«"Alexis, I split my year between Hammamet and Lyon. I have an apartment there, shares here. Where will my inheritance be taxed, and who decides?"»
Tunisia had 20,060 French citizens registered with the consular register as of December 31, 2025, compared to 20,469 a year earlier. -2.00 % over one year. This is the 21ste French community in the world, with a few hundred people in Senegal and Brazil.
Its composition is unique: long-established dual nationals, retirees attracted by the cost of living and proximity, entrepreneurs, and subsidiary executives. Many live a de facto double 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 comprehensive available to the firm outside of Europe. The convention of May 28, 1973 regulates income tax, inheritance tax, registration fees and stamp duties, and it includes a rule for linking securities that is found almost nowhere else. Balmont Conseil, We start from this text.
1. Why seek expertise in 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 property by property, and Article 35 assigns the remainder to the sole State of the deceased's domicile. The framework exists; it still needs to be applied in the correct order.
- A rare rule regarding titles. Paragraph 2 of Article 34 links shares, units and bonds issued by capital companies to the state where the issuing company is headquartered. 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 splitting a tax year between two countries, the number of days alone is not the determining factor: it is the table in Article 3 of the convention, combined with Article 4 B of the French General Tax Code. A poorly documented case will be 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 convention itself and in the annexes of the tax administration as of September 16, 2026.
| French registered in the register | 20,060 as of December 31, 2025 (−2.00 % over one year). |
| Income Convention | Yes — Convention of 28 May 1973 for the elimination of double taxation and the establishment of rules for mutual administrative assistance in tax matters, as amended by the BEPS Multilateral Convention. Income taxes: Articles 9 to 29. |
| Convention on Successions | Yes — The same convention 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 payment deferral. Tunisia has with France an information exchange clause and an assistance in recovery clause, recognized for all taxes, including inheritance tax. |
| CSG and CRDS on property income and capital gains | 17.2 %. The exemption from CSG and CRDS applies to members of a social security scheme in the European Economic Area, Switzerland, or the United Kingdom. Tunisia does not fall into any of these categories. |
The issuer's registered office rule is the technical point of this convention. Paragraph 2 of Article 34 assigns shares, profit-sharing certificates, founders' shares, and negotiable bonds issued by capital companies to the State where the issuing company is headquartered. A portfolio of French shares therefore remains linked to France upon death, regardless of the deceased's domicile—the exact opposite of what the Franco-Senegalese convention provides for the same assets.
The physical furnishings follow their location. Paragraph 1 of the same article assigns them to the State where they are actually located on the date of death, with the exception of boats and aircraft, which are taxable in the State of registration. For a furnished secondary residence in Hammamet, the consequence is direct.
The elimination method works in your favor. Article 29 provides for an exemption with an effective tax rate for income taxable exclusively in Tunisia, and a tax reduction mechanism for the categories referred to in its following paragraphs. Agreements signed since the 1990s operate differently, through a tax credit equal to the French tax: the result is less favorable when the local tax is low.
What we don't display. The details of Tunisian domestic tax law—personal income tax rates, local inheritance tax, reporting requirements, and exchange control—are not included in this table: we have not verified them in a current primary source. These matters should be addressed with a qualified advisor in Tunisia, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three projects, for a life shared between two shores.
Establish and document your tax residence
This is the first task, and one that no one does until it is necessary. Article 3 of the convention establishes a framework for determining eligibility — permanent home, center of vital interests, habitual residence, nationality — which is combined with Article 4 B of the General Tax Code.
We compile the file while the information is available: leases, consumption records, accounts, actual presence, family situation. An audit that occurs three years later cannot be won with memories alone.
- Applying the grid from article 3 to your actual situation.
- Building the probationary file, year by year.
- Relationship with Article 4 B of the General Tax Code.
The transmission, under the 1973 convention
We apply the succession chapter in order: buildings, business assets, assets used for a liberal profession, then article 34 — tangible movable property according to their location, securities according to the issuer's headquarters — and finally article 35 for the rest, attributed to the State of domicile.
We cross-reference this with Article 750 ter of the General Tax Code, based on each heir's residence, and calculate the net expense. Luxembourg assurance-vie contract and the tools of wealth engineering They then look at each other, in light of this calculation.
The revenues on both sides
Your income and assets from French sources remain subject to French law: minimum rate for non-residents under Article 197 A of the General Tax Code, option for the average rate when it is more favorable, real estate wealth tax, social security contributions at the full rate of 17.2 %.
Your pensions are taxable only in your country of residence, in accordance with Article 25. We verify that the exemption with effective rate under Article 29 is indeed applied to your French tax return—it is often overlooked—and we process everything with the architecture of your wealth.
4. Methodology: our way of working
We work in four stages, and you know where you are at each stage.
- 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.
- 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.
- The arbitrations. We present you with the numerical options, along with their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- 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 Tunisia
Is there an inheritance treaty between France and Tunisia?
Yes. The convention of May 28, 1973 includes a chapter on successions, in articles 30 to 37, as well as provisions on registration and stamp duties.
This is a more comprehensive framework than that of the majority of destinations outside Europe, where no convention governs transmissions.
Will my French shares be taxed in France or Tunisia upon my death?
In France. Paragraph 2 of Article 34 links shares, profit-sharing certificates, founders' shares and negotiable bonds issued by capital companies to the State of the registered office of the issuing company.
This is an unusual rule: in most inheritance agreements, securities follow the deceased's domicile. Here, they follow the issuer. A mixed Franco-Tunisian portfolio is therefore allocated 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, profit-sharing bonuses, artists' and athletes' income—follow a separate tax reduction mechanism. These provisions are subject to change: they do not automatically apply to an incorrectly completed tax return.
Is the deferral of payment of the exit tax automatic for Tunisia?
Yes. Tunisia has with France an information exchange clause and an assistance in recovery clause, which the BOI-ANNX-000508 annex updated on October 8, 2025 recognizes for all taxes.
The stay of execution is therefore automatic: no tax representative or guarantees are required. Reporting obligations remain.
I split my year between France and Tunisia: where am I a resident?
The question cannot be resolved by the number of days. Article 3 of the convention sets out a framework for resolution: permanent home, then center of vital interests, then habitual residence, then nationality.
This framework is combined with Article 4 B of the General Tax Code. In cases of dual residency, it is the body of evidence compiled over the years that determines the outcome, not the declaration made after the fact.
Will I pay CSG on my French income?
Yes, at the full rate of 17.2% (%) on your French-source rental income and capital gains. The partial exemption applies only to those affiliated with 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 comprehensive conventional framework — income, inheritance, registration, assistance — and a favorable elimination method inherited from ancient conventions.
Its unique feature lies in one rule: your securities follow the headquarters of their issuer, not your home address. For assets split between two banks, this is the line that determines the valuation.
Firm's fees: €500 including VAT per hour. Annual follow-up is offered.
Let's review your situation
A 30-minute exchange is all it takes to establish your tax residence under the treaty and to allocate your assets between the two countries. You can also start with a Free X-ray of your contracts.
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