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 assets if one of us dies.»

Germany has 93,281 French citizens registered with the consular register as of December 31, 2025. This is the sixth world destination, and the only major European destination whose numbers are declining slightly (−1.66 % over a year) — a sign of a settled community rather than a transient one.

It is also, of all our destinations, one of the best equipped legally. France and Germany are linked by two separate tax treaties One relates to income and wealth, the other – less common – to inheritances and gifts. In addition, there is a specific cross-border regime and, for those affiliated with the German system, exemption from CSG and CRDS contributions.

At the house of Balmont Conseil, We consider Germany as a case where the essentials are already written — provided you read the right texts, in the right order, and know the clauses that are exceptions.

1. Why seek expertise in wealth management In Germany?

Four topics structure a Franco-German dossier.

• Determining tax residence. The choice between a job in Germany and a family remaining in France is never straightforward. The 1959 convention establishes a hierarchy of criteria, and the border regime is an exception that overturns the general rule.
• The border regime. For those who live in the border region and work on the other side, wages are taxable only in their state of residence. The rules regarding border crossings and daily commutes are specific, and ignorance of them can be costly.
• Transmission. The convention of October 12, 2006, covers inheritances and gifts. It regulates the conventional domicile and provides for a tax credit. It also includes an anti-abuse clause that can link a person who has recently settled in the country to their country of origin.
• Social security contributions. This is the most tangible and often overlooked advantage: a member of the German social security system now only pays 7.5% of their French-source capital income, instead of 17.2%. However, the correct box must be ticked.

2. The France ↔ Germany framework in five verified points

Here is the applicable framework, verified in official sources as of September 15, 2026. Germany, along with the United States, is one of the few destinations where both of the first two lines are favorable.

The amendment of March 31, 2015 modified the pension scheme. Many Franco-German retirees still reason based on the previous legal framework. The applicable text is that of 2015: we verify it for each case rather than referring to outdated documentation.

The 2006 inheritance agreement does not neutralize everything. It organizes the division of assets between the two states and grants a tax credit. However, Article 750 ter of the French General Tax Code remains applicable, and its third paragraph makes all assets received by an heir domiciled in France for at least six of the last ten years taxable in France. If you live in Germany and your children have remained in Strasbourg or Lyon, their situation is the determining factor.

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 % because they failed to check two boxes. On rental income of €20,000, the difference exceeds €1,900 per year.

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

Our intervention focuses on three areas.

Qualification of your situation with regard to the two conventions

We determine your tax residence under the 1959 Convention for income and under the 2006 Convention for inheritance—as the two definitions do not necessarily coincide. We then verify whether the border regime applies to you, condition by condition.

This work provides an enforceable document: a reasoned, sourced and dated position that you can produce if questioned by either administration.

• Analysis of conventional domicile in light of the two texts.
• Verification of the conditions of the border regime (zone, return, employer).
• Written and sourced position, kept in your file.

Recovery and securing of CSG and CRDS exemptions

We verify that your membership entitles you to the exemption, that boxes 8SH or 8SI are correctly completed, and that your proof of membership is up to date. If necessary, we examine the possibility of a claim for the years not yet time-barred.

This is the most cost-effective move in a routine Franco-German matter, and the most frequently overlooked.

Structuring Franco-German transmission

We model the transfer in both systems and apply the conventional credit provided for by the 2006 agreement, then we cross-reference with article 750 ter of the CGI according to the domicile of each heir.

Finally, we are examining the portability of your envelopes. One Luxembourg life insurance contract This presents a particular interest here: it is neutral with regard to the subscriber's country of residence and supports a round trip between the two countries without interruption.

• Modeling of transmission and application of conventional credit.
• Calculation of article 750 ter for each heir.
• Allocation of envelopes based on their actual portability.

4. Methodology: our way of working

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

1. The initial assessment. We assess your actual situation: composition of assets, project timeline, situation of each member of the household, and tax domicile of your heirs — because it is theirs that dictates, not yours.
2. The applicable reference framework. We establish, source by source and with its date, the framework that concerns you. What we do not know, we write "to be confirmed" — never anything else.
3. The arbitrations. We present you with the numerical options, along with their respective consequences, and you decide. Heritage engineering comes after the decision, not before.
4. The follow-up. An annual review, offered free of charge, which verifies that the framework has not changed — the conventions are modified, the attractiveness schemes are eliminated, the thresholds change.

5. What the firm offers you

This is what specifically distinguishes our intervention.

• Sources, not claims. Each item in your file has its reference number and date. You can check. This is the only way to work on a subject where most of the information available online is outdated.
• A single point of contact in France. We coordinate with your local advisors, we do not replace them: the internal tax regulations of the host country are handled by a qualified professional on site. Our role is to maintain overall consistency and to defend the French side of the case.
• Fees that are easy to understand. Firm fees: €500 including VAT per hour. Annual follow-up is included. No hidden kickbacks, no performance-based billing.

Frequently Asked Questions in Germany

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

This depends first of all on your tax domicile as defined by the 1959 convention, which establishes a hierarchy of criteria — permanent home, centre of vital interests, habitual residence, nationality.

If you fall under the cross-border worker regime, the rule is reversed: your wages are taxable only in the country where you reside, regardless of your employer's location. The zone and return conditions are strict, and this is precisely the point we check first.

Can I avoid the CSG tax on my French rental income?

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

The exemption is not applied automatically: it requires checking boxes 8SH or 8SI on form 2042 C and being able to provide proof of affiliation. This is something we systematically check, including retroactively.

Does the 2006 inheritance agreement protect my children who remained in France?

It organizes the distribution of the right to tax between the two States and provides for a tax credit, which is a considerable advantage compared to destinations without a succession agreement — i.e. the majority.

It does not eliminate Article 750 ter of the French General Tax Code. If an heir is domiciled in France on the date of inheritance and has been so for at least six years during the ten preceding years, France taxes all the assets they receive. The tax credit then serves as a reduction, not an exemption.

Does the exit tax apply if I go to Germany?

The thresholds in Article 167 bis of the General Tax Code are assessed in the same way regardless of the host country. However, for a departure to a Member State of the European Union, the deferral of payment is automatic and without warranty.

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

Do we need German advice in addition to yours?

For everything related to German domestic tax law — tax rates, allowances, local reporting obligations, processing of your French contracts by the German administration — yes: these issues are dealt with by a qualified professional in Germany.

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

In summary

Germany, along with the United States, is the best-equipped destination in our panel in terms of conventions: two conventions, including one on inheritance, a border regime, and the exemption from CSG attached to European affiliation.

The main part of the work therefore consists less in constructing schemes than in correctly applying existing texts — and not letting go of advantages that do not trigger on their own.

Firm's fees: €500 including VAT per hour. Annual follow-up is offered.

Let's review your situation

A thirty-minute exchange is all it takes to verify your conventional address and your CSG exemption. You can also start with a Free X-ray of your contracts.

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