Wealth in several countries, a single architecture.

Written by Alexis Sagnier, financial and real-estate investment adviser, insurance broker, AMF-certified, founder of Balmont Conseil (Lyon). ORIAS 13003497. Last reviewed: 10/18/2026.

Holding company, Luxembourg contracts, property, inheritance: what optimises on one side of a border can cost on the other. We cost the whole before proposing a structure, with lawyers and notaries in each country.

5%is all that is taxed of dividends from a subsidiary at least 5%-owned by a French holding company (Articles 145 and 216 of the French Tax Code).

10%of a foreign entity with a privileged tax regime are enough for its profits to be taxed in France (Article 123 bis of the French Tax Code).

1 lawfor your entire estate: that of your last residence, unless you choose your national law (European Regulation No. 650/2012).

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The issues

Four questions the structure must settle.

Exit taxThe amount on the day of departure, the deferral, and what a holding company changes in the calculation.See the page →International retirementWhich country taxes your pensions, and how to combine entitlements built up in several countries.See the page →International divorceMatrimonial regime, applicable law, division: what the country of residence changes.See the page →Moving abroadWhat happens to your accounts, your contracts and your main residence on the day of departure.See the page →

The tools

What we put together.

Family holding companyConsolidating holdings and reinvesting dividends taxed on 5% of their amount.See the page →Luxembourg assurance-vieA contract that follows the policyholder from one country to another, in several currencies.See the page →Split of ownership (bare ownership / usufruct)Transferring bare ownership and retaining the income: lower duties today.See the page →Company subject to corporation taxOwning real estate or investments through a company taxed at 15% on profits up to €42,500.See the page →

What we check

Before any structure, three checks.

Who taxes what

For each flow — dividends, interest, rent — the treaty says which country taxes and how the other eliminates double taxation.

Anti-abuse rules

A foreign structure without substance falls under Articles 123 bis and 209 B of the French Tax Code, or under abuse of law (Article L. 64 of the French Tax Procedures Code).

Inheritance

The applicable law, the matrimonial regime and the inheritance rights in each country for the heirs.

Frequently asked questions

What clients ask us.

Is a holding company abroad risky?

Not if it has real activity and resources in its country. Without substance, France taxes its profits in your hands (Articles 123 bis and 209 B of the French Tax Code) or sets the arrangement aside for abuse of law (Article L. 64 of the French Tax Procedures Code).

How does the engagement work?

A fixed-price wealth review maps your assets and costs the scenarios. The structuring itself is a bespoke engagement, billed at €500 including VAT per hour, carried out with lawyers and notaries in each country. Contracts taken out are remunerated through insurers' commissions.

Does the European regulation apply outside the Union?

Yes, from the French perspective: Regulation No. 650/2012 designates the applicable law even if you live outside the Union. However, the country where you live applies its own rules: this is where conflicts of law arise.

Are your assets spread across several countries? We check that the whole thing holds together.

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