«Alexis, I don’t understand: I am a resident in Portugal, why is the French tax authority demanding 17.2 % in social security contributions on my rental income from Lyon?»
This customer question illustrates the classic trap of the non-resident taxation.
My response was that of a compliance audit: "Because you are not affiliated with an EU or EEA social security scheme."«
I am Alexis Sagnier.
As a’Augmented Wealth Engineer, I don't just observe the tax; I model the trajectories. For this client, a transition to LMNP (Non-Professional Furnished Rental) made it possible to eliminate this expense through depreciation.
At the house of Balmont Conseil, We are transforming tax constraints into performance levers. For a non-resident, France is not just a territory of taxation, it is a field of international wealth management strategies high precision.
Determining tax status: Beyond mere physical presence
Before discussing figures, we must discuss the law.’assessment of tax residence It is not simply a matter of counting 183 days. The French administration uses a range of indicators (home, center of economic interests, professional activity).
The importance of international tax treaties
To avoid double taxation, we analyze the international tax treaties bilateral agreements. These are the agreements that determine which country has the right to tax your dividends or rental income. Our role is to secure your expatriate tax status to avoid any risk of reclassification, while optimizing the’tax exemption provided for by certain treaties.
The most common mistake is believing you are protected by your foreign residence when the bulk of your income comes from France. If your major economic interests remain in France, the French tax authorities can invoke the...’Article 4B of the French General Tax Code to consider you as a French tax resident, with taxation on your Worldwide Income (global income).
Taxation of rental income for non-residents: The 20-% wall and avoidance solutions
The minimum rate mechanism
20 % for the portion of net taxable income below a certain threshold (approximately €27,000).
30 % beyond.
However, if you can prove that your average tax rate on your worldwide income would be lower, you can request that this average rate be applied. This is where Balmont Conseil's expertise comes in: we calculate this worldwide rate for you to optimize your tax return.
Social security contributions (CSG/CRDS) for expatriates: The geographical criterion
1. Residents outside the EU/EEA/Switzerland area : You pay 17.2 % in social security contributions.
2. Residents of the EU/EEA/Switzerland Thanks to the Ruyter ruling and legislative developments, this rate falls to 7.5 % (solidarity levy), provided that one is not covered by a French social security scheme.
The 2026 Property Income Tax Return: Prepare for Form 2044-SPE
One data entry error, and you're guaranteed an automatic tax audit triggered by the administration's AI.
Ready to structure Your future?
Your assets deserve expertise that matches your ambitions.
Whether you are in Lyon or on the other side of the world, Alexis Sagnier and the Balmont Conseil team are ready to listen to you.
Advanced Strategies: European SCPIs and Bare Ownership
For non-residents, the objective is often to decouple asset performance from French taxation.
Real estate investment trusts (REITs) for non-residents: The power of Europe
Investing in SCPIs that hold assets in Germany, Spain or Ireland allows you to benefit from the tax treaties of these countries.
- Advantage : The income is not considered French-source property income. Therefore, it is exempt from social security contributions (17.2 % or 7.5 %) and the minimum rate of 20 %.
Bare Ownership: Elimination of the IFI (Wealth Tax)
L'’Real Estate Wealth Tax (IFI) only affects French real estate assets exceeding €1.3 million. By investing in bare ownership, You remove the asset from your IFI tax base for the entire duration of the split of ownership (often 10 to 15 years), while preparing a inheritance optimized.
Expatriate financial investments: Arbitrage for liquidity and security
Investments to avoid
- Equity Savings Plan (PEA): While it can be retained, it loses its tax advantages in many countries of residence. In the USA, for example, it is considered a PFIC (Passive Foreign Investment Company), resulting in punitive taxation and complex reporting obligations (Form 8621).
- Savings account A for expatriates and home savings plan (PEL): While they remain accessible, their returns are often eroded by inflation and...’impact of exchange rates if you live in the dollar or Swiss franc zone.
Recommended investment products
L'’non-resident assurance-vie is the foundation of all expatriate wealth management. At Balmont, we recommend...’Luxembourg assurance-vie.
- Luxembourg safety triangle: A legal separation between client assets, the insurer's own funds and the custodian bank.
- Tax neutrality: Luxembourg does not tax non-residents. Only the country of tax residence applies its rules to redemptions.
- Multi-currency management: Crucial for neutralizing exchange rate risk.
The Exit Tax and Anticipating the Return to France
L'’Exit Tax This is not a departure tax, but a deferral mechanism. It targets taxpayers who have resided in France for at least 6 years out of the last 10 years and hold securities exceeding €800,000.
Managing the payment deferral
Balmont Conseil's support allows you to:
- Calculate the latent capital gain precisely.
- Submit the appropriate forms (2074-ET) to benefit from the automatic payment deferral to the EU or under guarantees to third countries.
- Follow the statute of limitations (2, 5 or 10 years depending on the case) so that the tax is permanently erased without ever being paid.
Anticipation of return: The Impatriate Regime (Art. 155 B)
If you are planning a return, the expatriate tax status This is turning into an opportunity. The Article 155 B scheme allows for a 50% exemption on the expatriation bonus and on 50% of foreign-sourced financial income. A windfall that is being prepared Before the signing of the employment contract in France.
The Balmont approach Augmented engineering at the service of non-residents
360° Wealth Audit
Delegated property management
Inheritance vigilance
Non-Resident Taxation in 6 Key Points
Your wealth deserves a borderless vision
Being a non-resident offers exceptional capital accumulation opportunities, provided you don't let the non-resident taxation absorb your performance. At Balmont Conseil, We combine Alexis Sagnier's expertise with technological power to secure every euro invested in France or internationally.
Don't let tax complexity limit your ambitions.
Schedule an appointment for a personalized non-resident tax audit
Alexis Sagnier
With over 17 years of expertise in financial engineering, Alexis Sagnier assists executives and expatriates in securing their cross-border challenges.
Sources & References:
- General Tax Code (CGI): Art. 4B, 155 B, 167 bis, 244 bis A.
- Official Bulletin of Public Finances (BOFiP): RPPM and RFPI series.
- Regulation (EU) No 650/2012 (International Successions).
- ANACOFI Member Booklet 2025 – Cross-border compliance standards.
- OECD Model Tax Convention.
- Comparison of SCPIs for expatriates: net-net return
