Buying a French Riviera villa as a non-resident: the taxes that apply at purchase, during ownership and on sale, and the France–Monaco residency question — set out from the official sources, every figure referenced.
EN / FR
elenaagueeva.com › Riviera Intelligence › Riviera Property Tax & the Monaco Question
Buying a French Riviera villa as a non-resident triggers a specific, predictable set of French taxes — at acquisition, during ownership, and on sale — and, for anyone weighing Monaco, a residency question governed by a 1963 treaty. This dossier sets out the framework from the official sources: the Code général des impôts (CGI) and the Bulletin officiel des finances publiques (BOFiP), every article referenced. It is general information, not personalised tax advice. Your actual position depends on your nationality, your tax residence and how you hold the property — confirm it with a notaire or an avocat fiscaliste before you act. Elena Agueeva works alongside a network of Riviera notaires and tax counsel and can make an introduction.
On an existing (non-new-build) property, the buyer pays droits de mutation à titre onéreux — a registration duty / taxe de publicité foncière whose departmental rate is fixed under the CGI (art. 683, referring to the rate of art. 1594 D), plus a departmental additional levy (art. 1595) and a communal share. In the Alpes-Maritimes and the Var these combine to roughly 5.8% of the price, collected by the notaire on top of the notaire's own regulated fee. The exact departmental rate is set locally, so confirm the current figure for the commune.
Source: Code général des impôts, art. 682, 683, 1594 A/D and 1595 (Légifrance)
A person not tax-resident in France who owns French real estate worth more than €1,300,000 net — held directly, or through a company to the extent of its real-estate value — is liable to the impôt sur la fortune immobilière (IFI), an annual tax on net real-estate wealth (progressive from 0.5% to 1.5% across the brackets above the threshold). Local taxe foncière (annual property tax) applies separately, set by the commune.
Source: Code général des impôts, art. 964 and 965 (Légifrance)
A legal entity — an SCI, an offshore company, a trust or comparable institution — that owns French real estate owes an annual tax of 3% of the property's market value (CGI art. 990 D). The tax is avoidable: entities based in France, the EU, or a state with an administrative-assistance treaty are exempt if they file an annual return disclosing their owners and holdings (art. 990 E–F). Buying through an opaque structure without meeting those conditions turns on a 3%-per-year charge — one of the most common and costly mistakes in cross-border Riviera purchases.
Source: CGI art. 990 D, 990 E, 990 F; Conseil d'État, 9 May 2019, n° 426431 (Légifrance)
Article 990 D reaches the entity, not the individual: any company, organisation, fiducie or comparable institution owning French property — or rights over it — owes 3% of market value, every year. Not 3% of the gain, not of the rent: of the value. Crucially, it applies where the property is held through interposed entities, and the article states expressly that this holds however many entities sit in the chain. Stacking a holding company above a holding company does not break the link — it only lengthens it.
Source: Code général des impôts, arts. 990 D, 990 E and 990 F (Légifrance), verified against the Chiron Legal Corpus.
Almost nobody actually pays this tax, because article 990 E exempts: sovereign states and international organisations; entities whose French real estate is less than 50% of their French assets; entities listed on a regulated market; and — the route that matters for a family structure — entities based in France, in the EU, or in a state bound to France by an administrative-assistance treaty, provided they either declare annually or give a formal undertaking to disclose on request: the property's situation, composition and value, plus the identity and address of every holder of more than 1% of the shares. A de minimis also applies where the French property share is under €100,000 or 5% of its value. The exemption is bought with transparency, not with structure.
Source: Code général des impôts, arts. 990 D, 990 E and 990 F (Légifrance), verified against the Chiron Legal Corpus.
Liability is fixed on ownership at 1 January; the return and the payment are both due by 15 May of the same year (art. 990 F). Where a chain of entities exists, the tax is owed by whichever entity sits closest to the property and is not itself exempt — but every interposed entity between the debtor and the property is jointly and severally liable for payment. The tax is collected under the rules, penalties and guarantees applicable to registration duties. On a €10M villa, a disclosure failure is €300,000 a year, and the exposure does not stay confined to the entity that made it.
