In summary…
In Monaco, a French citizen is not considered a non-resident for tax purposes: the 1963 convention treats them, for income tax purposes, as if he had his residence in France, except in specific cases related to long-standing residence, birth in Andorra, or marriage. In Andorra, the system is that of a classic convention, but the 2013 text contains a nationality clause which allows it, on paper, to impose its nationals as if the text did not exist.
In both cases, nationality is just as important as residence. Before moving, you need to know which side of that line you're on.
«I’m moving to Monaco, so I no longer have any tax ties with France.» This statement might be true for a foreign national, but it’s false, in most cases, for a French citizen. Andorra, on the other hand, is sometimes presented as a more accessible Monaco: the comparison doesn’t hold water, and not for the reason you might think.
1. Monaco: French nationality follows the taxpayer
The rule in Article 7-1 of the 1963 Convention
The Franco-Monegasque convention of May 18, 1963, amended by an addendum of June 25, 1969, and supplemented by an exchange of letters dated May 26, 2003, stipulates that French citizens who settle in Monaco, or who cannot prove five years of habitual residence in Monaco as of October 13, 1962 (i.e., residence prior to October 13, 1957), are taxed in France as if they were domiciled there. This rule therefore applies to any French citizen arriving after this date: worldwide income, declaration to the tax office in Menton.
On the Monegasque side, there is neither personal income tax nor wealth tax, with the exception of French nationals, governed by the 1963 convention (official website of the Monegasque government).
Social security contributions are a separate matter: they are governed by another text and only follow the rule if the taxpayer is also domiciled in France within the meaning of Article 4 B of the French General Tax Code (CGI, the collection of French tax laws). The real estate wealth tax (IFI) applies to all real estate assets, located in France or abroad, owned by French citizens residing in Monaco from 1 January onwards.st January 1989; those established before this date are only established by virtue of their real estate located in France.
For the technician. Convention of 18 May 1963, article 7-1 (income tax) and article 7-3 (wealth); BOI-INT-CVB-MCO-10-20210602, §§ 10 (rule), 220 (worldwide income and contribution on high incomes, article 223 sexies of the CGI), 230 (social contributions, opinion of the Council of State of 2004), 380 to 400 (wealth; declarations to the Menton service).
Who breaks the rule
| Situation | Treatment according to administrative doctrine |
|---|---|
| Frenchman who settled in Monaco before October 13, 1957 and remained | Outside the scope of Article 7-1 (§ 30) |
| French national born in Monaco, resident without interruption | Outside the scope, according to the Council of State of April 11, 2014; certificate of residence required; any interruption of habitual residence terminates it (§§ 30 and 40) |
| Frenchman married to a Monegasque | Excluded from the scope of the agreement under certain conditions (maintained habitual residence) according to the exchange of letters in 2003; the divorce terminates it (§§ 70 to 90) |
| Franco-foreign dual national | Article 7-1 applies only to French nationality. This exception is reserved for those who established their residence in Monaco before December 29, 1995, subject to the conditions of retaining their foreign nationality, maintaining their habitual residence, and providing supporting documents before December 31, 1996; spouses, children, and parents must personally meet the conditions (§§ 120 to 140). |
| Non-Monegasque foreigner | Article 7-1 is not applicable; only Article 4 B of the French General Tax Code (CGI) can link it to France (§ 120) |
Specifically. The application is won or lost based on the supporting documents: certificate of residence, civil status documents, and proof of uninterrupted residence. A break in habitual residence in Monaco is sufficient to invalidate the certificate (§ 40). Disputes fall under the jurisdiction of the Franco-Monegasque Joint Advisory Commission established under Article 25.
2. Andorra: a classic convention, and a clause to be aware of
Residence: the usual order, without the 1963 clause
France and Andorra had no tax treaty prior to the one signed on April 2, 2013, which entered into force on January 1.st July 2015 and applicable, for income tax purposes, from the year 2016. Andorran personal income tax has been applicable since 1 January 2015. For persons residing in both states, the convention prioritizes the following criteria in order: permanent home, center of vital interests, habitual residence, nationality, and agreement between the authorities. A detail of the protocol: Andorran nationality alone is not sufficient to establish a presumption of Andorran tax residence.
A French citizen who travels to Andorra is therefore judged on the basis of Article 4 B of the French General Tax Code and the application of the convention., as with any other country. His home, his work and his assets matter more than his nationality, subject to the following reservation.
In Andorra, a tax resident is someone who spends more than 183 days in the calendar year in Andorra, or has their main business activities or economic interests there. Personal income tax is levied at a rate of 10% (%), after a minimum tax-exempt threshold of €24,000 (€40,000 in certain cases for couples), according to Law 5/2014 and the Andorran government's 2024 guide; the version applicable to the year in question should be verified before any calculation.
