note: Costs follow published scales and are indicative; the notaire itemises the deed. No home wealth tax, and sterling exposure on a euro asset.

Reviewed as at 9 August 2026 · CGI arts. 964–965, 973–974, 1418, 990 D–990 F

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

These are questions to work through with your advisers, not recommendations. One fact shapes all of them: the United Kingdom taxes its residents on worldwide income and gains and gives credit for French tax, so a structure rarely reduces the total bill. What it changes is who holds what, who decides, and what happens at death.

What an ownership structure changes, beyond tax

A holding vehicle answers seven questions, of which tax is one, and rarely the decisive one.

What France asks of a trust, whatever the trust deed says

The instrument most United Kingdom families already use is also the one French law addresses most directly. Where the settlor or any beneficiary is domiciled in France, or the trust holds French property, the trustee must declare the trust. The declaration covers its creation, its changes and its ending, its terms, its beneficial owners, and the value of the relevant assets at 1 January (article 1649 AB). A trustee established outside the European Union who buys French property enters the same net.

Alongside the reporting sits a levy. Article 990 J charges settlors and beneficiaries at the top wealth-tax rate on the trust's French property — unless those assets are already in a normal wealth-tax return or declared under article 1649 AB. In practice the levy is a backstop rather than a cost: a properly declared trust does not pay it, and an undeclared one does.

What the 1963 convention says about trusts is nothing. It decides who taxes each asset by where they are situated, and it says nothing about who is treated as owning them along the way. How the trust's gains, distributions and successions are characterised on each side is therefore a question for counsel in both countries, settled before the compromis rather than after.

What an ownership structure will not change

Whichever route you take, three things stay where they are. The property is French property, so French duty reaches it at death under the 1963 convention. The wealth tax reaches it directly or through the property share of the shares, and no treaty softens that. And the gain on a sale is French first, whether you sell the walls or the company that owns them.

Sources considered: article 1649 A; article 990. Scope note: Structures are questions, not recommendations, settled with counsel in France and in the United Kingdom. Business use of the house can create a permanent establishment.

Reviewed as at 9 August 2026 · CGI arts. 669, 968, 990 J, 1649 AB; 1963 convention art. 4

4What you pay when you sell

Two countries tax the sale, in a fixed order. France taxes first as the country where the property stands: article 14 §1 of the 2008 convention assigns gains on French immovable property to France, and article 244 bis A of the tax code is what actually charges a non-resident. The allowances for years of ownership apply, under which the income-tax part of the charge falls away after 22 years of ownership and the social levies after 30. The United Kingdom then taxes the same gain as your country of residence and deducts the French tax as a credit under article 24 §1.

Selling the company instead of the property does not change the answer. Article 14 §2 reaches gains on shares in companies, partnerships and trusts whose value comes mainly from French real estate, so the wrapper is taxed here too. The paragraph states one carve-out itself: shares that are regularly traded — on a regulated market in the French text, on an approved Stock Exchange in the English — sit outside it. That carve-out is for traded shares alone; a partnership or trust interest does not get it. What the choice does change is the pool of buyers and the analysis on both sides, and it is better weighed before marketing starts than during a negotiation.

The 17.2% social levies, and whether they apply to you

On top of the gain, social levies of 17.2% apply to sellers outside the European coordination on social security. Whether you are inside it turns on where you are affiliated for social security — not on your nationality, and not on where you live. That is why the answer for a United Kingdom seller has moved since Brexit, and why it is settled on the file rather than assumed. Sellers resident outside the European Economic Area should also budget, above the statutory threshold, for an accredited fiscal representative.

If you left the United Kingdom less than six years ago

One clause deserves particular attention from anyone who has moved recently. Under article 14 §6, a person who was resident in the United Kingdom at any time in the tax year of the sale, or in any of the six preceding tax years, stays within United Kingdom reach under its domestic law. Leaving does not, by itself, put the gain outside it.

The convention then does something precise about the double charge that follows. Article 24 §4 makes the country relying on the six-year clause — not the other one — responsible for removing the double taxation, as if the gain arose abroad. So a former London resident selling the property from a new home elsewhere looks first to the United Kingdom for relief, not to France.

