France

Research notes

France — family-office tax dossier

Last reviewed: 2026-10-16 Tax year: 2026 Reviewer: research agent (Claude), unreviewed by a tax adviser

Summary

France taxes dividends, interest and gains on securities under the flat tax (PFU) of 31.4% from 2026 (12.8% income tax plus 18.6% social charges, up from 30%), plus the high-income surtax (CEHR, 3%-4%) and the differential contribution (CDHR) that lifts income tax on very high incomes to at least 20%, giving about 38.6% at the top. Real estate wealth above EUR 1.3 million bears the IFI (0.5%-1.5%); financial assets are not subject to wealth tax. Inheritance and gifts to children: EUR 100,000 allowance per child per parent, renewed every 15 years, then 5%-45% (45% above about EUR 1.9 million per child). The impatriate regime (art. 155 B CGI) exempts 50% of foreign passive income for eight years but requires taking up a job or business activity in France.

Residence and eligibility

Art. 4 B CGI: resident if the household (foyer) or main place of stay is in France, or the main professional activity is in France, or the centre of economic interests is in France. Any one test suffices; treaty tie-breakers apply.

• EU/EEA/Swiss free movement (EU): No permit required.
• Long-stay visa 'visiteur' or talent passport (US, OTHER): Visitor visa/residence card for people who will not work in France, with sufficient resources and health insurance; the talent passport (passeport talent) covers investors creating or investing in a French business (economic investment of at least EUR 300,000 historically). Not verified in this session.

Standard regime eligibility: French tax domicile under art. 4 B CGI: home or main place of stay in France, main professional activity in France, or centre of economic interests in France. Non-EU citizens need a long-stay visa or residence permit.

Capital gains

Gains on shares and bonds are taxed under the PFU at 12.8% income tax plus 18.6% social charges = 31.4% (the 18.6% rate applies to gains realised from 2025). Households with reference income above EUR 500,000 (couple) also pay the CEHR of 3% (4% above EUR 1 million), and the CDHR tops income tax up to an average of 20% of reference income above EUR 500,000 (couple), so a large gain of a wealthy household is taxed at about 38.6%. Real estate gains (other than the main home) are taxed at 19% plus 17.2% social charges, with taper relief giving full income tax exemption after 22 years and full social charge exemption after 30 years, plus a surtax of 2%-6% on gains above EUR 50,000.

JSON values: headline rate 38.6% (0.386); listed securities domestic 38.6% (0.386), foreign 38.6% (0.386); private business sale 38.6% (0.386); local real estate 0% (0.0); foreign real estate 0% (0.0).

• How the JSON numbers were derived: PFU 12.8% income tax + 18.6% social charges = 31.4%; CEHR 4% (couple above EUR 1 million) brings income-tax-type levies to 16.8%, and CDHR raises income tax plus CEHR to an average of 20% of reference income, so 20% + 18.6% = 38.6% for a household whose income is mostly investment income. Real estate: 0 because held longer than 30 years (income tax exemption after 22 years, social charges after 30); earlier the rate is up to 19% + 17.2% + 6% surtax + CEHR. Foreign real estate: treaties usually give France the right to tax with a credit for situs tax; same taper.
• Holding periods: None for securities under the PFU. Real estate: taper from year 6, income tax exempt after 22 years, social charges after 30 years.
• Professional-trader risk: Habitual securities trading by a private individual is rarely recharacterised as business income (BNC/BIC); the risk is mainly for real estate dealers (marchand de biens).
• Foreign assets: Worldwide gains taxed; same rates for foreign securities.
• Exemptions and thresholds: No annual allowance for securities gains under the PFU. Main home exempt. Real estate: taper relief, exempt after 30 years. Holding-period allowances (50%/65%/85%) only for shares bought before 2018 and only under the progressive-scale option.
• Eligibility conditions: Resident private investor.
• Regional differences: None.
• Important exceptions / announced changes: Exit tax (art. 167 bis CGI) on leaving France after 6 of the last 10 years of residence, on unrealised gains on shareholdings of at least 50% of a company's profits or securities worth more than EUR 800,000 in total; deferred automatically for moves to the EU/treaty countries and cancelled after 2 years (5 years above EUR 2.57 million) if not sold (details from general knowledge, not re-read). Social charges on investment income are 7.5% only for people insured in another EEA state, Switzerland or the UK.
• Tax year / confidence / verification: 2026 / medium / partially_verified (checked 2026-10-15)
• Sources: France - Individual - Income determination; France - Individual - Taxes on personal income