Source: Code général des impôts, arts. 990 D, 990 E and 990 F (Légifrance), verified against the Chiron Legal Corpus.
The trap is escapable. An entity that breached its disclosure undertaking and fell into the tax can exempt itself from the year in which it supplies the information to the tax authority and gives a fresh undertaking to supply it again on request (art. 990 F). That is the good news. The limit is that the cure runs forward only: years already triggered remain due. Which is why this is a structuring question to settle before the deed, not after the first assessment — and why an SCI or trust acquired with a property should be audited for 990 E compliance during the purchase, not discovered in May.
Source: Code général des impôts, arts. 990 D, 990 E and 990 F (Légifrance), verified against the Chiron Legal Corpus.
When a non-resident sells French property, the gain is taxed in France under the special levy of article 244 bis A of the CGI — broadly the resident regime: a 19% levy on the gain plus social contributions, reduced by relief for length of ownership (tapering to exemption over 22–30 years) — subject to any applicable double-tax treaty, which may reallocate or credit the tax. Non-residence is assessed at the date of sale (CGI art. 4 B for fiscal domicile).
Source: BOFiP series BOI-RFPI-PVINR; CGI art. 244 bis A, 4 B, 150 U (Légifrance / bofip.impots.gouv.fr)
Monaco levies no personal income tax on individuals resident on its territory. But the France–Monaco fiscal convention of 18 May 1963 (art. 7-1) provides that French nationals who transfer their residence to Monaco after 13 October 1962 — or who cannot show five years' habitual residence there by that date — remain taxable in France on their worldwide income as if they were resident in France (returns filed at the Menton tax office). Non-French nationals who establish genuine residence in Monaco can enjoy its zero income tax. The Conseil d'État has clarified the edges — French nationals born in Monaco and continuously resident since birth fall outside art. 7-1.
Source: BOFiP BOI-INT-CVB-MCO (convention du 18 mai 1963, art. 7-1); Conseil d'État, 11 April 2014, n° 362237 and 21 June 2021, n° 439354
Three variables set the outcome — your nationality (the France–Monaco treaty turns on it), your tax residence (which country taxes what, under the relevant treaty), and your holding structure (direct ownership, an SCI, or an offshore entity — each with its own IFI, 3%-tax and succession consequences). None of this is one-size-fits-all: the same villa carries a very different tax profile for a German buyer resident in Munich, a Brazilian resident in São Paulo, a Dutch owner structuring through a company, and a French national relocating to the Principality. This dossier maps the terrain; a notaire or avocat fiscaliste should price your specific route before you sign.
Under the Franco-German tax convention, income and gains from French real estate are taxable in France, where the property is situated; the convention then sets how Germany relieves the double taxation for its residents (BOFiP series BOI-INT-CVB-DEU). Practically, a German resident buying a Riviera villa meets the full French framework described above — transfer duties at purchase, the IFI above €1.3M of net French real estate, and the 3% entity tax if holding through a non-disclosing company. Germany currently levies no general wealth tax of its own, so the IFI is often the first wealth-type tax a German owner encounters — worth pricing before, not after, the purchase.
Source: BOFiP BOI-INT-CVB-DEU (convention fiscale franco-allemande); CGI art. 964
The France–Brazil convention of 10 September 1971 (art. 13) makes gains from French real estate — including shares of companies whose assets are principally French property — taxable in France, and the Conseil d'État has twice confirmed that the treaty does not prevent the residence state from also taxing with a credit (CE 11 Dec. 2020, n° 440307; CE 14 Apr. 2022, n° 455943). The point most often missed: the 1971 convention covers income taxes only. It is silent on wealth tax — so a Brazilian resident's French real estate above €1.3M net falls under the IFI by French domestic law, with no treaty relief to invoke.
