"Alexis, I've been running a services company from Limassol for two years. My Cypriot accountant handles the local side, but nobody is looking at the French side. That worries me."
Cyprus is home to 1,268 French nationals on the consular register at 31 December 2025: the smallest community in our panel, but also the fastest growth, at +15.48% year on year. The community is concentrated in Limassol and Nicosia, around services, shipping and technology.
It is a destination where half the file is often handled well — the Cypriot side, by a local accountant — and the other half is left untended. Yet it is precisely the French side that carries the risks: an old tax treaty, no estate tax treaty, and a tax residence that mobility can sometimes make uncertain.
At Balmont Conseil, we do not advise on Cypriot law. We cover the French side, and we make sure the two halves of the file are consistent.
1. Why seek expert wealth management in Cyprus?
Four issues, for a move that is often entrepreneurial.
- Effective tax residence. A business run from Cyprus but partly carried on elsewhere raises the question of domicile and, for companies, of the place of effective management. It is the first point to secure, with evidence.
- No estate tax treaty. There is no allocation of the right to tax death benefits between France and Cyprus. Article 750 ter of the French General Tax Code applies without any treaty amendment.
- The European advantages. Exemption from CSG and CRDS for anyone covered by the Cypriot scheme, and automatic deferral of exit tax when leaving for a Member State.
- The 1981 treaty. It is old but well constructed: it includes an article on wealth, allocates pensions to the State of residence and reserves social security pensions for the State that pays them.
2. The France ↔ Cyprus framework in five verified points
Here is the applicable framework, checked against the text of the treaty itself and official sources as at 15 September 2026.
| French nationals on the register | 1,268 at 31 December 2025 (+15.48% year on year), the fastest growth in the panel. |
| Income tax treaty | Yes — treaty of 18 December 1981 (Official Journal of 30 March 1983), covering income and wealth. Pensions taxable in the State of residence (Article 19), except pensions paid under social security legislation, which are taxable in the State that pays them. Dividends: 10% or 15% (Article 10). Interest: 10% (Article 11). |
| Estate tax treaty | None. In the list of treaties concluded by France, Cyprus appears only for income and wealth. |
| Exit tax — deferral of payment | Automatic deferral of payment, no guarantee required. Cyprus is an EU Member State and has the full set of exchange-of-information and recovery-assistance clauses with France. |
| CSG and CRDS on property income and capital gains | 7.5% only. A person covered by a compulsory Cypriot scheme is exempt from CSG and CRDS; only the solidarity levy remains due. Boxes 8SH or 8SI of form 2042 C. |
Article 24 of the treaty is worth knowing. It allocates the taxation of real estate wealth to the State where the property is located, and provides that all other assets are taxable only in the State of residence. For a Cyprus resident who owns property in France, IFI (real estate wealth tax) therefore remains due on the French property alone.
The absence of an estate tax treaty is the core issue. Article 750 ter of the French General Tax Code applies without any treaty adjustment: paragraph 3 makes all assets received by an heir domiciled in France for at least six of the last ten years taxable in France. Article 784 A only allows for a capped offset.
What we do not show. Cypriot tax rates, the regime for non-domiciled persons and the local treatment of a foreign assurance-vie contract are not shown in this table: they fall under Cypriot domestic law and should be checked with a qualified local adviser. We do not reproduce unsourced figures.
3. Our services: 360° support for expatriates and investors
Three workstreams, on the French side.
Securing your tax residence
We draw up a written position on your tax domicile under Article 4 B of the French Tax Code, then under the treaty criteria if there is a conflict: home, principal place of stay, professional activity, centre of economic interests.
For an entrepreneurial activity, we also look at where the effective management of your structures actually lies. This point is often overlooked, and it is decisive.
- A reasoned, dated position on your tax domicile.
- A body of evidence assembled and kept.
- Review of where your structures are effectively managed.
Addressing the inheritance blind spot
In the absence of a treaty, we model the transfer under domestic law alone and quantify the French tax charge, with and without the offset under Article 784 A of the French Tax Code.
The outcome depends on where each of your heirs is domiciled: we note this at the first meeting, before we even discuss your assets.
European advantages and French wealth
We check that your Cypriot social security cover does entitle you to the exemption from CSG and CRDS and that boxes 8SH or 8SI are completed, with a claim for the years not yet time-barred where appropriate.
We monitor your French assets — property income at the minimum non-resident rate under Article 197 A of the French Tax Code, election for the average rate when it is more favourable, IFI (real estate wealth tax) — and we look at the portability of your investment wrappers, in particular the case for a Luxembourg assurance-vie contract taken out under the freedom to provide services.
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: Cyprus
Is there an estate tax treaty between France and Cyprus?
No. The treaty of 18 December 1981 covers income tax and wealth tax. Nothing governs inheritance or gifts.
Shared membership of the European Union changes nothing: France has concluded estate tax treaties with only eight of the twenty-seven Member States, and Cyprus is not one of them.
Am I still liable for IFI (real estate wealth tax) in France?
On your property located in France, yes. Article 24 of the 1981 treaty allocates the taxation of real estate wealth to the State where the property is located.
However, the other components of your wealth are taxable only in your State of residence. It is a standard allocation, but it needs to be applied correctly, particularly where property-rich companies are involved.
Can my Cypriot residence be challenged?
It can, if the facts do not support it. Tax domicile is determined by home, principal place of stay, professional activity and centre of economic interests, within the meaning of Article 4 B of the French Tax Code.
For an entrepreneur whose business is mobile by nature, the question also arises at the level of their structures, through their place of effective management. This is the point we document first.
How do I obtain the CSG exemption on my French income?
By being covered by a compulsory Cypriot social security scheme and declaring it: boxes 8SH or 8SI of form 2042 C, keeping proof of cover on file.
Your French-source property income and property capital gains then bear only the 7.5% solidarity levy, instead of 17.2%.
Do you advise on Cypriot tax?
No, and that is deliberate. Cypriot tax law is handled by a qualified local professional, who takes on liability locally.
Our role is to cover the French side of the file — residence, estate transfer, assets kept in France, social charges — and to make sure the two analyses are consistent with each other. That is where the most costly inconsistencies are found.
In summary
Cyprus is the fastest-growing destination in our panel in relative terms, and the one where the French side of the file is most often neglected.
The European advantages are secured there — CSG exemption, automatic deferral of exit tax. The two issues to address are the robustness of your residence and the absence of an estate tax treaty.
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 check the robustness of your residence and your CSG exemption. You can also start with a free contract X-ray.
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