“Alexis, I have been running a factory in Querétaro for four years and I have just bought a flat in Mexico City. My children live in France. What happens if I don't go back?”
Mexico has 20,643 French nationals on the consular register at 31 December 2025, compared with 20,636 a year earlier: a community that is perfectly stable, ranked 19e in the world. This stability tells you something — expatriations to Mexico last.
The community has grown up around industry: Bajío, Querétaro, Monterrey, Mexico City. Many of the people we work with have been there for more than ten years, have bought locally and have children who stayed in France. The file is therefore no longer that of a posting, but that of a long-term settlement with ties to France.
The France–Mexico framework has one rare feature and one clear gap. The feature: the treaty of 7 November 1991 removes withholding tax on dividends paid to the beneficial owner. The gap: no treaty covers inheritance. At Balmont Conseil, we start from these two findings, verified in the text.
1. Why seek expert wealth management in Mexico?
Four realities, in the order in which they weigh on a long-term move.
- Dividends are exempt from withholding tax. Paragraph 1 of Article 10 reserves taxation to the State of residence of the beneficial owner. Few treaties go this far, and it changes the choice between distribution and capitalisation.
- No text protects your estate. The convention only covers income tax. France applies Article 750 ter of the General Tax Code without any treaty amendment, and Mexico applies its own law to assets located within its territory.
- The exit tax deferral, on the other hand, applies as of right. Mexico has both required clauses with France — exchange of information and assistance in the recovery of income tax. This is a real comfort, and it sets Mexico apart from Brazil.
- Mexican real estate triggers the 365-day clause. Article 13 allows the State where the property is situated to tax gains on shares deriving more than half their value from immovable property at any time during the 365 days preceding the disposal. A poorly calibrated property-holding company gets caught by it.
2. The France ↔ Mexico framework in five verified points
Here is the applicable framework, verified in the text of the treaty itself and in the tax authorities' annexes as at 16 September 2026.
| French nationals on the register | 20,643 at 31 December 2025 (+0.03% over one year). |
| Income tax treaty | Yes — treaty of 7 November 1991, amended by the BEPS multilateral convention. Dividends: taxable only in the State of residence of the beneficial owner (Article 10, paragraph 1). Interest: capped at 15%, with exemptions (Article 11). |
| Estate tax treaty | No. No treaty governs inheritance between France and Mexico. Article 750 ter of the French Tax Code applies with no treaty adjustment, and Mexican law applies on its side. |
| Exit tax — deferral of payment | Automatic deferral of payment. Mexico has an exchange of information clause and an assistance in recovery clause with France for income tax. |
| CSG and CRDS on property income and capital gains | 17.2%. The exemption from CSG and CRDS applies to members of a social security scheme in the European Economic Area, Switzerland, or the United Kingdom. Mexico does not fall into any of these categories. |
The absence of withholding tax on dividends is the rare feature of this treaty. Paragraph 1 of Article 10 reserves taxation to the State of residence of the beneficial owner, with no withholding tax ceiling on outbound dividends. Paragraph 2 reintroduces taxation at source, capped at 5%, in the specific case of a company more than half owned by residents of third States. For an executive receiving dividends from their French company, the difference from an ordinary treaty is immediate.
The elimination method, however, is that of modern treaties. Article 21 grants a tax credit equal to the French tax on the income concerned, rather than the exemption with effective rate found in older treaties. The result is less favourable when local tax is low — the opposite of Brazil and Tunisia.
Assistance in recovery does not cover gift and inheritance tax. Annex BOI-ANNX-000508 recognises it for income tax and VAT, but not for inheritance tax. The comfort of the exit tax deferral therefore does not extend to inheritance, which remains without a treaty.
What we do not show. The detail of Mexican domestic tax law — ISR, state inheritance taxes, local reporting obligations — is not shown in this table: we have not verified it in an up-to-date primary source. It is handled with a licensed adviser in Mexico, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three workstreams, geared to a long-term stay.
