“Alexis, my group is offering me Singapore or Tokyo for three years. From a tax point of view, is it the same for the assets I keep in France?”
No, and the difference has nothing to do with the local tax rate. It comes down to two texts that are rarely read before leaving: the list of countries that assist France in recovering tax, and the list of treaties that cover estates.
Of the eleven Asian countries in our comparison, none has signed an estate tax treaty with France. And the exit tax is automatically deferred for only four of them: Japan, South Korea, India and Indonesia. For Singapore, Hong Kong, Thailand or Vietnam, guarantees are required.
These eleven countries have 88,042 French nationals on the consular register as at 31 December 2025. At Balmont Conseil, we start from this verified framework, country by country, before discussing investments.
1. What applies across Asia
Four observations, common to all eleven countries, that expatriation guides leave out.
- No treaty protects your estate. France applies Article 750 ter of the French Tax Code: assets located in France, and all assets received by an heir domiciled in France for at least six of the last ten years. The host country applies its own law, with no coordination.
- Exit tax depends on the country, not on you. For a departure with more than €800,000 in securities, or at least 50% of a company's profits, deferral is automatic in four countries, and requires a tax representative and guarantees in the others.
- Your French income remains taxable in France. Rent, property capital gains, dividends: a minimum rate of 20%, then 30% above €29,579 of net taxable income, plus social charges at the full rate, since no Asian country qualifies for the reduced rate of 7.5%.
- Treaties from very different generations. Those with Thailand, Malaysia and the Philippines date from the 1970s; those with China and Singapore from the 2010s. A text from 1974 and one from 2015 are not read the same way: each is read article by article.
2. The eleven-country comparison, verified
Here, for each country, are the four pieces of information that change a wealth planning case, taken from official sources as at 1st October 2026.
| Country | French nationals registered at 31/12/2025 | Tax treaty | Estate tax treaty | Exit tax: deferral |
|---|---|---|---|---|
| Singapore | 11,498 (−5.7 %) | 15 January 2015 — income | None | Subject to guarantees |
| Hong Kong | 9,943 (−0.6%), including Macau | 21 October 2010 — income and wealth | None | Subject to guarantees |
| Japan | 13,125 (+3.7 %) | 3 March 1995, 2007 amendment — income | None | Automatic |
| China | 10,997 (+0.9%), excluding Hong Kong | 26 November 2013 — income | None | To be confirmed: plan for guarantees |
| South Korea | 3458 (−2.2 %) | 19 June 1979, 1991 amendment — income | None | Automatic |
| India | 6893 (−1.9 %) | 29 September 1992 — income and wealth | None | Automatic |
| Indonesia | 3135 (−2.6 %) | 14 September 1979 — income and wealth | None | Automatic for departures since 2025 |
| Malaysia | 2,937 (+1.7 %) | 24 April 1975, 1991 and 2009 amendments — income | None | Subject to guarantees |
| Philippines | 3,029 (stable) | 9 January 1976, 1995 and 2011 amendments — income | None | Subject to guarantees |
| Thailand | 16,070 (+4.8 %) | 27 December 1974 — income | None | Subject to guarantees |
| Vietnam | 6957 (−3.1 %) | 10 February 1993 — income and wealth | None | Subject to guarantees |
“Income and wealth” matters for IFI (real estate wealth tax). Hong Kong, India, Indonesia and Vietnam have a treaty that also covers wealth tax: it allocates the right to tax your assets. Elsewhere, French IFI applies under French law alone, to your property located in France above €1.3 million.
The case of China. The tax authority's annex recognises a recovery-assistance clause with China, but the official notes to the exit tax return do not list it among the countries with automatic deferral. Until the non-residents' tax office has confirmed this in writing, we prepare the file as if guarantees were required.
Singapore and Hong Kong, the two financial centres, require guarantees. This is the point most often discovered too late: an executive leaving with their shares must provide guarantees to avoid paying the exit tax on departure.
3. Our services: 360° support for expatriates and investors
Three workstreams, in the order in which they are decided.
Exit tax, depending on the country of arrival
We calculate your unrealised gains and test the thresholds in Article 167 bis of the French Tax Code before the destination is decided. For Japan, South Korea, India or Indonesia, deferral is automatic; elsewhere, we prepare the file: tax representative, type and amount of guarantees.
- Assessment of unrealised gains and threshold testing.
- Deferral file: tax representative and guarantees, if the country requires them.
- Annual follow-up of the return for as long as the deferral runs.
Your French contracts and investments as seen from Asia
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, which the treaty may reduce. We look, contract by contract, at what to keep, what to surrender before leaving and how the host country will treat it.
For a long expatriation or a move between several countries, a Luxembourg assurance-vie contract may be considered, always in light of local taxation.
Estate transfer without a treaty
We establish, heir by heir, what would be taxed in France and what would be taxed in your host country, then compare scenarios: death during the expatriation, death after returning. Gifts are prepared before leaving, while the French framework is known.
4. Methodology: our way of working
We work in four stages, and at each stage you know where you stand.
- 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.
- 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.
- The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- 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 about expatriation to Asia
Is there an estate tax treaty with any Asian country?
With none of the eleven countries in this comparison. The official list of conventions (BOI-ANNX-000306, updated April 29, 2026) recognizes only conventions on income, and sometimes on wealth. France therefore applies Article 750 ter of the General Tax Code without any treaty-based adjustment.
To which Asian countries is exit tax deferral automatic?
Japan, South Korea and India, plus Indonesia for departures since 2025: these countries assist France in recovering tax. For Singapore, Hong Kong, Malaysia, the Philippines, Thailand and Vietnam, deferral must be requested, with a tax representative and guarantees (Article 167 bis of the French Tax Code).
Is my French rental income still taxed in France?
Yes. It remains taxable in France, 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. On top of this come social charges of 17.2% on unfurnished lettings and 18.6% on furnished lettings from 2025 income.
Is my French assurance-vie still worthwhile from Asia?
It remains worthwhile: a non-resident no longer pays social charges on gains, and the 12.8% or 7.5% levy on withdrawals can be reduced by the treaty. But the host country may tax these gains in its own way: this must be checked country by country, before any withdrawal.
I am leaving for three years: do I need to reorganise everything?
No. A three-year expatriation is prepared as a round trip: you deal with the exit tax, check what happens to your contracts and plan your estate, without undoing what will have to be rebuilt on your return.
In summary
In Asia, it is not the local tax rate that makes the difference: it is the absence of an estate tax treaty, common to all eleven countries, and the exit tax, automatic for only four.
These two points are settled before leaving, together with the fate of your contracts and your French income.
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 place your destination in this comparison. You can also start with a free contract X-ray.
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