Wealth management in China

"Alexis, I'm moving to Shanghai for four years. My employer is still French and pays me partly from Paris. Where am I taxed?"

This is exactly the kind of situation that needs examining. In China, a resident foreigner may, during the first years, not be taxed on foreign income paid by a foreign payer. However, the France–China agreement excludes from residence persons taxed in a State only on their locally sourced income. Depending on how you are paid, France may keep the right to tax you.

Mainland China has 10,997 French nationals on the consular register at 31 December 2025, excluding Hong Kong and Macao (+0.9% over one year).

The applicable text is the agreement of 26 November 2013, which replaced the 1984 tax treaty. It does not cover Hong Kong or Macao, or inheritance. At Balmont Conseil, we start from this text, read article by article.

1. Why seek expert wealth management in China?

Four points determine your situation.

Residence depends on how you are paid. Article 4 § 1 of the agreement excludes from residence persons taxed in China only on their Chinese income. A salary paid wholly or partly from France needs to be reviewed before departure.
The correct text. Shanghai and Beijing fall under the 2013 agreement; Hong Kong has its own agreement, from 2010; Macao is covered by neither.
The exit tax remains to be confirmed. The tax authorities' annex recognises tax collection assistance for China, but the official notice for the exit tax return does not mention it. As a precaution, we prepare the file with guarantees.
Your estate. No convention governs it: France applies article 750 ter of the general tax code, without conventional correction.

2. The France ↔ China framework in five verified points

Here is the applicable framework, checked against official sources as at 1st October 2026.

French nationals on the register	10,997 at 31 December 2025, excluding Hong Kong and Macao (+0.9% year on year).
Income tax treaty	Yes — agreement of 26 November 2013, in force since 28 December 2014, replacing the 1984 tax treaty. It covers only income tax, and does not apply to Hong Kong or Macao.
Estate tax treaty	No. No convention governs inheritances or gifts between France and China: Article 750 ter of the General Tax Code applies without conventional correction.
Exit tax — deferral of payment	To be confirmed: guarantees to be provided. Annex BOI-ANNX-000508 records tax collection assistance, but the notice for return 2074-ETD 2026 does not list China among the States with automatic deferral.
CSG and CRDS on property income and capital gains	17.2% on property income and property capital gains, 18.6% on furnished lettings from 2025 income. The reduced rate of 7.5% does not apply.

Sources: list of tax treaties concluded by France (BOI-ANNX-000306, updated 29 April 2026); exchange-of-information and recovery-assistance clauses (BOI-ANNX-000508, position at 8 October 2025); register of French nationals living outside France at 31 December 2025 (Ministry for Europe and Foreign Affairs); text of the treaty published by impots.gouv.fr; impots.gouv.fr for non-residents' social charges. Position as at 1st October 2026.

On residence. Chinese law treats you as resident from 183 days in the year. The question is not only being a Chinese resident, but being taxed there broadly enough to be resident within the meaning of the agreement too. Chinese residence certificate, residence permit, annual returns and lease are gathered from arrival.

On exit tax. Until the non-residents' tax office has confirmed the automatic deferral for China in writing, we build the file as if guarantees were needed: it is the position that costs nothing if it proves unnecessary.

On your French income. They remain taxed in France, at the minimum rate of 20%, then 30% above €29,579 of net taxable income, or at the average rate if that is more favourable.

What we do not show. The detail of Chinese tax law is handled with a licensed adviser in China, whom we coordinate.

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

Three workstreams, in the order in which they are decided.

Residence and remuneration

We examine the structure of your pay — the part paid in China, the part paid from France — in light of Article 4 of the agreement, and we date your French tax departure. The Chinese residence documents are listed from arrival.

Pay structure and Article 4 § 1 of the agreement.
French tax departure date.
Chinese residence documents.

Exit tax and your French contracts

If your securities exceed €800,000 or if you hold at least 50% of the profits of a company, the exit tax applies (article 167 bis of the general tax code): we prepare the file with guarantees, unless there is written confirmation of the automatic deferment.

A French assurance-vie held by a non-resident no longer bears social charges; withdrawals are subject to a 12.8% levy, or 7.5% after eight years. A Luxembourg assurance-vie contract may be considered, case by case.

Estate transfer without a treaty

We establish what each heir would pay in France, according to their residence and the situation of the assets, and we prepare the gifts before departure.

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: China

Does the France–China agreement apply to Hong Kong?

No. The agreement of 26 November 2013 applies neither to Hong Kong, which has had its own agreement with France since 21 October 2010, nor to Macao.

Is the exit tax deferral automatic for China?

It is not established. Annex BOI-ANNX-000508 records tax collection assistance, but the notice for return 2074-ETD 2026 does not mention China. Until the tax authorities have confirmed it in writing, it is better to prepare guarantees (Article 167 bis of the French Tax Code).

Does the fact that my salary is paid from France pose a problem?

It can. Article 4 § 1 of the agreement excludes from residence persons taxed in China only on their Chinese income. If part of your pay is not taxed in China, your status as a resident within the meaning of the agreement must be checked before departure.

Is my French rental income still taxed in France?

Yes: at a minimum rate of 20% up to €29,579 of net taxable income and 30% above that, unless you opt for the average rate, plus social charges of 17.2% on unfurnished lettings and 18.6% on furnished lettings from 2025 income.

Will my estate be taxed in France?

For your assets located in France, yes, and for all assets received by an heir domiciled in France for at least six of the last ten years (Article 750 ter of the French Tax Code). No treaty governs inheritance between France and China.

In summary

In China, residence within the meaning of the agreement depends on how you are paid, exit tax remains to be confirmed and no text protects your estate.

These three points are settled before departure, along with what happens to your French income and contracts.

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