If you leave France after selling: the exit tax

Families who sell and then move away from France sometimes ask whether an exit charge applies. It is narrower than its name suggests. France's exit tax (article 167 bis) is aimed at securities, not at property. It reaches people who were domiciled in France for at least six of the ten years before leaving. It taxes the unrealised gain on their substantial securities holdings, as those stand on the day of departure. Substantial means worth more than €800,000 in total, or a stake of 50% or more in a company's profits.

A property already sold has paid its own tax under the rules above, and the sale proceeds are not caught. Shares in a family SCI follow the property rather than the portfolio. So long as the company keeps the ordinary income-tax regime, gains on its shares stay in the property regime (article 150 UB) and outside the exit tax. France's right to tax a later sale is preserved instead by article 244 bis A. A company that has opted for corporation tax changes that classification, and the option belongs on the pre-departure checklist.

The length of your French residence matters as much. Anyone who leaves before six years of French domicile within the previous ten stands outside the exit tax altogether, so the family that tried France for a few years and moved on usually departs untouched. Where the exit tax does apply, payment is generally deferred, and the assessment lapses automatically if the securities are still held two years after departure — five where the portfolio exceeded €2.57M — or on a return to France. For most sellers the exit tax therefore affects the timing and the paperwork of a departure rather than its cost.

Sources considered: article 14 §1; article 244 bis A; article 24 §1; article 14 §6; article 167 bis; article 150 U. Scope note: Allowances follow the statutory scales; the base is itemised on the deed. SCI shares are not in the convention's enumerated category.

Reviewed as at 9 August 2026 · 2008 convention arts. 14, 24; CGI arts. 150 UB, 167 bis, 244 bis A

5Renting before you buy, and renting your property out

Renting before you buy

A year's rental before purchase is still the classic first step, and it carries one caution worth stating plainly. French tax residence under article 4 B of the tax code turns on where your home is, where you principally stay, and where your professional and economic interests sit. A lease does not protect you from any of that. A Riviera property that becomes the family's real home can make you French-resident, with worldwide consequences, well before you buy anything. Since the United Kingdom's 2025 reforms tie its own charges to years of residence, the calendar of a trial year now counts on both sides of the Channel. The choice between furnished seasonal lets and a one-to-three-year civil lease decides how easily you can leave, and should match what the trial is actually for.

Renting your property out

French rental income of a non-resident is taxed under article 197 A at a minimum rate: 20% up to the ceiling of the second bracket and 30% above it, unless you show that your worldwide effective rate is lower. Social levies apply on top, at a rate that depends on your social-security affiliation — the same post-Brexit question as on a sale, settled on the file. The 2008 convention gives the income to France as the country where the property stands (article 6), and the United Kingdom, taxing its residents on the same income, credits the French tax under article 24 §1.

Why article 29 does not reach your rent, and what it does reach

Article 29 is the clause most often raised in this pair, and it is worth reading carefully, because it is usually raised about the wrong income. Under article 29 §1, where the treaty gives income a tax advantage in one country and the other country taxes only the part of that income actually brought into it, the advantage shrinks to match. It was written for the United Kingdom's former remittance basis.

It has nothing to bite on for a Riviera property. Article 6 gives France the rent and article 14 §1 gives France the gain, both without restriction — France grants no treaty advantage on either, so there is no advantage for article 29 to cut back. The clause matters for French-source income where the treaty does reduce French tax: dividends, royalties, pensions and other income. It expressly does not apply to business profits (article 7) or to interest (article 11).

What the 2025 reforms changed is the United Kingdom side of that arithmetic, not the French side. The remittance basis they replaced was the thing article 29 was drafted around. How the new rules interact with the clause is a live question for anyone with French dividends or a French pension — and not one that affects what you pay on the property.

Sources considered: article 4 B; article 197 A; article 6; article 24 §1; article 29; article 29 §1; article 14 §1; article 7; article 11. Scope note: Treatment turns on the form of exploitation and on affiliation, both questions of fact. The relief for UK duty must be claimed within five years.

Reviewed as at 9 August 2026 · CGI arts. 4 B, 197 A; 2008 convention arts. 6, 24, 29

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

This is the section that makes the United Kingdom different from most of France's treaty partners. Where no succession treaty exists, French domestic law decides everything and the family's home country simply taxes again. Here a treaty of 21 June 1963 does the dividing first, and it has done so for six decades.

