“Alexis, I'm arriving in Bangalore in September to head the research centre. For that year, where am I resident?”
Possibly in both countries at once. India assesses residence over a tax year that runs from 1st April to 31 March, with a 182-day threshold; France reasons by calendar year. A September departure creates a period when both administrations may treat you as resident: the treaty breaks the tie, provided you have the evidence.
India has 6,893 French nationals on the consular register at 31 December 2025 (−1.9% over one year).
The treaty of 29 September 1992 covers income tax and wealth tax ; exit tax qualifies for automatic deferral. However, nothing governs inheritance. At Balmont Conseil, we start from this text, read article by article.
1. Why seek expert wealth management in India?
Four points determine your situation.
- Two calendars. The Indian tax year runs from 1st April to 31 March; the French tax year from 1st January to 31 December. The year of arrival and the year of return are prepared month by month.
- The most-favoured-nation clause no longer applies automatically. The treaty's protocol provides for aligning certain Indian withholding taxes with more favourable treaties. Since a ruling of the Indian Supreme Court of 19 October 2023, this alignment requires a notification by the Indian government: it can no longer be presumed.
- The exit tax is automatically suspended. India assists France in recovering tax: deferral is automatic, filing is not.
- Your estate. No convention governs it: France applies article 750 ter of the general tax code, without conventional correction.
2. The France ↔ India framework in five verified points
Here is the applicable framework, checked against official sources as at 1st October 2026.
| French nationals on the register | 6,893 at 31 December 2025 (−1.9% over one year). |
| Income tax treaty | Yes — treaty of 29 September 1992 and its protocol, amended by the BEPS multilateral convention. It covers income tax and wealth tax, and therefore IFI. |
| Estate tax treaty | No. No convention governs inheritances or gifts between France and India: Article 750 ter of the General Tax Code applies without conventional correction. |
| Exit tax — deferral of payment | Automatic deferral of payment : India assists France in recovering tax (annex BOI-ANNX-000508) and appears in the notes to form 2074-ETD 2026. |
| 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. |
On residence. The Indian certificate of residence is requested from the Indian tax authorities, for the Indian tax year. For the period when both countries claim you, the treaty breaks the tie by permanent home, then centre of interests, then habitual abode and nationality: keep your passport, lease, employer letters and day count.
On the IFI. The treaty covers wealth tax: it frames the IFI due on your real estate located in France above €1.3 million.
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 details of Indian tax, including the status of new arrivals, are handled with a qualified adviser in India, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three workstreams, in the order in which they are decided.
Departure: two calendars and exit tax
We date your French tax departure and your arrival in the Indian sense, month by month, then we file the exit tax declaration if your securities exceed €800,000 or if you hold at least 50 % of the profits of a company (article 167 bis of the general tax code).
- Year of arrival: the dual-residence period and evidence.
- Exit tax return and monitoring of the deferral.
- Year of return, prepared in the same way.
Your French income and contracts as seen from India
Rent, dividends, assurance-vie: we establish what France continues to tax and what the treaty reduces, without presuming the effect of the most-favoured-nation clause. A French assurance-vie policy held by a non-resident is no longer subject to social charges; its redemptions are subject to a levy of 12.8%, or 7.5% after eight years.
A Luxembourg assurance-vie contract may be considered for long-term mobility, on a case-by-case basis.
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: India
Why is the year I arrive in India a tricky one?
Because India assesses residence over a tax year from 1st April to 31 March, with a 182-day threshold, and France by calendar year. The same period can fall under both: the treaty of 29 September 1992 then breaks the tie, on evidence.
Is the exit tax deferral automatic for a move to India?
Yes. India assists France in recovering tax (annex BOI-ANNX-000508): payment is suspended with no guarantees. Form 2074-ETD remains mandatory in the year of departure, then every year (Article 167 bis of the French Tax Code).
Does the most-favoured-nation clause reduce Indian withholding taxes?
Not automatically any more. Since the Indian Supreme Court ruling of 19 October 2023, applying it requires a notification by the Indian government. Any saving based on this clause must be treated as not secured.
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 India.
In summary
India offers an automatic exit tax deferral and a treaty that covers IFI, but two tax calendars to reconcile and no protection for your estate.
The year of arrival, exit tax and passing on wealth are prepared before departure.
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 align your departure with both calendars. You can also start with a free contract X-ray.
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