“Alexis, I am retiring to Cebu. The Philippines does not tax my French pension. So I have nothing to worry about on the tax side?”

That is precisely what can cause a problem. The Philippines taxes a resident foreigner only on Philippine-source income. Yet the French-Philippine treaty excludes from residence persons taxed in a State only on income from local sources. You can therefore be a Philippine resident under local law without being one under the treaty.

The Philippines has 3,029 French nationals on the consular register at 31 December 2025, a figure unchanged over the year.

The treaty of 9 January 1976 covers only income tax: nothing governs inheritance, and the exit tax requires guarantees. At Balmont Conseil, we start from this text, read article by article.

1. Why seek expert wealth management advice in the Philippines?

Four points determine your situation, and the first is specific to the Philippines.

  • A Philippine resident, but not necessarily a treaty resident. If the treaty does not recognise you as a Philippine resident, its tie-breaker rules do not apply, and France keeps its right to tax you as long as you remain domiciled in France within the meaning of Article 4 B of the French Tax Code. Your departure must therefore be clean.
  • An old treaty, not updated by the multilateral convention. The 1976 text, amended in 1995 and 2011, is not covered by the multilateral convention: it is read as it is, in its consolidated version.
  • The exit tax requires guarantees. The Philippines does not assist France in recovering tax: the deferral has to be requested, with a tax representative in France.
  • Your estate. No convention governs it: France applies article 750 ter of the general tax code, without conventional correction.

2. The France ↔ Philippines framework in five verified points

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

French nationals on the register3,029 at 31 December 2025 (stable year on year).
Income tax treatyYes — treaty of 9 January 1976, protocols of 1995 and 2011. It covers only income tax and is not modified by the BEPS multilateral convention.
Estate tax treatyNo. No convention governs inheritances or gifts between France and the Philippines: Article 750 ter of the General Tax Code applies without conventional correction.
Exit tax — deferral of paymentDeferral on request, with a tax representative and guarantees. The Philippines does not assist France in recovering tax (annex BOI-ANNX-000508).
CSG and CRDS on property income and capital gains17.2% 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. The Philippine residence certificate attests your residence under local law; it says nothing about the scope of what is taxed in the Philippines, and that is the point the treaty looks at. What protects you first is a genuine departure from France: no more home, no more main activity, no more centre of economic interests in France.

On your pension. If France retains the right to tax you, your French pension remains taxable there. We quantify this scenario before you move, not after a tax audit.

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

What we do not show. The details of Philippine tax and retirement visas are handled with a qualified adviser in the Philippines, whom we coordinate.

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

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

A departure from France that holds up

We check each of the criteria in Article 4 B of the French Tax Code, examine your status under Article 4 of the treaty, and list what needs to be closed or transferred so that your departure cannot be challenged.

  • Criteria for French tax residence, one by one.
  • Status under the 1976 treaty.
  • Philippine 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 deferral file, with tax representative and guarantees.

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.

  1. 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.
  2. 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.
  3. The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
  4. 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: the Philippines

Can I be a Philippine resident without being one under the treaty?

Yes. Article 4(1) of the treaty of 9 January 1976 excludes from residence persons taxed in a State only on income from local sources; and a foreign resident in the Philippines is taxed there only on Philippine income. France can then continue to tax you if you remain domiciled in France within the meaning of Article 4 B of the French Tax Code.

Is the exit tax deferral automatic for a move to the Philippines?

No. The Philippines does not assist France in recovering tax (annex BOI-ANNX-000508). The deferral must be requested, with a tax representative and guarantees (Article 167 bis of the French Tax Code).

Is there an estate tax treaty between France and the Philippines?

No. The 1976 convention only covers income tax. France therefore applies Article 750 ter of the General Tax Code, without any treaty amendment.

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.

Has the treaty been updated?

Partly: by the protocols of 1995 and 2011, the latter on the exchange of information. It is not covered by the BEPS multilateral convention, unlike most French treaties in Asia.


In summary

In the Philippines, not being taxed on your foreign income can deprive you of the treaty's protection. The exit tax there requires guarantees, and no text protects your estate.

A clean departure from France, the exit tax and the transfer of your estate are all prepared before you settle there.

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 check how solid your departure is. You can also start with a free contract X-ray.


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