Which assets France taxes when a United Kingdom-domiciled person dies

Article 3 says that where the deceased was domiciled in either country, the situation of each asset is fixed exclusively by article 4. Article 4 then places immovable property where it stands, and rights over immovable property — mortgage debts apart — in the territory where the property lies. It adds the sentence everything else in this section depends on: whether an asset or a right has immovable character is decided by the law of the place where the property is located.

So France taxes the Riviera property at death, wherever the family was domiciled. The tax authority's own commentary sets out the rest of the list. On the death of a person domiciled in the United Kingdom, French duty is due on:

• immovables and tangible movables situated in France;
• the tangible and intangible parts of a business carried on in France — goodwill, lease rights, fittings, stock;
• shares, founders' shares and similar rights issued by capital companies and limited-liability companies with their seat in France.

It is not due on bonds issued by French companies, nor on securities of the same kind. That exclusion covers annuities and negotiable bills issued by the French State or by French public bodies.

The duty on what counts as French is then computed under ordinary French rules, on the French estate alone, but with every allowance, exemption, deduction and reduction French law provides. The commentary is explicit that the reductions for family circumstances go to heirs of French or United Kingdom nationality alike.

Two points to settle before the vehicle is chosen, not after the estate opens

The first is the French property company. An SCI is neither a capital company nor an SARL, so its shares are not in the enumerated list above. But article 4 independently puts immovable property and rights over immovable property where the property stands, and leaves the question whether a right has immovable character to the law of the place. So whether a particular SCI holding is caught turns on how it is classified, not on the list. No reported decision settles it for this convention, which is why it belongs in a conversation with counsel before the vehicle is chosen.

The second is the direction of travel. Article 5 confirms that the article 4 rules bind only the country that is not the country of domicile. A France-domiciled estate is therefore assessed under ordinary French law, with United Kingdom shares taxed under article 750 ter of the tax code — and relief comes as a credit under article 6 for the United Kingdom duty. That credit is capped at the French tax on the same assets, and article 7 requires the claim within five years of the death, or within five years of the later date on which the tax became due. Nobody applies it for you, and any refund is made without interest. A family that moves across the Channel during a long ownership can find the same property analysed under two different mechanisms, depending on where death finds them.

One boundary is absolute: lifetime gifts fall outside the 1963 convention entirely. French domestic law applies to them in full, under article 750 ter, with nothing to divide and nothing to credit.

Your children's reserved share, and what a British will can and cannot do

Before France works out the duty, French civil law works out who inherits. Children have a reserved share of the estate that a will cannot simply remove. EU Regulation 650/2012 lets you choose the law of your nationality to govern your succession, and a British national may choose it.

Choosing it does not end the matter. Since the French law of 24 August 2021 there is an exception. It applies where you, or one of your children, is a national or a resident of an EU member state and the law you chose gives children no reserved share. Each child may then claim compensation out of your French assets, the property first among them, up to what French law would have given them (article 913, third paragraph, of the Civil Code). A will built on testamentary freedom therefore meets a limit at the French border, and it is worth knowing about before the will is drafted rather than after.

Where French duty applies, the scale of article 777 runs progressively to 45% in the direct line above €1.8M per share, after the €100,000 per-child allowance of article 779.

Sources considered: article 4; article 750 ter; article 6; article 7; article 913; article 777; article 779; Regulation 650/2012. Scope note: Civil law decides who inherits before any duty is computed: matrimonial regime, will, reserved share. That question belongs with counsel in France and in the United Kingdom. A succession convention exists and settles which country taxes each asset before duty is computed.

Reviewed as at 9 August 2026 · 1963 convention arts. 3–7; CGI arts. 750 ter, 777, 779; Code civil art. 913 al. 3; EU Regulation 650/2012

7The eight questions United Kingdom buyers ask most

Does the France–United Kingdom treaty cover a Jersey or Guernsey resident?

No. Paragraph 2 of the protocol to the 2008 convention states that “United Kingdom” does not include the Channel Islands, the Isle of Man, Gibraltar, the Sovereign Base Areas in Cyprus, or any overseas country or territory with special relations with the United Kingdom. Neither convention reduces the French tax for a resident of those places, so France taxes the property under its own law alone. France does have a tax-information agreement with each of the four, reaching French wealth tax and inheritance duty. Article 990 E, 3° needs exactly that kind of clause and not a treaty, so all four keep access to the 3%-tax exemption if the entity also meets one of its a) to e) conditions (§ 1).