Source: convention franco-brésilienne du 10 septembre 1971, art. 13 and 22; Conseil d'État n° 440307 (2020) and n° 455943 (2022); CGI art. 964
The France–Netherlands convention of 16 March 1973 (art. 6) states the rule plainly: income from immovable property is taxable in the state where the property is situated — France, for a Riviera villa — with double taxation relieved under art. 24. The Franco-Belgian convention applies the same situs principle to real-estate income (art. 3), as the Conseil d'État set out when reading both treaties side by side (CE 7 Dec. 2018, n° 409229). For Dutch and Belgian residents the practical framework is therefore the standard one above: French duties at purchase, French taxation of rental income and gains, IFI above the €1.3M threshold — with the home-country relief mechanics set by each convention.
Source: conventions of 16 March 1973 (NL, art. 6 and 24) and franco-belge (art. 3), as cited in Conseil d'État, 7 Dec. 2018, n° 409229
Three stages: at purchase, transfer duties of roughly 5.8% of the price plus the notaire's fee (CGI art. 683, 1594 D, 1595); during ownership, the IFI wealth tax if French real estate exceeds €1.3M net (art. 964-965) plus local taxe foncière, and a 3% annual tax if held through a non-compliant company or trust (art. 990 D); on sale, a 19% capital-gains levy plus social contributions with relief over time (art. 244 bis A) — all subject to any tax treaty. This is general information; confirm with a notaire or avocat fiscaliste. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Under article 7-1 of the France–Monaco convention of 18 May 1963, a French national who transfers residence to Monaco after 13 October 1962 remains taxable in France on worldwide income as if resident in France — despite Monaco levying no income tax. Non-French nationals establishing genuine Monaco residence can enjoy its zero income tax. Source: BOFiP BOI-INT-CVB-MCO; Conseil d'État nos 362237 (2014) and 439354 (2021). This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Yes — the impôt sur la fortune immobilière (IFI) applies to a non-resident whose French real estate exceeds €1,300,000 net, held directly or via a company to the extent of its real-estate value, at progressive rates from 0.5% to 1.5% (CGI art. 964-965). This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
It can. A legal entity owning French real estate owes an annual 3% tax on the property's market value (CGI art. 990 D) unless it files an annual return disclosing its owners and qualifies for exemption (art. 990 E). Structuring without complying triggers 3% per year — take advice before choosing a holding vehicle. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
In all three cases the villa itself is taxed in France — the German, Dutch (art. 6, 1973 convention) and Brazilian (art. 13, 1971 convention) treaties all assign real-estate income and gains to the state where the property sits, with home-country relief per each treaty. The IFI wealth tax applies above €1.3M of net French real estate; notably, the France–Brazil convention does not cover wealth tax, so IFI applies to Brazilian residents with no treaty relief. General information — confirm your case with a notaire or avocat fiscaliste. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
France levies an annual 3% tax on the market value of French real estate held by a legal entity — company, trust or similar (CGI art. 990 D) — unless the entity files an annual return disclosing its beneficial owners and qualifies for exemption (art. 990 E). It exists to prevent anonymous offshore ownership; individuals holding property in their own name do not pay it. Non-compliant structuring costs 3% of the property's value every year. Elena Agueeva reliers on a leading hedge super-prime legal and fiscal advisory service for answering specific cases; but is no substitute for an avocat fiscaliste. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Yes — France imposes no nationality or residence restriction on buying property; a non-resident foreigner can purchase freely, per Notaires de France. What differs is tax: roughly 5.8% transfer duties plus notaire's fee at purchase (CGI art. 683, 1594 D), the IFI wealth tax if French real estate exceeds €1.3M net (art. 964-965), and on resale a 19% capital-gains levy plus social contributions with taper relief (art. 244 bis A) — all subject to any applicable tax treaty. Elena Agueeva relies on a leading hedge super-prime legal and fiscal advisory service for answering specific cases; but is no substitute for an avocat fiscaliste. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