Distribution or capitalisation: the trade-off
For an executive who owns a French company and lives in Mexico, the removal of withholding tax on dividends opens up a trade-off that most destinations rule out. Beneficial owner status must still be established and Mexican tax residence must be demonstrable.
We cost both routes — distributing or capitalising — in the light of your actual tax in both countries, and we document the residence file that makes the advantage enforceable.
- Verification of the status of beneficial owner within the meaning of Article 10.
- Tax residence file that holds up with both tax authorities.
- Costed comparison of distribution and capitalisation over the actual length of your stay.
Passing on your wealth without an estate tax treaty
This is the blind spot of Mexican files, all the more sensitive because stays there are long and local wealth grows. No text allocates the right to tax: France applies Article 750 ter of the French Tax Code, and Mexico applies its domestic law to assets located on its territory.
We map your assets country by country, establish the position of each heir — a child who has stayed in France for more than six years changes everything — and calculate the net cost. The Luxembourg assurance-vie contract and the tools of wealth engineering are then considered in the light of these figures.
Real estate, on both sides
Your French assets remain taxable in France: the non-resident minimum rate under Article 197 A of the French Tax Code, the option for the average rate when it is more favourable, real estate wealth tax, and social charges at the full rate of 17.2%.
On the Mexican side, Article 13 of the treaty allocates to the State where the property is situated gains on shares in property-rich companies, assessed over 365 days. Holding through a company should therefore be calibrated before the acquisition, not after. We handle all of this together with the architecture of your wealth.
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: Mexico
Is there a tax treaty between France and Mexico?
Yes: the treaty of 7 November 1991 for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income, amended by the BEPS multilateral convention.
It covers income taxes only. No treaty covers inheritance or gifts.
Will my French dividends be subject to withholding tax?
In principle, no. Paragraph 1 of Article 10 reserves the taxation of dividends to the State of residence of the recipient alone, provided they are the beneficial owner.
Paragraph 2 reintroduces taxation at source, capped at 5%, in the specific case of a company more than 50% owned by residents of third States. Beneficial owner status has to be demonstrated: it is not presumed.
Is the deferral of payment of the exit tax automatic for a move to Mexico?
Yes. Mexico has, with France, the two clauses required by Article 167 bis of the French Tax Code: exchange of information and mutual assistance in the recovery of income tax.
The deferral therefore applies as of right, with no tax representative and no guarantees to provide. This is what sets Mexico apart from Brazil, where the deferral must be requested.
What happens to my estate if I die in Mexico?
In the absence of a treaty, two systems apply side by side. France taxes under Article 750 ter of the French Tax Code: assets located in France, all assets if you were domiciled there, and all assets received by an heir domiciled in France for at least six of the last ten years.
Mexico applies its domestic law to assets located on its territory. The assistance in recovery recognised between the two countries does not cover gift and inheritance tax either: nothing corrects any double taxation.
I bought a flat in Mexico City through a company: is that a problem?
This depends on the composition of the asset. Article 13 of the convention assigns to the State where the property is located the right to tax gains from securities which derive, directly or indirectly, more than 50% of their value from real estate located in that State, at any time during the 365 days preceding the transfer.
The test focuses on a period, not a date: a structure calibrated on the day of the sale is not sufficient. It must be reviewed before the acquisition.
Will I pay CSG on my French income?
Yes, at the full rate of 17.2% on your French-source property income and real estate capital gains. The partial exemption applies only to people covered by a scheme in the European Economic Area, Switzerland or the United Kingdom.
On a let property, this item weighs more than income tax itself: it must be included in any yield simulation made before departure.
In summary
Mexico offers a rare advantage on dividends, an exit tax deferral as of right, and a complete vacuum on inheritance.
Because stays there last and local wealth builds up, it is precisely the inheritance vacuum that ends up costing. It is dealt with while the two estates can still be separated.
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 gauge your inheritance exposure and check whether the Article 10 advantage is really yours. You can also start with a free contract X-ray.
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