“Alexis, I am being seconded to Seoul for three years. I am keeping my investments in France. Will Korea tax them?”
During your first years, probably not, as long as the money stays in France. And that is precisely what needs checking: the Franco-Korean treaty excludes from residence people taxed in Korea only on their Korean income. Your status under the treaty is checked before departure.
South Korea has 3,458 French nationals on the consular register as of 31 December 2025 (−2.2% year on year).
The Franco-Korean framework has one advantage: the exit tax benefits from automatic deferral. It also has a gap: no estate tax treaty. At Balmont Conseil, we start from these two verified findings.
1. Why seek expert wealth management in South Korea?
Four points determine your situation.
- The first five years. Korea taxes the foreign income of a foreign resident who has lived there for less than five of the last ten years only if it is paid in or remitted to Korea. Article 4 § 1 of the treaty excludes from residence people taxed only on their local-source income: how the two interact is examined before departure.
- A 1979 treaty, updated in 1991. The 1991 amending protocol replaced the 20% flat-rate tax credit with a credit equal to the tax actually paid: old calculations no longer hold.
- The exit tax is automatically suspended. Korea assists France with tax recovery: deferral is automatic, the return is not.
- Your estate. No convention governs it: France applies article 750 ter of the general tax code, without conventional correction.
2. The France ↔ South Korea framework in five verified points
Here is the applicable framework, checked against official sources as at 1st October 2026.
| French nationals on the register | 3,458 at 31 December 2025 (−2.2% year on year). |
| Income tax treaty | Yes — treaty of 19 June 1979, amending protocol of 9 April 1991, modified by the BEPS multilateral convention. It covers income tax only: IFI (real estate wealth tax) applies under French law alone. |
| Estate tax treaty | No. No convention governs inheritances or gifts between France and South Korea: Article 750 ter of the General Tax Code applies without conventional correction. |
| Exit tax — deferral of payment | Automatic deferral of payment : South Korea assists France with tax recovery (annex BOI-ANNX-000508) and is listed in the notes to the 2026 form 2074-ETD. |
| CSG and CRDS on property income and capital gains | 17.2% on property income and property capital gains, 18.6% on furnished lettings from 2025 income. The reduced rate of 7.5% does not apply. |
On residence. The Korean residence certificate is requested from the National Tax Service. It certifies your residence, but says nothing about the scope of what is taxed in Korea: it is this second point that the treaty looks at.
On your French income. They remain taxed in France, at the minimum rate of 20%, then 30% above €29,579 of net taxable income, or at the average rate if that is more favourable.
On exit tax. Deferral is automatic, but the return is mandatory in the year of departure, then every year while it runs.
What we do not show. The detail of Korean tax is handled with a qualified adviser in Korea, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three workstreams, in the order in which they are decided.
Departure: residence and exit tax
We date your departure from French tax, we examine your situation during the first five years with regard to Article 4 of the convention, and we file the exit tax declaration if your securities exceed €800,000 or if you hold at least 50% of the profits of a company (Article 167 bis of the General Tax Code).
- Tax departure date and Korean residence documents.
- Foreign income paid in or remitted to Korea.
- Exit tax return and monitoring of the deferral.
Your French income and contracts as seen from Seoul
Rents, dividends, assurance-vie: we establish what France continues to tax and what the treaty reduces. A French assurance-vie held by a non-resident no longer bears social charges; its withdrawals are subject to a 12.8% levy, or 7.5% after eight years.
A Luxembourg assurance-vie contract may be considered for long-term mobility, on a case-by-case basis.
Estate transfer without a treaty
We establish what each heir would pay in France, according to their residence and the situation of the assets, and we prepare the gifts before departure.
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: South Korea
Is exit tax deferral automatic for a move to South Korea?
Yes. South Korea assists France with tax recovery (annex BOI-ANNX-000508): payment is suspended without guarantees. Form 2074-ETD remains mandatory in the year of departure, then every year (Article 167 bis of the French Tax Code).
I do not repatriate my French income: am I a Korean resident within the meaning of the treaty?
That is the point to check. Article 4 § 1 of the treaty of 19 June 1979 excludes from residence people taxed in Korea only on their Korean-source income. During your first five years, your Korean tax base depends on what you bring into the country.
Is there an estate tax treaty between France and South Korea?
No. The 1979 convention only covers income tax. France therefore applies Article 750 ter of the General Tax Code, without any treaty amendment.
Is my French rental income still taxed in France?
Yes: 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, plus social charges of 17.2% on unfurnished lettings and 18.6% on furnished lettings from 2025 income.
Does the 20% tax credit still exist?
No. The amending protocol of 9 April 1991 replaced it with a credit equal to the tax actually paid. Any simulation based on the old flat rate needs to be redone.
In summary
South Korea offers automatic exit tax deferral, but no protection for your estate, and a residence position to examine during the first five years.
Everything is prepared before departure: residence, exit tax return and wealth transfer.
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 prepare your departure for Seoul. You can also start with a free contract X-ray.
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