“Alexis, I've been running a subsidiary in Abidjan for seven years. My life is here; my wealth stayed back home. I've never taken the time to look at what that means.”
Côte d'Ivoire is home to 19,346 French nationals on the consular register at 31 December 2025, an increase of +7.00% over one year : one of the fastest growth rates in the panel, driven by Abidjan and the dynamism of the West African subsidiaries.
It is also one of the best-covered destinations in treaty terms, which few people know. The treaty of 6 April 1966 contains an entire chapter on inheritance taxes, with a detailed allocation asset by asset — real property, business assets, fixed places of business, tangible movable property — and a clear catch-all rule for everything else.
At Balmont Conseil, we handle West African cases with the same documentary rigour as European ones. The difference lies not in the method but in the texts you need to know.
1. Why seek expert wealth management in Côte d'Ivoire?
Four issues, for an expatriation that is often work-related and long-term.
- Duration. Ivorian expatriations are becoming more prolonged, often beyond what was planned. Non-resident status is taking hold, and with it consequences that few anticipated — on retirement, assurance-vie, and inheritance.
- Passing on your estate. The 1966 treaty sets out precisely how taxing rights are shared between the two states. Its catch-all rule gives the state of the deceased's domicile everything the specific articles do not cover: that is substantial protection.
- French assets kept. Family residence, rental investment, savings: it continues to be taxed in France, according to the rules for non-residents.
- A family split between two countries. When part of the family has stayed in France and the rest has settled in Côte d'Ivoire, the taxation of what is passed on depends on each person's domicile. The calculation is done person by person.
2. The France ↔ Côte d'Ivoire framework in five verified points
Here is the applicable framework, checked against the text of the treaty itself and official sources as at 15 September 2026.
| French nationals on the register | 19,346 at 31 December 2025 (+7.00% over one year). |
| Income tax treaty | Yes — treaty of 6 April 1966 (Official Journal of 22 January 1969), amended by the protocols of 25 February 1985 and 19 October 1993. It covers income tax, wealth tax, inheritance and registration duties. |
| Estate tax treaty | Yes, and comprehensively. Chapter III of the treaty covers inheritance taxes. Real property is taxable in the state where it is located; business assets attach to the permanent establishment; tangible movable property is taxed where it is located at death; and all other assets are taxable only in the state where the deceased was domiciled at the time of death. |
| Exit tax — deferral of payment | Automatic deferral of payment. Côte d'Ivoire has both an exchange-of-information clause and a clause on assistance in the recovery of income tax with France. |
| CSG and CRDS on property income and capital gains | 17.2%. The exemption from CSG and CRDS applies to people covered by a scheme in the European Economic Area, Switzerland or the United Kingdom. The France–Côte d'Ivoire social security agreement, although in force, does not give access to it. |
The catch-all rule is the most useful provision in this text. It gives the state of the deceased's domicile the right to tax all assets not covered by the specific articles — in other words, the bulk of a financial estate. Where the deceased was domiciled in Côte d'Ivoire, this rule removes France's right to tax those assets.
On its own, it does not settle your heirs' position. Article 750 ter of the French Tax Code still applies, and its 3° makes assets received by an heir domiciled in France for at least six of the last ten years taxable in France. The treaty allocates and corrects; it is the combination of the two that must be calculated.
Ivorian domestic law is not included in this table. Rates, allowances, local reporting obligations, treatment of a foreign assurance-vie contract: we have not verified these against a primary source, so we do not assert them. They are handled with a qualified adviser in Côte d'Ivoire.
3. Our services: 360° support for expatriates and investors
Three workstreams for a long-term expatriation.
Establishing your domicile and reading the treaty
We first establish where your tax domicile lies, under French law and under the treaty. This determination governs everything else, and after several years abroad it is not always what you think.
We then apply the treaty asset by asset, separating what falls under the specific articles of the inheritance chapter from what falls under the catch-all rule.
- A reasoned position on your tax domicile, sourced and dated.
- Treaty allocation, asset by asset.
- Costing Article 750 ter for each heir.
Pension rights and social security cover
A long expatriation raises the question of continuity of rights. We establish the status of the rights you have built up in France, how they will be paid out, and the options available — joining a voluntary scheme, buy-backs, timing of drawing your pension.
We also review your household's protection insurance and health cover, often taken out by the employer and rarely reread since.
French wealth and the portability of envelopes
Your French assets remain taxed in France: property income at the minimum non-resident rate under Article 197 A of the French Tax Code, with the option for the average rate when it is more favourable, and IFI (real estate wealth tax). We keep track of the deadlines and hold on to the supporting documents.
On savings wrappers, we look at what to keep and what to switch. A Luxembourg assurance-vie contract offers a stable framework that does not depend on your country of residence, which matters when the expatriation goes on and trips home are few and far between.
4. Methodology: our way of working
We work in four stages, and at each stage you know where you stand.
- 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.
- 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.
- The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- 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 on Côte d'Ivoire
Does the France–Côte d'Ivoire treaty really cover inheritance?
Yes, and in detail. Chapter III of the treaty of 6 April 1966 covers inheritance taxes, with several articles allocating taxing rights according to the type of asset.
That is more complete coverage than Morocco's, for example, where the treaty contains only a single one-off provision. Few expatriates in Côte d'Ivoire know this.
What does the rule for my financial assets say?
Assets in the estate to which the specific articles of the chapter do not apply are taxable only in the state where the deceased was domiciled at the time of death.
In practice, for a mainly financial estate held by a deceased person domiciled in Côte d'Ivoire, this rule gives taxing rights to Côte d'Ivoire. Each heir's situation under Article 750 ter of the French Tax Code still has to be checked.
Are my children who stayed in France protected by this treaty?
Partly. The treaty allocates taxing rights between the two states, which is a real advantage. But Article 750 ter of the French Tax Code still applies: if an heir is domiciled in France on the date of the transfer and has been for at least six of the previous ten years, France taxes all the assets they receive.
The treaty then steps in to correct the result, not to prevent it. It is the combined calculation that gives the real tax burden.
After seven years in Abidjan, am I still a French tax resident?
It depends on specific criteria — home, main place of stay, professional activity, centre of economic interests — within the meaning of Article 4 B of the French Tax Code, and then on the treaty criteria if there is a conflict.
This is rarely clear-cut when part of the family has stayed in France. We draw up a written, reasoned and dated position that you can produce if the question is raised.
Will I pay CSG on my French rental income?
Yes, at the full rate of 17.2%. The exemption from CSG and CRDS is reserved for people covered by a scheme in the European Economic Area, Switzerland or the United Kingdom.
The social security agreement between France and Côte d'Ivoire is in force and coordinates certain rights, but it does not give entitlement to this exemption.
In summary
Côte d'Ivoire is one of the best-covered destinations in treaty terms, with a full inheritance chapter in what is nonetheless an old text. It is a real advantage, and largely overlooked.
The issue specific to this destination is duration: an expatriation that goes on changes your domicile, your pension rights and how your wealth is passed on. That is what we set out in full.
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 establish your tax domicile and assess your inheritance exposure. You can also start with a free contract X-ray.
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