“Alexis, I split my year between Hammamet and Lyon. I have a flat there, shares here. Where will my estate be taxed, and who decides?”
Tunisia had 20,060 French nationals on the consular register at 31 December 2025, against 20,469 a year earlier, a change of −2.00% over one year. It is the 21e largest French community in the world, within a few hundred people of Senegal and Brazil.
Its make-up is distinctive: long-established dual nationals, retirees drawn by the cost of living and proximity, entrepreneurs and subsidiary executives. Many live a de facto dual residence, between France and the Tunisian Sahel — which makes the question of tax residence central, and rarely addressed.
The Franco-Tunisian framework is one of the most complete the firm works with outside Europe. The treaty of 28 May 1973 covers income tax, inheritance, registration duties and stamp duties, and it contains a rule for allocating securities found almost nowhere else. At Balmont Conseil, we start from this text.
1. Why seek expert wealth management in Tunisia?
Four realities, in the order in which they determine the outcome.
- A complete chapter on inheritance. Articles 30 to 37 allocate the right to tax asset by asset, and Article 35 assigns the remainder solely to the State of the deceased's domicile. The framework exists; it still has to be applied in the right order.
- A rare rule on securities. Paragraph 2 of Article 34 allocates shares, units and bonds issued by joint-stock companies to the State where the issuing company has its registered office. A portfolio of French shares held by a Tunisian resident therefore does not follow the domicile rule.
- The exemption method with effective rate. Article 29 exempts from French tax income taxable exclusively in Tunisia, with France retaining only the right to calculate tax at the rate applicable to all of your income. This is more advantageous than the tax credit provided by recent tax treaties.
- Tax residence, a central issue. When you split your year between two countries, the number of days alone does not decide: it is the grid in Article 3 of the treaty, combined with Article 4 B of the French Tax Code. A poorly documented file is settled to the taxpayer's detriment.
2. The France ↔ Tunisia framework in five verified points
Here is the applicable framework, verified in the text of the treaty itself and in the tax authorities' annexes as at 16 September 2026.
| French nationals on the register | 20,060 at 31 December 2025 (−2.00% over one year). |
| Income tax treaty | Yes — treaty of 28 May 1973 for the avoidance of double taxation and the establishment of rules of mutual administrative assistance in tax matters, as amended by the BEPS multilateral convention. Taxes on income: Articles 9 to 29. |
| Estate tax treaty | Yes — the same treaty includes a chapter on inheritance (Articles 30 to 37), as well as articles on registration and stamp duties. Connecting rule: assets not covered by Articles 31 to 34 are taxable only in the State of the deceased's domicile (Article 35). |
| Exit tax — deferral of payment | Automatic deferral of payment. Tunisia has an information exchange clause and a recovery assistance clause with France, recognised for all taxes, including gift and inheritance taxes. |
| CSG and CRDS on property income and capital gains | 17.2%. The CSG and CRDS exemption applies to people affiliated to a scheme in the European Economic Area, Switzerland or the United Kingdom. Tunisia falls into none of these categories. |
The issuer's registered office rule is the technical point of this treaty. Paragraph 2 of Article 34 allocates shares, profit shares, founders' shares and negotiable bonds issued by joint-stock companies to the State where the issuing company has its registered office. A portfolio of French shares therefore remains attached to France on death, whatever the deceased's domicile — the exact opposite of what the Franco-Senegalese treaty provides for the same assets.
Tangible movable property follows its location. Paragraph 1 of the same article allocates it to the State where it is actually located on the date of death, except boats and aircraft, which are taxable in the State of registration. For a furnished second home in Hammamet, the consequence is direct.
The elimination method works in your favour. Article 29 uses exemption with effective rate for income taxable exclusively in Tunisia, and a tax reduction mechanism for the categories covered in its following paragraphs. Treaties signed since the 1990s work differently, through a tax credit equal to the French tax: the result is less favourable when local tax is low.