Update 2026-10-15: the CDHR is confirmed for 2026 income. Art. 224 CGI, as amended by the 2026 Finance Law (loi n° 2026-103 du 19 février 2026, art. 2), applies from 2025 income until the year in which the budget outturn shows a general government deficit below 3% of GDP (BOFiP ACTU-2026-00104, 30 June 2026). Thresholds EUR 250,000 (single) / EUR 500,000 (couple) of reference income; minimum average rate 20%. The 18.6% social-charge rate on investment income from 1 January 2026 is confirmed by Service-Public (F34913).

Dividends

Dividends and interest, French or foreign, are taxed at the PFU of 31.4% from 2026 (12.8% income tax plus 18.6% social charges; 30% before), withheld as a prepayment for French-source income. High-income surtaxes CEHR (3%/4%) and CDHR (20% minimum average income tax) apply on top, giving about 38.6% at the top. Option for the progressive scale (with a 40% dividend allowance) for all investment income if more favourable.

JSON values: headline 38.6% (0.386); domestic 38.6% (0.386); foreign gross 38.6% (0.386); foreign tax relief: credit.

• How the JSON numbers were derived: 12.8% + 18.6% = 31.4% PFU, plus CEHR/CDHR lifting income tax to an average of 20%: 20% + 18.6% = 38.6%. Foreign dividends: treaty withholding (typically 15%) is credited against French income tax, not against social charges. JSON credit_cap 0.128. Treaty withholding on foreign dividends is imputed on the 12.8% flat income tax only (art. 200 A 1°, A: the tax withheld abroad is imputed on the flat-rate tax 'dans la limite du credit d'impot auquel il ouvre droit'), and conventional credits are added back to income tax in the CDHR formula (art. 224 IV A 2°), so with 15% withheld the credit absorbs 12.8 points, not 15: the French tax left on a foreign dividend is 20% + 18.6% - 12.8% = 25.8%, against 23.6% if the whole 15% were credited.
• Outbound withholding: 12.8% on dividends paid to non-resident individuals (25% to non-resident companies, 75% to non-cooperative states), reduced by treaties; 0% to EU parent companies.
• Treaty network: About 120 income tax treaties, one of the largest networks, including the US (count from general knowledge).
• Holding-company notes: A French holding company pays 25% corporate tax; the participation exemption taxes only 5% (or 1% in a tax group) of dividends from holdings of at least 5%. A new tax on non-operating assets held in personal holding companies was debated in the 2026 budget; status not verified.
• Exemptions and thresholds: None under the PFU.
• Eligibility conditions: Resident individual.
• Regional differences: None.
• Important exceptions / announced changes: The 2026 Social Security Financing Law raised CSG on investment income by 1.4 points (social charges 17.2% to 18.6%); real estate income and gains, life insurance and regulated savings stay at 17.2%.
• Tax year / confidence / verification: 2026 / high / verified (checked 2026-10-16)
• Sources: France - Individual - Income determination; France - Individual - Taxes on personal income; France - Individual - Significant developments

Update 2026-10-15: PFU 12.8% income tax + 18.6% social charges from 1 January 2026 confirmed on Service-Public (F34913, revenus 2026); CDHR applies to 2026 income (BOFiP ACTU-2026-00104). Confidence raised to high / verified.

Inheritance and gifts to children

Each child receives EUR 100,000 tax-free from each parent; gifts from the same parent in the previous 15 years use up the allowance. Above it, direct-line rates are 5% to 45% (marginal), with 45% above EUR 1,805,677 of taxable value per child. Worldwide assets are taxed if the deceased lived in France; spouses and PACS partners are exempt. Life insurance (assurance-vie) has a separate regime with an extra EUR 152,500 allowance per beneficiary for premiums paid before age 70.

