«"Alexis, I've been running a factory in Querétaro for four years and I just bought an apartment in Mexico City. My children live in France. What happens if I don't go back?"»
Mexico had 20,643 French citizens registered with the consulate as of December 31, 2025, compared to 20,636 a year earlier: a community perfectly stable, on the 19the world ranking. This stability says something — Mexican expatriates last.
The community has structured itself around industry: Bajío, Querétaro, Monterrey, Mexico City. Many of our contacts have been there for over ten years, have bought property locally, and have children who remained in France. The issue is therefore no longer one of a mission, but rather one of a... durable installation with French fasteners.
The Franco-Mexican framework has a rare singularity and a clear gap. The singularity: the convention of November 7, 1991 abolishes withholding tax on dividends for the benefit of the beneficial owner. The hole: No agreement governs inheritances.. At the house of Balmont Conseil, We start from these two observations verified in the text.
1. Why seek expertise in wealth management In Mexico?
Four realities, in the order in which they affect a sustainable installation.
- Dividends are exempt from withholding tax. Paragraph 1 of Article 10 reserves taxation to the State of residence of the beneficial owner. Few conventions go this far, and this changes the trade-off between distribution and capitalization.
- No text protects your inheritance. The convention only covers income tax. France applies Article 750 ter of the General Tax Code without modification, and Mexico applies its own law to assets located within its territory.
- The deferral of exit tax, however, is a right. Mexico and France have both required clauses—exchange of information and assistance in income tax collection. This is a real advantage, and it distinguishes Mexico from Brazil.
- Mexican real estate triggers the 365-day clause. Article 13 imposes taxation in the state where the gains from securities that derive more than half their value from real estate are located, at any time during the 365 days preceding the transfer. A poorly structured civil society takes advantage of this.
2. The France ↔ Mexico framework in five verified points
Here is the applicable framework, verified in the text of the convention itself and in the annexes of the tax administration as of September 16, 2026.
| French registered in the register | 20,643 as of December 31, 2025 (+0.03 % over one year). |
| Income Convention | Yes — Convention of 7 November 1991, as 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). |
| Convention on Successions | No. No treaty governs inheritance between France and Mexico. Article 750 ter of the French General Tax Code applies without any treaty amendment, and Mexican law also applies. |
| Exit tax — deferral of payment | Automatic payment deferral. Mexico has an information exchange clause and an assistance clause for the recovery of income tax with France. |
| 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 agreement. Paragraph 1 of Article 10 reserves taxation to the State of residence of the beneficial owner, without a cap on withholding tax on the outbound journey. Paragraph 2 reintroduces withholding tax, capped at 5%, in the specific case of a company more than half-owned by residents of third countries. For an executive receiving dividends from their French company, the difference compared to a standard tax treaty is immediately apparent.
The method of elimination, on the other hand, is that of modern conventions. Article 21 grants a tax credit equal to the French tax on the income in question, rather than the exemption with an effective tax rate provided by older agreements. The result is less favorable when local tax is low—the opposite is true for Brazil and Tunisia.
Assistance with recovery does not cover inheritance tax. Appendix BOI-ANNX-000508 recognizes it for income tax and VAT, but not for inheritance tax. The benefit of deferring exit tax therefore does not extend to inheritance matters, which remain unaffected by this agreement.
What we don't display. Details of Mexican domestic tax law—including income tax, state inheritance tax, and local reporting requirements—are not included in this table: we have not verified them in a current primary source. These matters should be addressed with authorized counsel in Mexico, whom we coordinate.
3. Our services: 360° support for expatriates and investors
Three construction sites, based on a long-term installation.
Arbitrage: Distribution or Capitalization
For an executive who owns a French company and resides in Mexico, the elimination of withholding tax on dividends opens up an arbitrage opportunity that most tax havens prohibit. However, this requires establishing beneficial ownership and demonstrating Mexican tax residency.
We calculate both options — distributing or capitalizing — in light of your actual tax liability in both countries, and we document the residency case that makes the benefit enforceable.
- Verification of the status of beneficial owner within the meaning of Article 10.
- Tax residency file enforceable against both administrations.
- Numerical comparison of distribution/capitalization over the actual duration of the stay.