What we do not show. The details of Tunisian domestic tax law — the personal income tax scale, local inheritance tax, reporting and exchange control obligations — are not in this table: we have not verified them in an up-to-date primary source. They are handled with a qualified adviser in Tunisia, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three workstreams, for a life shared between two shores.
Establishing your tax residence, and documenting it
This is the first piece of work, and the one nobody does until they need it. Article 3 of the treaty sets out a tie-breaker grid — permanent home, centre of vital interests, habitual abode, nationality — which combines with Article 4 B of the French Tax Code.
We build the file while the evidence is available: leases, utility consumption, accounts, actual presence, family situation. An audit that comes three years later is not won with memories.
- Applying the Article 3 grid to your actual situation.
- Building the evidence file, year by year.
- Coordination with Article 4 B of the French Tax Code.
Passing on wealth under the 1973 treaty
We apply the inheritance chapter in order: immovable property, business assets, assets used in a liberal profession, then Article 34 — tangible movables by location, securities by the issuer's registered office — and finally Article 35 for the rest, allocated to the State of domicile.
We cross-check this with Article 750 ter of the French Tax Code according to each heir's domicile, and we calculate the net cost. The Luxembourg assurance-vie contract and the tools of wealth engineering are then considered in the light of these figures.
Income on both sides
Your French-source income and assets remain subject to French law: minimum non-resident rate under Article 197 A of the French Tax Code, option for the average rate when it is more favourable, real estate wealth tax, social charges at the full rate of 17.2%.
Your pensions are taxable only in your State of residence, under Article 25. We check that the exemption with effective rate under Article 29 is actually applied on your French tax return — it is often overlooked — and we handle the whole matter together with the architecture of your wealth.
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: Tunisia
Is there an estate tax treaty between France and Tunisia?
Yes. The treaty of 28 May 1973 includes a chapter on inheritance, in Articles 30 to 37, as well as provisions on registration and stamp duties.
This is a more complete framework than that of most destinations outside Europe, where no treaty governs the passing on of wealth.
Will my French shares be taxed in France or Tunisia upon my death?
In France. Paragraph 2 of Article 34 allocates shares, profit shares, founders' shares and negotiable bonds issued by joint-stock companies to the State where the issuing company has its registered office.
This is an unusual rule: under most estate tax treaties, securities follow the deceased's domicile. Here, they follow the issuer. A mixed Franco-Tunisian portfolio is therefore split line by line.
Will my Tunisian income be taxed in France?
Article 29 provides that income exclusively taxable in Tunisia is exempt from French taxes, France retaining the right to calculate the tax at the rate corresponding to all of your taxable income according to its legislation.
Certain categories — dividends, interest, directors' fees, entertainers and sportspeople — follow a separate tax reduction mechanism. These provisions have to be claimed: they do not apply automatically to an incorrectly completed return.
Is deferral of payment of exit tax automatic for a move to Tunisia?
Yes. Tunisia has an information exchange clause and a recovery assistance clause with France, which annex BOI-ANNX-000508, updated on 8 October 2025, recognises for all taxes.
The deferral therefore applies as of right: no tax representative, no guarantees to provide. Reporting obligations remain.
I split my year between France and Tunisia: where am I a resident?
The question is not settled by the number of days. Article 3 of the treaty sets out a tie-breaker grid: permanent home, then centre of vital interests, then habitual abode, then nationality.
This grid combines with Article 4 B of the French Tax Code. In dual-residence cases, it is the evidence file built up over the years that decides, not the return filed after the event.
Will I pay CSG on my French income?
Yes, at the full rate of 17.2% on your French-source property income and real estate capital gains. The partial exemption applies only to people covered by a scheme in the European Economic Area, Switzerland or the United Kingdom.
On a property rented in France, this item weighs more heavily than income tax itself.
In summary
Tunisia offers a complete treaty framework — income, inheritance, registration, assistance — and a favourable elimination method inherited from older treaties.
Its particularity lies in one rule: your securities follow their issuer's registered office, not your domicile. For wealth split between two shores, that is the line that decides the figures.
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 residence within the meaning of the treaty and to allocate your assets between the two States. You can also start with a free contract X-ray.
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