JSON values: basis beneficiary, bracket mode marginal, children taxed, exemption EUR 100,000, marginal brackets above the exemption: 5% (0.05) from EUR 0, 10% (0.1) from EUR 8,072, 15% (0.15) from EUR 12,109, 20% (0.2) from EUR 15,932, 30% (0.3) from EUR 552,324, 40% (0.4) from EUR 902,838, 45% (0.45) from EUR 1,805,677; other transfer costs 0% (0); gifts same as inheritance: True; tax-free after years: 15.

• Gifts: Gifts use the same EUR 100,000 allowance and 5%-45% scale; the allowance renews every 15 years per parent and child. Plus a EUR 31,865 cash-gift exemption (donor under 80) renewable every 15 years. Gifts of bare ownership with retained usufruct are valued at a discount depending on the donor's age.
• Business relief: Dutreil pact (art. 787 B CGI): 75% of the value of shares in an operating company exempt with collective (2 years) and individual (4 years) holding commitments and a management role; does not apply to holding companies of listed portfolios. Covers listed portfolios: no.
• Foreign assets: Worldwide if the deceased/donor is resident, or the heir has been resident 6 of the last 10 years. Foreign inheritance tax on foreign assets credited (art. 784 A); estate tax treaties with about 35 countries including the US.
• Domicile / residence rules: French domicile (art. 4 B) of the deceased/donor at the time of transfer makes worldwide assets taxable; there is no post-departure tail for the donor, but an heir resident 6 of the last 10 years pays French tax on foreign assets from a non-resident parent.
• Exemptions and thresholds: EUR 100,000 per child per parent (renewed after 15 years); extra EUR 159,325 for a disabled child. Cash gift exemption EUR 31,865 (donor under 80, adult child), renewable every 15 years, cumulative with the allowance.
• Eligibility conditions: Scope: worldwide assets if the deceased/donor is French-resident, or if the heir has been French-resident for at least 6 of the last 10 years; French assets always.
• Regional differences: None.
• Important exceptions / announced changes: Dutreil pact: 75% exemption on qualifying operating businesses with collective and individual holding commitments; not for portfolios. Life insurance: 20%/31.25% after EUR 152,500 per beneficiary for premiums before 70 (art. 990 I CGI; from general knowledge).
• Tax year / confidence / verification: 2026 / high / verified (checked 2026-10-15)
• Sources: Droits de succession : calcul; Droits de donation; France - Individual - Other taxes
• Surviving spouse or PACS partner: exempt from inheritance tax (service-public.fr, CGI art. 796-0 bis).

Wealth tax

IFI (impôt sur la fortune immobilière) is levied on net real estate wealth (direct and indirect, including real estate held through companies and funds, not used for one's own business) when it exceeds EUR 1.3 million on 1 January; the scale then applies from EUR 800,000. Financial assets such as listed shares and bonds are not taxed. A 30% allowance applies to the value of the main home. New residents are exempt on foreign real estate for five years.

JSON type: limited.

• Component IFI - real estate wealth tax (base real_estate_all, bracket mode marginal): allowance EUR 0, entry threshold EUR 1,300,000; brackets: 0% (0.0) from EUR 0, 0.5% (0.005) from EUR 800,000, 0.7% (0.007) from EUR 1,300,000, 1% (0.01) from EUR 2,570,000, 1.25% (0.0125) from EUR 5,000,000, 1.5% (0.015) from EUR 10,000,000. Marginal scale on net taxable real estate value (art. 977 CGI as reported by Service-Public). Entry threshold EUR 1.3 million with decote up to EUR 1.4 million. Base includes real estate held indirectly through companies and funds. JSON main_home_valued_at 0.7: the main home counts at 70% of its value (the 30% allowance).
• Property tax (not a wealth tax): Taxe foncière on all property owners and taxe d'habitation on second homes, set locally; separate from IFI.
• Exemptions and thresholds: Entry threshold EUR 1.3 million; brackets from EUR 800,000; decote between EUR 1.3 million and 1.4 million (EUR 17,500 minus 1.25% of the net value). 30% allowance on the main home (from general knowledge). Real estate used in the taxpayer's own business is exempt.
• Eligibility conditions: Residents: worldwide real estate (except during the newcomer period); non-residents: French real estate.
• Regional differences: None.
• Important exceptions / announced changes: Proposals in the 2026 budget debate to turn IFI into a tax on 'unproductive wealth' and the 2% 'Zucman tax' on fortunes above EUR 100 million were not enacted as far as could be checked (PwC, reviewed April 2026, mentions no such change). New arrivals not resident in the previous five years are exempt on non-French real estate until 31 December of the fifth year after arrival.
• Tax year / confidence / verification: 2026 / high / partially_verified (checked 2026-10-15)
• Sources: Impôt sur la fortune immobilière (IFI); France - Individual - Other taxes