Article 25: Nationality as a point of leverage
Article 25 §1 d of the convention stipulates that France may tax its nationals residing in Andorra as if the convention did not exist. The Senate report of December 2014 notes that such taxation based on nationality deviates from the residency principle of French law (Article 4 A of the French General Tax Code) and the OECD model, and that the precedent is the Franco-Monegasque convention of 1963. The Secretary of State stated at the time that this reference was "without legal effect" and that no such proposal existed. The rapporteur called for a national debate before any application, or the removal of the clause. A response from the Ministry of the Budget, published in the Official Journal of the National Assembly on May 10, 2016, clarifies that this clause can only be applied if the French legislature adopts a measure to that effect, and that reopening negotiations is not being considered.
For the technician. Convention of 2 April 2013: Article 4 §2 a to d (arbitration), Protocol point 2 (Andorran nationality), Article 18 §2 (public pensions and nationality exception), Article 25 §1 d (nationality clause), Article 13 §5 (other earnings: State of residence of the transferor). Senate, Report No. 185 (2014-2015); Bill No. 2488 (National Assembly); Written Question No. 70097 (Official Journal of the National Assembly of 10 May 2016); Andorran Law 5/2014 on the Income Tax of Natural Persons, Articles 8, 35 and 43. Private pensions are allocated to the State of residence, public pensions to the State that pays them (Senate Report).
3. What this changes in the choice
Three questions to ask before signing a lease
- What is your nationality, and that of your spouse? In Monaco, it is the first question of the convention; in Andorra, it is that of the clause in article 25.
- Since when and without interruption? The Monegasque exceptions are based on dates and continuity.
- What remains of French? Home, property, activity: a single criterion of article 4 B is sufficient to maintain tax residence in France.
Detailed country-specific texts are in the Franco-Monegasque convention and the Franco-Andorran convention ; for living there, living in Monaco and living in Andorra ; for departures, Monaco and Andorra, and the return: returning from Andorra.
Our position
For a Frenchman, the question is not the rate, it's the status
A Monegasque or Andorran project is first assessed based on status: French nationality (arrival after 1962), whether or not it falls outside the scope of the regulations, and what documentation is required; French nationality (residence in Andorra), with a nationality clause that the government stated in 2016 could only be applied through French legislation. Local rates and benefits are secondary considerations, and they are irrelevant if France continues to tax global income. The Monegasque and Andorran domestic law rules cited here are from official sources in both countries; they are verified before each departure.
Related questions
Can a French citizen be a non-resident for tax purposes while living in Monaco? Generally, no: Article 7-1 of the 1963 convention treats the individual in France as if they were domiciled there, for income tax purposes. There are exceptions: presence in Monaco before October 13, 1957, birth in Monaco with continuous residence, or marriage to a Monegasque citizen under the 2003 regulations.
Is a foreigner who moves to Monaco affected? Article 7-1 only applies to French nationality. A resident of foreign nationality is only considered to be connected to France if one of the criteria of Article 4 B of the CGI is met (home, main residence, main activity, center of economic interests).
Is Andorra subject to the same rule as Monaco? No. The tie-breaker is that of a standard convention, but Article 25 §1 d allows France to tax its nationals as if the convention did not exist. The Senate highlighted this clause in 2014, and the government indicated in 2016 that it can only be applied if the French legislature adopts a measure to that effect.
Are you French and considering Monaco or Andorra?
The initial interview aims to determine your nationality, dates of residence, and what aspects of your situation remain French, before any commitment is made. Forty-five minutes, with no obligation.
Are you a notary, chartered accountant, lawyer, or fellow consultant? And a client wants to settle in Monaco or Andorra? We act as a co-contractor on the status and the documents: the client remains yours, we give you the grid of criteria and the list of supporting documents.
Book an appointment
The initial consultation is to establish your exact situation and determine if there is anything that can be done—sometimes there is nothing, and we will say so as well. Thirty minutes, with no obligation.
Book an exchange with Balmont Conseil
Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 23/10/2026.
Official sources consulted
- BOFiP, France-Monaco agreement (BOI-INT-CVB-MCO-10-20210602): https://bofip.impots.gouv.fr/export/pdf/317763
- Senate, report no. 185 (2014-2015) on the France-Andorra convention, general statement: https://www.senat.fr/rap/l14-185/l14-1851.html
- Senate, report no. 185, second part: https://www.senat.fr/rap/l14-185/l14-1855.html
- National Assembly, Bill No. 2488 (France-Andorra Convention): https://www.assemblee-nationale.fr/14/pdf/projets/pl2488.pdf
- Princely Government of Monaco, MonServicePublic, Monegasque taxation: https://monservicepublic.gouv.mc/en/themes/tax/information/general-information/tax-in-monaco
- Government of Andorra, guide to personal income tax 2024: https://www.govern.ad/documents/d/guest/Guia_IRPF_2024
- National Assembly, written question no. 70097 (entry into force of the France-Andorra convention, article 25): https://questions.assemblee-nationale.fr/q14/14-70097QE.htm
- Service-public.gouv.fr, tax domicile: https://www.service-public.gouv.fr/particuliers/vosdroits/F62
