Donations and non-residents: what France taxes

If the donor is domiciled in France, all donated assets, whether located in France or abroad, are taxable in France, regardless of the donee's domicile. If the donor is domiciled outside France, only assets located in France are taxable, unless the donee has been domiciled in France for at least six of the ten preceding years. Tax treaties may alter this outcome.

This page deals with territoriality: what France can impose. It does not calculate taxes. The sources consulted do not specify whether allowances and tax rates apply in the same way to a non-resident recipient: the rule depends on your situation, so you should verify this before making a decision. It also does not address the content of tax treaties on a country-by-country basis.

The three cases in Article 750 ter

The BOFiP links donations to the same rules as inheritances: article 750 ter of the CGI, subject to agreements (BOI-ENR-DMTG-10-10-30, version of 12/09/2012, in force on this day according to the page).

The six years need not be consecutive (§ 390). The stay of a person not domiciled in France within the meaning of Article 4 B does not count (§ 380).

What the administration's Q&A says

The impots.gouv.fr page dedicated to the donation of a non-resident (modified on 20/03/2026) states that the rules differ depending on whether the donor and the donee are residents or not, and that the agreements "take precedence over the rules of French domestic law".

The page does not list the conventions and does not reproduce any pricing scales.

The depot route in 2026: two pages to read together

Economie.gouv.fr (page written on 01/04/2026) indicates that, since 01/01/2026, gifts made by hand must be declared exclusively online. The paper form 2735 is reserved for listed exemptions, including the crediting of taxes paid abroad. The impots.gouv.fr page on gifts from non-residents refers to form 2735 and the Non-Resident Tax Office. The two pages are not consistent in the sources consulted: verify the applicable filing method before proceeding.

A notarial deed is mandatory, particularly for real estate and real estate rights, gifts between spouses, and gifts involving division of property (economie.gouv.fr): this list is not exhaustive. In principle, the recipient pays the taxes in a single payment when filing the declaration. The donor can pay them without this being reclassified as a supplement to the gift.

Which properties are "located in France"?«

According to the BOFiP (paragraphs 90 and 100), assets located in France include real estate, tangible personal property and businesses operated in France, receivables from a debtor domiciled in France, and securities issued by the State or by a company having its registered office or effective management in France. The text read does not address bank accounts or life insurance policies: this page does not classify them.

Two extensions exist for a donor not domiciled in France:

• a French building held indirectly, when the donor holds, alone or with members of his family group (spouse, ascendants, descendants, brothers and sisters, as well as those of his spouse, § 230), more than half of the shares of a legal entity, including through a chain of participations (§ 170 to 250); ;
• the assets or rights comprising a trust as defined in Article 792-0 bis, the rights being due because of the tax residence in France of the beneficiary (§ 300).

Conventions and Column D

The conventions allocate the right to tax according to the donor's tax residence and the location of the assets, without taking into account that of the donee (BOFiP, § 420). The official list (BOI-ANNX-000306, in force since 29/04/2026) designates the letter D for donations.

The page "Inheritance treaties: which countries have agreements with France" provides the complete list. This list only includes agreements and conventions in force as of January 1, 2026.

Donation and non-resident: numerical example (fictitious profile)

Situation. Marc, a fictional character, resides outside of France. He gives his fictional daughter Zoé an apartment in France worth €400,000 and a securities portfolio held abroad worth €250,000. Zoé has been a resident of France since 2023.

Hypotheses. Notional values. A calendar year counts as a year of residence in France. The ten-year period precedes the year of the gift. No agreement applies. No tax is calculated: the tax base is assessed.

Issue. What assets are included in the taxable base in France if the donation is made in 2026? And if an identical donation were made in 2030? And if Marc were domiciled in France?

Strategy. Marc and Zoé take stock of their respective homes and the nature of their assets before signing, using the documents in their file. This calculation illustrates the process; it doesn't specify when to give.

Result.

This profile is fictitious and does not reflect your situation.

Donations and non-residents: what changes depending on your situation

• The donor's home on the day of the donation: he orders the first question.
• The donee's residence and years of residence in France : it plays a role when the donor is domiciled outside of France.
• The nature of the goods : real estate, securities, receivables, company or trust are not situated in the same way.
• The country in question and its convention : Column D of the official list does not tell the whole story.
• The drop-off point Paper form or online declaration, see above.
• Calculating rights : allowances and tax rates for a non-resident are not covered here.

The rule depends on your situation. No results are guaranteed.