Special regimes

Impatriate regime (art. 155 B CGI) (impatriate_155b)

For people recruited from abroad by a company in France, or who set up a business activity in France, after five years of non-residence: besides relief on employment income, 50% of foreign-source passive income (dividends, interest, gains on foreign securities, royalties) paid by companies in treaty countries with an administrative assistance clause is exempt from income tax, until 31 December of the eighth year after arrival. IFI and inheritance tax are unaffected (IFI already exempts foreign real estate for five years).

• Eligible citizenships: EU, US, OTHER
• Eligibility: Not French tax-domiciled during the five calendar years before the year of taking up the post; employee or listed corporate officer (e.g. SAS president, SA managing director) of a company established in France, recruited from abroad or moved within a group (BOI-RSA-GEO-40-10-10 §§ 10-150); must be French-domiciled through that professional activity. Someone whose only link with France is managing their own wealth is expressly excluded (§ 210). Non-salaried founders fall under a separate branch of art. 155 B that was not checked. The passive-income exemption is personal to the impatriate, not to other household members.
• Duration: 8 years (until 31 December of the eighth calendar year after the year the post was first taken up; a change of role in the same company or group does not extend it; BOI-RSA-GEO-40-10-10 §§ 250-280)
• Sources: BOFiP BOI-RSA-GEO-40-10-10 (11 August 2025): Régime des impatriés - champ d'application et durée; BOFiP BOI-RSA-GEO-40-10-30 (21 June 2017): Impatriés - exonération partielle de certains revenus de source étrangère; BOFiP BOI-RSA-GEO-40-10-30-10 (16 February 2023): Impatriés - revenus passifs, conditions communes

Capital gains under this regime

50% of gains on securities held abroad is exempt from income tax (art. 155 B II CGI); social charges of 18.6% are due on the full gain. Without high-income surtaxes that is 6.4% + 18.6% = 25%, but for a household with reference income above EUR 500,000 the CDHR tops income tax up to 20% of reference income, so the effective rate is about 28.6% (if the exempt half is left out of reference income) to 38.6% (if it is included).

JSON values: headline rate 38.6% (0.386); listed securities domestic 38.6% (0.386), foreign 28.6% (0.286); private business sale 38.6% (0.386); local real estate 0% (0.0); foreign real estate 0% (0.0).

• How the JSON numbers were derived: Foreign listed securities: 12.8% income tax on 50% = 6.4%, raised by CDHR to 20% of reference income; if only the taxable half is in reference income that is 10% of the gain, plus 18.6% social charges on the full gain = 28.6% (lower bound). Without CDHR (household reference income below EUR 500,000) it would be 25.0%. Other items as standard.
• Holding periods: As standard.
• Professional-trader risk: As standard.
• Foreign assets: Foreign-source passive income only.
• Exemptions and thresholds: 50% of qualifying foreign passive income and gains exempt from income tax, for the impatriate only (not the spouse's or children's holdings).
• Eligibility conditions: As regime eligibility. The paying person (for gains: the custodian, or failing that the company whose shares are sold) must be established outside France in a state whose tax treaty with France has an administrative assistance clause (BOI-RSA-GEO-40-10-30-10 § 60). Income collected abroad still qualifies if later transferred to a French account (§ 100).
• Important exceptions / announced changes: Social charges are due on the unreduced amount (BOI-RSA-GEO-40-10-30 § 10). The exempt half is deducted from the CDHR base (art. 224 II 3° CGI), so the JSON uses 28.6% (CDHR applied, exempt half excluded); the CEHR base was not checked for the same exclusion.
• Tax year / confidence / verification: 2026 / low / partially_verified (checked 2026-10-15)
• Sources: BOFiP BOI-RSA-GEO-40-10-30 (21 June 2017): Impatriés - exonération partielle de certains revenus de source étrangère; BOFiP BOI-RSA-GEO-40-10-30-10 (16 February 2023): Impatriés - revenus passifs, conditions communes; BOFiP BOI-RSA-GEO-40-10-10 (11 August 2025): Régime des impatriés - champ d'application et durée