Which country taxes the inheritance of a French property?

France, as the country where the property stands. The succession convention of 21 June 1963 puts immovable property where it lies (article 4), whatever the family's domicile. The country of domicile then taxes on its own terms and credits the French duty (articles 6 and 7), on a claim made within five years of the death. The convention does not cover lifetime gifts, so French domestic law applies to them in full.

Does a United Kingdom resident pay French wealth tax on a Riviera property?

Yes, once French real-estate assets exceed €1.3M, whether held directly or through the property share of company shares (article 964). Neither treaty covers wealth tax, so no relief runs through them — but the United Kingdom charges no wealth tax, so the charge is never doubled.

Who taxes the gain when a United Kingdom resident sells a French property?

France first, under article 14 §1 of the 2008 convention and article 244 bis A of the tax code, with the allowances for years of ownership. The United Kingdom then taxes as country of residence and credits the French tax (article 24 §1). Shares in a company whose value comes mainly from French property are taxed the same way (article 14 §2).

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

Yes. France taxes first under article 197 A, at a minimum of 20% and 30% above the second bracket, with social levies on top; the United Kingdom taxes the same income and credits the French charge (articles 6 and 24). Article 29 does not restrict this — France grants no treaty advantage on the rent for it to cut back.

Does a trust holding a French property create French obligations?

Yes, expressly. The trustee must declare the trust — its terms, its parties and its asset values — once the settlor or a beneficiary is domiciled in France, or the trust holds French property (article 1649 AB). Article 990 J then charges a levy at the top wealth-tax rate on trusts whose French assets go undeclared. A properly declared trust does not pay it.

Am I still within United Kingdom tax on a gain after leaving?

Possibly, for six years. Article 14 §6 lets each country tax the gains of a former resident realised in the tax year of departure or in any of the six following it. Where a gain is taxable only under that clause, article 24 §4 makes the country relying on it responsible for removing the double charge.

Does a French exit tax apply after selling and leaving?

Rarely, and never on the property itself. The charge (article 167 bis) reaches only people domiciled in France for six of the ten years before departure, and only their unrealised gains on securities — above €800,000, or a stake of 50% or more of a company's profits. The sold property and its proceeds stand outside, as do family SCI shares kept under the ordinary income-tax regime (article 150 UB).

Sources considered: article 4; articles 6; article 964; article 14 §1; article 244 bis A; article 24 §1; article 14 §2; article 197 A; article 1649 A; article 24 §4; article 167 bis; article 150 U. Scope note: These answers condense the sections above and inherit their scope notes. A succession convention exists and settles which country taxes each asset before duty is computed.

Reviewed as at 9 August 2026

8The court decisions, the sources and the sales figures

When a lease on a chalet gave France the tax on a British company — CE n° 405468

One decision of the Conseil d'État on this relationship belongs in a property brief, because its facts sit closer to a private owner's than the parties did. An English company that designed and sold corporate seminars in the United Kingdom held a nine-year lease on a chalet in Haute-Savoie, where all of its courses were actually run. It filed and paid its tax in the United Kingdom and nothing in France.

The Conseil d'État held that it had a permanent establishment here: a fixed place of business at which it carried on part of its activity, through its employees and through providers acting on its instructions. France therefore taxed the profits attributable to it. The court reached that conclusion even though the appeal judges had found the French operation had no management autonomy of its own — autonomy was not the test, the fixed place of business was.

What that means for a Riviera owner is direct. A property used as a home, or let on ordinary terms, is not a business establishment. A property around which an activity is organised can be: retreats, events, corporate hospitality, a charter or concierge operation run from the property, courses or shoots hosted there. A lease, or the title, is enough of a foothold. Ask the question before the season, not after an audit.

The same decision carries a quieter comfort. The company had been charged the 80% penalty for undeclared activity, and the Conseil d'État discharged it. The treaty has an administrative-assistance clause, and the gap between the French tax sought and the United Kingdom tax already paid was small. On those facts the company had genuinely mistaken the extent of its French obligations rather than concealed anything. Good faith, evidenced by full compliance in the other country, is worth something — which is an argument for keeping the foreign filings clean, not for leaving the French ones undone.

