Wealth management in Germany

“Alexis, I've been working in Frankfurt for three years; my wife stayed in Strasbourg with the children. Nobody can tell me which country we're supposed to be taxed in, or what will happen to our wealth if one of us dies.”

Germany has 93,281 French nationals on the consular register at 31 December 2025. It is the sixth-largest destination worldwide, and the only major European destination where numbers are falling slightly (−1.66% over one year) — a sign of a settled community rather than a transient one.

It is also, of all our destinations, one of the best covered legally. France and Germany are bound by two separate tax treaties : one on income and wealth, the other — rarer — on inheritances and gifts. Added to these are a specific cross-border workers' regime and, for anyone affiliated to the German scheme, exemption from CSG and CRDS.

At Balmont Conseil, we see Germany as a case where most of the answers are already written — provided you read the right texts, in the right order, and know the clauses that make exceptions.

1. Why seek expert wealth management in Germany?

Four issues shape a Franco-German case.

• Determining tax domicile. Between a job across the Rhine and a family that stayed in France, the answer is never obvious. The 1959 treaty sets out a hierarchy of criteria, and the cross-border workers' regime an exception that reverses the general rule.
• The cross-border workers' regime. For anyone who lives in the border zone and works on the other side, salaries are taxable only in the State of residence. The zone and daily-return conditions are precise, and getting them wrong is costly.
• Passing on your estate. The treaty of 12 October 2006 covers inheritances and gifts. It settles treaty domicile and provides for a tax credit. It also contains an anti-abuse clause that can tie a recent arrival to their State of origin.
• Social charges. This is the most tangible advantage, and the most often forgotten: anyone affiliated to the German scheme bears only 7.5% on French-source capital income, instead of 17.2%. The right box still has to be ticked.

2. The France ↔ Germany framework in five verified points

Here is the applicable framework, checked against official sources as at 15 September 2026. Germany is, with the United States, one of the few destinations where the first two lines are both favourable.

The protocol of 31 March 2015 changed the rules on pensions. Many Franco-German retirees still reason on the basis of the former law. The applicable text is the 2015 one: we check it for each case rather than relying on old documentation.

The 2006 estate tax treaty does not neutralise everything. It allocates taxing rights between the two States and grants a tax credit. But Article 750 ter of the French Tax Code still applies, and its paragraph 3° makes taxable in France all assets received by an heir domiciled in France for at least six of the last ten years. If you live in Germany and your children have stayed in Strasbourg or Lyon, it is their situation that decides.

The exemption from CSG is not automatic. It requires an active declaration and proof of affiliation. Every year, European expatriates pay 17.2% instead of 7.5% for failing to tick two boxes. On property income of €20,000, the difference exceeds €1,900 a year.

3. Our services: 360° support for expatriates and investors

Our work covers three areas.

Qualifying your situation under the two treaties

We determine your tax domicile under the 1959 treaty for income, and under the 2006 treaty for inheritance — because the two definitions do not necessarily coincide. We then check, condition by condition, whether the cross-border workers' regime applies to you.

This work produces a document you can rely on: a reasoned, sourced and dated position that you can produce if either tax authority raises a question.

• Analysis of treaty domicile under both texts.
• Checking the conditions of the cross-border workers' regime (zone, daily return, employer).
• A written, sourced position, kept on your file.

Recovering and securing the CSG and CRDS exemption

We check that your affiliation does entitle you to the exemption, that boxes 8SH or 8SI are correctly completed, and that your proof of affiliation is up to date. Where appropriate, we look at the possibility of a claim for the years not yet time-barred.

It is a profitable step in a common Franco-German case, and one that is often omitted.

Structuring the Franco-German transfer of your wealth

We model the transfer of your wealth under both systems and apply the credit provided for by the 2006 treaty, then cross-check against Article 750 ter of the French Tax Code according to each heir's domicile.

Finally, we examine how portable your wrappers are. A Luxembourg assurance-vie contract is of particular interest here: it is neutral as regards the policyholder's country of residence and withstands a move back and forth between the two countries without disruption.

• Modelling the transfer of wealth and applying the treaty credit.
• Costing Article 750 ter for each heir.
• Reallocating wrappers according to their real portability.

4. Methodology: our way of working

We work in four stages, and at each stage you know where you stand.

1. The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
2. The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
3. The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
4. Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.

5. What the firm offers you

What concretely sets our work apart.

• Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
• A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
• Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.

Frequently asked questions: Germany

I work in Germany and my family lives in France. Where am I taxed?

It depends first on your tax domicile under the 1959 treaty, which sets out a hierarchy of criteria — permanent home, centre of vital interests, habitual abode, nationality.

If you fall within the cross-border workers' regime, the rule is reversed: your salary is taxable only in the State where you live, wherever your employer is located. The zone and return conditions are strict, and that is precisely the point we check first.

Can I avoid CSG on my French property income?

Yes, if you are affiliated to a mandatory German social security scheme. You are then exempt from CSG and CRDS, and only the 7.5% solidarity levy remains due, instead of 17.2%.

The exemption is not applied automatically: you must tick boxes 8SH or 8SI on form 2042 C and be able to prove your affiliation. It is a point we check systematically, including retrospectively.

Does the 2006 estate tax treaty protect my children who stayed in France?

It allocates the right to tax between the two States and provides for a tax credit, which is a considerable advantage over destinations with no estate tax treaty — that is, most of them.

It does not override Article 750 ter of the French Tax Code. If an heir is domiciled in France on the day of the transfer and has been for at least six of the previous ten years, France taxes all the assets they receive. The treaty credit then reduces the tax; it does not remove it.

Does exit tax apply if I move to Germany?

The thresholds in Article 167 bis of the French Tax Code are assessed in the same way whatever the host country. However, for a move to a European Union member state, the deferral of payment is automatic and requires no guarantee.

What remains are the reporting obligations and the follow-up until the tax is discharged. It is a formality, not a cash-flow burden.

Do I need a German adviser as well as you?

For anything under German domestic tax law — scales, allowances, local reporting obligations, how the German authorities treat your French contracts — yes: these matters are handled with a professional authorised in Germany.

Our role is to handle the French side of the case, ensure overall consistency and ask the German adviser the right questions. We do not claim to replace them.

In summary

Germany is, with the United States, the destination in our panel best covered by treaties: two treaties, including one on inheritance, a cross-border workers' regime, and the CSG exemption tied to European affiliation.

Most of the work is therefore less about building structures than about applying existing texts correctly — and not letting slip the advantages that do not apply automatically.

Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.

Let's review your situation

A thirty-minute conversation is enough to check your treaty domicile and your CSG exemption. You can also start with a free contract X-ray.

To learn more about Germany

Living in Germany: tax residency and tax rates 2026 · Leaving France for Germany: exit tax and Anmeldung · France-Germany Tax Convention: 1959 and 2006 · Returning to France from Germany · Taxation of rental income in Germany.

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