It depends on nationality. Monaco levies no personal income tax, and non-French nationals who establish genuine Monaco residence can benefit from that. But under article 7-1 of the France–Monaco convention of 18 May 1963, a French national who moved to Monaco after 13 October 1962 remains taxable in France on worldwide income as if still French-resident. And any French real estate keeps its French taxes (IFI, taxe foncière, capital gains) regardless of where the owner lives. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Monaco itself levies no personal income tax — but that does not free French citizens. Under article 7-1 of the France–Monaco tax convention of 18 May 1963, French nationals who transferred residence to Monaco after 13 October 1962 remain taxable in France on their worldwide income as if they had never left (BOFiP BOI-INT-CVB-MCO; upheld by the Conseil d'État in 2014 and 2021). The zero-tax advantage of Monaco residence is, in practice, reserved to non-French nationals. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Yes. Beyond the base 19% levy and social contributions, gains above €50,000 on built property attract an additional progressive tax of 2% to 6% (CGI art. 1609 nonies G): 2% from €50,001, stepping through the bands to 6% for gains above €260,000 — applied to the whole taxable gain, due by the seller at the sale. It expressly covers non-residents taxed under art. 244 bis A, and does not apply to building land. On villa-scale gains the 6% band is the practical norm. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Once net taxable real estate exceeds €1,300,000 (CGI art. 964), the IFI applies on a progressive scale (art. 977): 0.50% on the fraction from €800,000 to €1.3M, 0.70% to €2.57M, 1% to €5M, 1.25% to €10M and 1.50% beyond, with a smoothing formula for estates between €1.3M and €1.4M. A principal residence enjoys a 30% abatement on its market value (art. 973 — one property per couple), and non-residents are assessed on French-situs assets only (art. 964 2°). This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Not immediately. Under CGI art. 964 1°, a person who becomes French tax-resident after five consecutive calendar years of non-residence is liable to the IFI only on French-situs real estate until 31 December of the fifth year following arrival — foreign property enters the net from the sixth year. Married couples are assessed jointly. The €1,300,000 threshold and the principal-residence abatement apply as usual. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
A trust does not shelter French real estate from wealth taxation. Trust assets are included in the settlor's (or deemed-settlor beneficiary's) IFI base; where they are not duly declared for IFI, a dedicated levy (prélèvement) applies instead, assessed on the net market value of the trust's in-scope real assets at 1 January and payable by the trustee by 15 June, with the settlor and beneficiaries jointly liable on default (CGI art. 990 J). Separately, trusts fall squarely within the annual 3% tax regime of art. 990 D unless they qualify for and claim an exemption. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Often, yes. The non-resident capital-gains levy is paid on registration of the deed — or within the month of sale — under the responsibility of a representative established in France and accredited by the tax administration, whose eligibility conditions are set by statute (CGI art. 244 bis A IV). Sellers resident in the EU (or an EEA state with the required assistance conventions) benefit from a dispensation in practice; sellers from elsewhere — UK, Switzerland, the US, the Gulf — should budget for an accredited representative's fee in their closing costs. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Unlike other nationalities, French citizens gain no income-tax advantage from moving to Monaco: under article 7-1 of the Franco-Monegasque convention of 18 May 1963, a French national who transfers domicile to Monaco remains subject to French income tax on worldwide income exactly as if still living in France (declarations are filed with the Menton tax office). The Conseil d'État admits narrow exceptions — notably French nationals born in Monaco who have always resided there. French-situs real estate remains fully taxable in France in any event, including IFI above €1.3M of net French property. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Three layers. At purchase: transfer duties and notaire fees of roughly 7–8% on existing property — the same rates as French buyers, with no foreigner surcharge. Each year: taxe foncière like any owner, plus IFI wealth tax if net French real estate assets exceed EUR 1.3M (non-residents are assessed on French-situs assets only). At resale: 19% capital gains tax, plus social levies of 17.2% (7.5% for EU/EEA-affiliated sellers), plus a 2–6% surtax on gains above EUR 50,000, before holding-period abatements. Individual situations vary by treaty and residence — obtain advice from a qualified avocat fiscaliste before transacting. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Monaco publishes no DVF — the reference is IMSEE, the Principality's statistics institute: resale apartments averaged a record €51,967/m² in 2024, and under IMSEE's revised 2025 methodology the average stands at €57,569/m², with Larvotto above €71,000/m². Houses barely exist and trade privately. For perspective, the French corridor around Monaco — Roquebrune-Cap-Martin, Cap-d'Ail, Èze, Beaulieu — recorded €1.12 billion of €3M+ villa sales in the past 36 months (DVF).