What changed, and what our agency is watching

Edition 1, August 2026, is the baseline. The instruments as they stand: the convention of 19 June 2008 as modified by the anti-abuse instrument of 2017, and the succession convention of 21 June 1963, in force since 30 June 1964. For edition 2 our agency is watching four things:

• the United Kingdom's successive Finance Acts settling the residence-based regime that replaced the non-domiciled rules in April 2025;
• the annual French budget law, on the wealth tax and on transfer duties;
• communal surcharge votes along the Riviera;
• the case law on social levies for residents of third countries.

The ownership aggregates below refresh with each edition.

The sales figures behind this brief

Seen from London, the Riviera's €3M+ villa market divides into three registers where United Kingdom ownership has concentrated. Saint-Jean-Cap-Ferrat is the narrowest and most expensive stretch of the coast: 178 qualified sales for €2,375M across 2014–2025, at a €6.5M median and a €200.0M ceiling. Cannes and its hills contributed 306 sales for €2,066M at a €4.9M median. The Saint-Tropez peninsula remains the largest €3M+ register on the coast, at 1006 sales for €7,049M.

Source: the French government's official transaction records (DVF, DGFiP), villa sales of €3M and above, 2014–2025, each sale counted once — the same method as the published Riviera Intelligence pages. Register through 2025-12-31.

Where United Kingdom buyers concentrate, and how they hold

The figures below count owners, they do not identify them. They come from public registers read in aggregate, and no percentage here can be traced back to a person. Across 20 Riviera communes, 34% of the ownership positions studied are held from outside France, and the United Kingdom accounts for 13% of those, concentrated on Saint-Jean-Cap-Ferrat, the Cannes hills and the Saint-Tropez peninsula.

One number stands out. 100% of United Kingdom positions in the current study are held in a personal name, with no company in the chain. That is the opposite of the pattern on the same pockets for most other countries, and it reads as the trace of a decade in which the United Kingdom aimed successive charges at company-held homes. Whether holding in a personal name is still the right answer after the 2025 reforms is one of the questions section 3 puts.

Totals, never single sales. They come from the French government's official transaction records and from the public company registers, both already public. No owner is named anywhere in this brief. Residence follows the address of record, and the figures refresh with each edition.

How this brief was checked, and its limits

Method. Legal statements are verified 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 9 August 2026 covered the raw text of both conventions as published by the French tax administration (the 2008 convention consolidated with the anti-abuse instrument; the 1963 succession convention), the administration's commentary at BOI-INT-CVB-GBR-10 and -20, and Légifrance for articles 4 B, 150 UB, 167 bis, 197 A, 244 bis A, 669, 750 ter, 751, 777, 779, 913, 964–965, 968, 973–974, 990 D–990 F, 990 J, 1418 and 1649 AB of the tax code. Where the raw treaty text and a secondary summary disagreed, the text governed. United Kingdom law is stated at orientation level from secondary sources and is never load-bearing for a legal claim. Market data: the French government's official transaction records, villa sales of €3M and above, each sale counted once, register through 2025-12-31. Ownership aggregates compiled from public land and company registers, anonymised, as at 09 August 2026.

What is not settled here. Whether the shares of a French property company (SCI) fall within article 4 of the 1963 convention turns on how the holding is classified too, and no reported decision settles it for this convention. Whether article 29 §3's five-year wealth-tax shelter, written for the ISF, carries over to the tax that replaced it in 2018 has not been ruled on. Social-levy treatment for a United Kingdom seller turns on affiliation and is settled on the file. Communal rates and the fiscal-representation threshold are re-verified rather than frozen.

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, domicile, matrimonial regime, the chain of title — change outcomes. For a live transaction, our agency brings in the French tax lawyer and the notaire you need, and handles the sale or purchase itself.

Law reviewed as at 9 August 2026 — verified against Légifrance and BOFiP through the Chiron Legal Corpus · v5-NV · CE, 10e-9e ch. r., 18 October 2018, n° 405468 — decision text read in full

Further intelligence

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

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

France–Monaco — the convention pair

France–Ireland — the convention pair