In summary…
Singapore and Hong Kong no longer levy inheritance tax, and their local tax systems generally exempt foreign-sourced income (under certain conditions in Singapore). However, assets remaining in France continue to be taxed in France: dividends and interest withheld at source, real estate, and sometimes pensions.
The two agreements with France are not identical in every respect, and the biggest risk is not fiscal: it is a household remaining in France, which can cause the departure itself to fail.
«In Singapore, as in Hong Kong, I’ll pay almost nothing.» We hear this from a Lyon-based executive who maintains a rented apartment, a securities account, and company shares in France, with a wife and two children who are finishing the school year. The first half of the sentence is debatable depending on income. The second half implies that the move hasn’t happened yet.
1. What each territory taxes within its own borders
Singapore: Foreign income received in Singapore is generally exempt
A person is a tax resident of Singapore if they reside there during the year preceding the tax year, or are present or employed there for 183 days or more. A resident is not taxed on foreign-source income received there, provided they meet the requirements for the exemption under Singapore law, including the Comptroller of Taxation's judgment that the exemption is beneficial to the taxpayer. The exception to be aware of applies to income received through a partnership established in Singapore. Inheritance tax (estate duty) are removed for deaths occurring from February 15, 2008 onwards.
Hong Kong: Only what is born in Hong Kong is taxed
Hong Kong's tax system is based on source: corporate income tax targets profits "born or derived from Hong Kong", payroll tax follows the place of employment, and property tax (property tax, (15 %) applies to buildings located on the premises. For the purposes of corporate income tax, capital gains from the sale of capital assets and dividends from a company already taxed locally are excluded. Inheritance tax was abolished for deaths effective February 11, 2006.
For the technician. Singapore: Article 2(1) of the’Income Tax Act 1947 (resident); Article 13(7A)(b) (exemption for foreign income received by a resident individual, excluding Singapore partnerships); IRAS (Singapore Tax Administration) guide "Tax Exemption for Foreign-Sourced Income". Hong Kong: Inland Revenue Ordinance (taxes on profits, wages and land); IRD (Hong Kong Revenue Authority) brochure on administered taxes; Revenue (Abolition of Estate Duty) Ordinance 2005.
2. What France retains, according to the convention
Two agreements, two distributions
When you leave France, it ceases to tax your worldwide income but continues to tax income from French sources, within the limits of the applicable tax treaty. The Singapore treaty was signed on January 15, 2015 (in force since June 1, 2016, effective January 1, 2017); the Hong Kong treaty, on October 21, 2010. They differ on important points:
| What remains in France | Singapore | Hong Kong |
|---|---|---|
| Dividends from a French company | 15 %s maximum (5 %s for a company holding at least 10 %s) — art. 10 | 10 % at most — art. 10 |
| Interests of French origin | 10 % at most — art. 11 | 10 % at most — art. 11 |
| Income from a building located in France, including rents | Taxable in France (art. 6) | Taxable in France (art. 6) |
| Capital gains on a building located in France | Taxable in France (art. 13) | Taxable in France (art. 13) |
| Shares of a predominantly real estate company | Taxable in France if more than 50% of the value comes from real estate (art. 13, para. 3) | Same (art. 13) |
| Participation of at least 25 % | No such clause | Taxable gain in the state of the company (Art. 13, para. 3) |
| Other capital gains | Taxable only in the seller's state of residence (Art. 13, para. 4) | Ibid. (Art. 13, para. 5) |
| Private guesthouse of French origin | Taxable only in Singapore (Art. 17) | May be taxed in France, the country of origin (art. 17) |
The last line is the surprising one. For a private pension, Singapore follows the usual rule: only the state of residence taxes it. Hong Kong deviates from this: the pension can be taxed at source. A French retiree doesn't choose between these two territories lightly. On pension income for non-residents, see our article on French pensions for non-residents.
The Hong Kong text adds an article on capital: real estate can be taxed where it is located, other assets only in the state of residence (Article 21). It refers to wealth tax, not inheritance tax, which the excerpts read do not address.
For the technician. Conventional rates are ceilings: the actual French withholding tax is the lower of the domestic rate and the ceiling. France withholds 12.8% of its taxable income on dividends paid to a non-resident individual (Article 119 bis, 2 of the French General Tax Code, CGI), up to the ceiling of the applicable convention; see dividends paid to a non-resident. Capital gains on real estate for non-residents: Article 244 bis A of the French General Tax Code; securities: capital gains on securities held by non-residents. Anti-abuse clauses of conventions as amended by the OECD Multilateral Convention (BEPS, base erosion and protection; principal purpose test).