The transfer, in the absence of a succession agreement
This is the blind spot in Mexican cases, all the more sensitive given the lengthy nature of the installations and the growing local assets. No legislation allocates the right to tax: France applies Article 750 ter of the General Tax Code, while Mexico applies its domestic law to assets located within its territory.
We map your assets country by country, we establish the situation of each heir—a child who has remained in France for more than six years changes everything—and we calculate the net burden. Luxembourg assurance-vie contract and the tools of wealth engineering They then look at each other, in light of this calculation.
Real estate, on both sides
Your French assets remain taxable in France: minimum rate for non-residents under Article 197 A of the General Tax Code, option for the average rate when it is more favorable, real estate wealth tax, social security contributions at the full rate of 17.2 %.
On the Mexican side, Article 13 of the convention stipulates that gains from real estate-heavy securities, valued over 365 days, are taxable in the state where the property is located. Therefore, holdings through a company should be assessed before, not after, the acquisition. We are handling all of this with the architecture of your wealth.
4. Methodology: our way of working
We work in four stages, and you know where you are at each stage.
- The initial assessment. We assess your actual situation: composition of assets, project timeline, situation of each member of the household, and tax domicile of your heirs — because it is theirs that dictates, not yours.
- The applicable reference framework. We establish, source by source and with its date, the framework that concerns you. What we do not know, we write "to be confirmed" — never anything else.
- The arbitrations. We present you with the numerical options, along with their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- The follow-up. An annual review, offered free of charge, which verifies that the framework has not changed — the conventions are modified, the attractiveness schemes are eliminated, the thresholds change.
5. What the firm offers you
This is what specifically distinguishes our intervention.
- Sources, not claims. Each item in your file has its reference number and date. You can check. This is the only way to work on a subject where most of the information available online is outdated.
- A single point of contact in France. We coordinate with your local advisors, we do not replace them: the internal tax regulations of the host country are handled by a qualified professional on site. Our role is to maintain overall consistency and to defend the French side of the case.
- Fees that are easy to understand. Firm fees: €500 including VAT per hour. Annual follow-up is included. No hidden kickbacks, no performance-based billing.
Frequently Asked Questions in Mexico
Is there a tax treaty between France and Mexico?
Yes: the convention of 7 November 1991 for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, as amended by the BEPS multilateral convention.
It only covers income taxes. No agreement covers inheritances or gifts.
Will my French dividends be subject to withholding tax?
In principle, no. Paragraph 1 of Article 10 reserves the taxation of dividends solely to the State of residence of the recipient, provided that he is the beneficial owner.
Paragraph 2 reintroduces withholding tax, capped at 5 %, in the specific case of a company more than 50 % in ownership by residents of third countries. Beneficial ownership must be demonstrated; it is not presumed.
Is the deferral of payment of the exit tax automatic for Mexico?
Yes. Mexico has with France the two clauses required by article 167 bis of the general tax code: exchange of information and mutual assistance in matters of collection for income tax.
The stay of execution is therefore automatic, without the need for a tax representative or guarantees. This is what distinguishes Mexico from Brazil, where the stay of execution must be requested.
What happens to my estate if I die in Mexico?
In the absence of a treaty, two systems apply in parallel. France taxes according to article 750 ter of the general 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 within its territory. Furthermore, the mutual assistance in tax recovery recognized between the two countries does not cover inheritance tax: nothing prevents a potential double taxation.
I bought an apartment 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 rental income and capital gains. The partial exemption applies only to those affiliated with a scheme in the European Economic Area, Switzerland, or the United Kingdom.
On a rented property, this item weighs more heavily than income tax itself: it must be included in any return simulation done before departure.
In summary
Mexico offers a rare advantage on dividends, a deferral of exit tax by right, and a complete void on inheritances.
Because the facilities there endure and local wealth is built up, it is precisely the gap in the inheritance process that ultimately becomes costly. This can be addressed while the two estates are still separable.
Firm's fees: €500 including VAT per hour. Annual follow-up is offered.
Let's review your situation
A thirty-minute exchange is enough to assess your inheritance situation and verify whether you are truly entitled to the benefit of Article 10. You can also start with a Free X-ray of your contracts.
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