In practice, yes — but it is banking convention, not law. Monaco's carte de séjour requires proof of solvency, usually a reference letter from a Monegasque bank, and most banks issue one only against a deposit of roughly €500,000, which remains your money. Alternatives exist: a Monaco employment contract, a business in the Principality, or support from a resident spouse or parent. Non-EU nationals first need a French long-stay (type D) visa. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Yes — but unlike every other nationality, French citizens gain no income-tax advantage. Under article 7-1 of the 1963 Franco-Monegasque convention, French nationals who move to Monaco remain subject to French income tax on their worldwide income as if they had never left, filing with the Menton tax office. Holding a second (non-Monegasque) nationality changes nothing: dual nationals are treated as French. The only exemption is treaty-based and historical — French nationals who could prove five years' habitual residence in Monaco as of 13 October 1962, in practice long-established Monaco-born families. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
France charges foreigners exactly the same recurring property taxes as French owners — there is no surcharge for being foreign. Expect taxe foncière, set annually by each commune, and taxe d'habitation on second homes, which many high-demand communes — including most of the Riviera — may increase by 5–60%. The tax that catches international owners is IFI, the real-estate wealth tax, due once net French property assets exceed EUR 1.3M; non-residents are assessed on French-situs property only, and some treaties modulate it. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Yes — Monaco places no nationality restriction on property ownership; non-residents buy freely through a Monegasque notary, and much of the market is held by international owners. Owning does not confer residency: the carte de séjour is a separate process requiring accommodation and proof of solvency. Note that Monaco levies no annual property tax and no capital-gains tax on individuals — part of why entry prices average €57,569/m² (IMSEE 2025). This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Per IMSEE, the Principality's official statistics institute: resales averaged €51,967/m² in 2024 — a record — ranging from €47,836/m² for studios to €58,767/m² for the largest apartments; the 2025 revised-methodology average is €57,569/m². A modest 100 m² two-bedroom therefore represents roughly €5–6M before the premium districts: Larvotto averages above €71,000/m².
Yes. The route: a French long-stay (type D) visa first, then Monaco's carte de séjour with proof of accommodation and solvency (in practice a Monegasque bank reference, customarily backed by a ~€500,000 deposit). One caveat no move erases: US citizens remain subject to US federal taxation on worldwide income wherever they live — Monaco's zero income tax softens, not cancels, the bill. This is general information — for specific cases Elena Agueeva relies on a leading-edge super-prime legal and fiscal advisory service, though that is no substitute for your own avocat fiscaliste.
Only if the structure fails the disclosure conditions. CGI art. 990 D charges an annual 3% of market value on any company, trust or comparable entity owning French property, including through any number of interposed entities. But art. 990 E exempts entities based in France, the EU or a treaty state that either declare annually or undertake to disclose on request — the property's situation, composition and value plus the identity of every holder of more than 1% of the shares. Most private structures are exempt; the ones that pay are the ones that did not file. This is a leading-edge super-prime legal and fiscal advisory service, not a substitute for an avocat fiscaliste on your own structure.
Liability is fixed on ownership at 1 January, and the return plus payment are due by 15 May of the same year (CGI art. 990 F). Where entities are stacked, the tax falls on whichever is closest to the property and not exempt, and every interposed entity is jointly liable for payment. This is a leading-edge super-prime legal and fiscal advisory service, not a substitute for an avocat fiscaliste on your own structure.
Only forward. Art. 990 F lets an entity that breached its undertaking exempt itself from the year in which it supplies the information and gives a fresh undertaking — but years already triggered remain due. On a €10M villa that is €300,000 per year already crystallised, which is why 990 E compliance is audited during a purchase rather than after the first assessment. This is a leading-edge super-prime legal and fiscal advisory service, not a substitute for an avocat fiscaliste on your own structure.
Enquiries on this market reach Elena Agueeva directly.
Emailelena@elenaagueeva.comTelephone+33 7 66 44 02 34WhatsAppMessage Elena Agueeva
Riviera Intelligence — every market analysis · elenaagueeva.com