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Moving to France
Moving to France with international assets: what must be decided before you arrive.
As soon as your household is in France, French tax applies to your worldwide income and, on your death, to your worldwide assets. Some decisions can only usefully be taken before the day you move: gifts, choice of law, contracts, holding structures.
What changes on arrival
French tax extends to all your assets.
| Tax | Before the move | After the move |
|---|---|---|
| Income tax | French-source income | Worldwide income, from the date of your move (Article 4 B of the French Tax Code) |
| IFI | Real estate located in France, above €1.3 million | Real estate located in France for 5 years, then worldwide real estate (Article 964 of the French Tax Code) |
| Inheritance and gift tax | Assets located in France | Assets worldwide, up to 45% in the direct line after a €100,000 allowance per child (Article 750 ter of the French Tax Code) |
| Assurance-vie, including foreign contracts | Depending on the country of residence | Withdrawals taxed in France; death benefits taxed above €152,500 per beneficiary (Article 990 I of the French Tax Code) |
| Accounts and contracts abroad | Nothing to declare in France | Declared every year: €1,500 fine per account omitted, €10,000 in a State without an administrative-assistance agreement (Article 1649 A of the French Tax Code) |
The tax treaty between France and your home country may alter these rules: it should be read before the move, not after.
The family
The law governing your matrimonial property regime and your estate can change without you deciding it.
With no marriage contract and no choice of law, the law governing your property changes automatically, for the future, after more than 10 years of residence in France (1978 Hague Convention, Article 7). A choice of law prevents this.
No automatic change: the applicable law remains that of your first common residence, unless the spouses choose otherwise (Regulation (EU) 2016/1103). The choice is made in writing, dated and signed by both spouses.
By default, the law of your last residence applies to the entire estate, including French forced heirship (réserve héréditaire). A will can choose the law of your nationality (Regulation (EU) No 650/2012, Article 22).
The structures
Trusts, companies and foreign contracts: to be declared, and sometimes reviewed.
Declared every year by its trustee, on pain of a €20,000 fine. Its real estate falls within IFI, or bears a 1.5% levy (Article 990 J of the French Tax Code), and its transfers are taxed according to the family relationship (Article 792-0 bis of the French Tax Code).
Held at least 10%, based in a low-tax jurisdiction, with mainly financial assets: its profits are taxed in your hands as income (Article 123 bis of the French Tax Code). Within the European Union, the rule does not apply unless the company is an artificial arrangement.
It can be kept: declared every year, it follows French assurance-vie taxation as soon as you are resident (Article 125-0 A of the French Tax Code). Before arrival, we check whether it is better to keep it, transfer it or surrender it.
Arrival
Working, housing, taking stock.
Frequently asked questions
What clients ask us.
We will not be working in France: does the impatriate regime apply?
No: it is reserved for employees and executives recruited from abroad or transferred to France (Article 155 B of the French Tax Code). Limiting IFI to your assets located in France for 5 years, however, applies to anyone who moves to France after 5 years outside the country (Article 964 of the French Tax Code).
Should we make gifts to our children before moving?
This is the first question to settle. A gift made by a non-resident parent to a non-resident child, of assets located outside France, is not taxed in France (Article 750 ter of the French Tax Code). Made after the move, the same gift is taxed, up to 45% in the direct line. Your home country may also tax it: we check both sides.
In the year of arrival, which income is taxed in France?
Your French-source income up to the date of your move, then all your income, French and foreign, from that date (Article 4 B of the French Tax Code). A single return covers the year. If your home country still regards you as resident, the tax treaty decides between the two.
Our children live outside France: will they be taxed in France on our death?
Yes, if you are domiciled in France when you die: all your assets, wherever they are, fall within French inheritance tax, whatever the heirs' residence (Article 750 ter of the French Tax Code). Tax paid abroad on assets located abroad is credited against the French tax (Article 784 A of the French Tax Code).
