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.
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)
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.
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).
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).
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.
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.