3. The trap of the household remaining in France
Only one criterion is needed to remain a French resident
French law establishes alternative criteria: the home, the principal residence (at least 183 days in the year), the principal professional activity, and the center of economic interests (Article 4 B of the French General Tax Code). Only one is required. The home is the family. An executive who moves to Singapore while his wife and children remain in Lyon has not relocated his home, regardless of the number of days spent there. Details follow: the three criteria of article 4 B.
The convention remains the deciding factor in cases of dual residency. Both texts begin in the same way: permanent home, then center of vital interests, then habitual residence. They then diverge. With Hong Kong, the focus shifts to nationality (French, or "right of abode" on the Hong Kong side) before the inter-administrative agreement: for a French citizen, this criterion favors France. With Singapore, the focus goes directly to the inter-administrative agreement.
Specifically. What makes the difference is what can be proven. Having housing available in both countries shifts the focus to vital interests: family, children's schooling, work, and assets. Timing is equally important: leaving mid-school year with family remaining works against you.
Example: a French dividend of €40,000
Situation. A French citizen residing in Singapore or Hong Kong receives €40,000 in dividends from a French company in which they hold less than 10% of the share capital. Assumptions: natural person, beneficial owner, internal withholding tax rate of 12.8%, form 5000 filed before payment; illustrative example calculated using the rules in effect on October 23, 2026.
Issue. The dividend is of French origin. France can tax it at source, at the lower of the domestic rate and the ceiling of the treaty.
Strategy. Compare the conventional ceiling to the internal rate that France applies, and decide before any payment whether the securities remain held directly.
Result. Singapore: conventional ceiling of 15 %, higher than the internal rate of 12.8 %, therefore a withholding of 12.8 % of €40,000, i.e. €5,120. Hong Kong: conventional ceiling of 10 %, lower than the domestic rate, therefore a withholding of 10 % of €40,000, i.e. €4,000. Difference: €1,120. Without form 5000 filed before payment, the conventional rate is not applied at source.
Our position
Choose based on proof of residence, not on the displayed rate.
Between the two territories, the tax difference on French assets is only a few percentage points for dividends, and it depends on the pension. The real difference in risk lies elsewhere: a household partially remaining in France can be more expensive than the difference in withholding tax. Three key steps: decide before leaving where the family lives and from when; only keep in France what you are willing to have taxed at source; and compile the supporting documentation from the very first month. Regarding the departure itself: leaving France for Singapore and leaving France for Hong Kong. For life on site: living in Singapore and living in Hong Kong.
Frequently asked questions
Are my capital gains on a French property still taxable if I leave?
Yes. Both conventions I've read leave capital gains on real estate to the state where it is located (Article 13), as do rental income (Article 6). Therefore, capital gains from the sale of French property remain taxable in France, whether you reside in Singapore or Hong Kong.
Do Hong Kong and Singapore levy inheritance taxes?
No. Singapore abolished its inheritance tax for deaths from February 15, 2008, and Hong Kong for deaths from February 11, 2006. Assets located in France, however, remain subject to French rules: see the list of inheritance agreements.
Should an expatriate employee living with their family in Singapore be concerned about Article 4B?
No, not if the household has actually moved. The issue arises when the family remains in France or returns before the end of the year of settlement. Available housing in France is also a factor.
Are you planning a move to Singapore or Hong Kong with assets remaining in France?
The initial consultation is used to list what remains taxable in France, to choose the departure date and composition, and to establish proof of residence. Forty-five minutes, with no obligation.
Are you a notary, chartered accountant, lawyer, or fellow consultant? And one of your clients is leaving for Asia? We work in co-contracting on French residences and wealth properties: the client remains yours.
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
- IRAS — Tax Exemption for Foreign-Sourced Income (e-Tax Guide)
- Singapore Statutes Online — Income Tax Act 1947 (section 2(1), residence)
- Impots.gouv.fr — form 2777-SD (withholding tax on income distributed to non-residents)
- Impots.gouv.fr — notice 2048-IMM (tax payable by non-residents on capital gains from real estate)
- Service-public.gouv.fr — tax domicile (article 4 B of the CGI)
- IRAS — Estate Duty
- IRAS — Singapore/France Convention (text with the multilateral convention)
- Inland Revenue Department of Hong Kong — A Brief Guide to Taxes
- Inland Revenue Department of Hong Kong — Hong Kong / France Convention (summarized text)
- Hong Kong Inland Revenue Department — Conventional rates (France)
- Hong Kong Government — Signing of the agreement with France (October 21, 2010)