Dividends under this regime

50% of foreign dividends and interest is exempt from income tax; social charges 18.6% on the full amount. 25% without surtaxes; about 28.6% to 38.6% for a household above the CDHR threshold (see capital gains). French dividends taxed as standard.

JSON values: headline 38.6% (0.386); domestic 38.6% (0.386); foreign gross 28.6% (0.286); foreign tax relief: credit.

• How the JSON numbers were derived: Lower bound with CDHR: 10% income tax (20% of the taxable half) + 18.6% social charges = 28.6% on foreign dividends; treaty withholding credited on the taxable part.
• Tax year / confidence / verification: 2026 / low / partially_verified (checked 2026-10-15)
• Sources: BOFiP BOI-RSA-GEO-40-10-30 (21 June 2017): Impatriés - exonération partielle de certains revenus de source étrangère; BOFiP BOI-RSA-GEO-40-10-30-10 (16 February 2023): Impatriés - revenus passifs, conditions communes; BOFiP BOI-RSA-GEO-40-10-10 (11 August 2025): Régime des impatriés - champ d'application et durée

Metrics not listed inherit the standard regime.

Holding structures

Holding company subject to corporate tax (holding_is, structure)

A French SAS or SARL subject to IS holds the listed portfolio. It is the vehicle French families commonly use (société holding patrimoniale). It is scored because, for this family, it cuts the yearly tax bill from about EUR 650,000 to about EUR 540,000 (app profile, payout and running costs included). The saving comes from a lower rate plus deferral of the 18.6% social charges, not from an exemption.

• Gains: portfolio shares (stakes under 5%) are ordinary profit at 25% IS. The long-term regime (88% exempt, 12% quote-part, i.e. 3%) only covers titres de participation: stakes of at least 5% held 2 years (PwC France, income determination and group taxation). JSON: listed domestic and foreign 0.25; private business sale 0.03 (12% x 25%); local real estate 0.25 (no holding-period taper inside a company); foreign real estate null (treaty-dependent). The 3.3% social contribution only applies to IS above EUR 763,000, which this family does not reach.
• Dividends: portfolio dividends are fully taxable at 25%. The parent-subsidiary regime (95% exempt; 99% in a tax group) needs 5% held 2 years. Treaty withholding is credited against IS up to the French tax, so a 15% US withholding leaves 10%. JSON: domestic and foreign 0.25, credit.
• Payout: PFU 31.4% (12.8% + 18.6%, 2026). CEHR and the CDHR only apply above EUR 500,000 of reference income for a couple (art. 223 sexies and 224 CGI). Paying the family EUR 400,000 net needs a gross dividend of about EUR 583,000 (400,000 / (1 - 0.314)), EUR 83,000 over the threshold: the CEHR at 3% on that excess adds about 0.4 point and the CDHR is nil (decote, art. 224 V). 31.4% is used as the rate at today's amounts (payout_tax_rate 0.314); the thresholds are not indexed, so a payout growing with prices drifts up towards 38.6%, which the flat rate does not capture. Repaying contributed capital or a shareholder current account is tax-free; the app does not model this.
• Running costs: the holding's annual running cost is deductible from the company's profit at the 25% IS rate (JSON running_cost_deductible_at 0.25).
• Wealth tax: IFI unchanged (holding shares count only for any real estate inside). Inherits the standard regime.
• Inheritance: the children inherit the shares at the standard 5%-45% rates on net asset value. Dutreil relief excludes passive holdings. Inherits the standard regime.
• 2026 Finance Law (loi n° 2026-103 of 19 February 2026), per Deloitte: (1) new art. 235 ter C CGI. It levies 20% a year on the market value of sumptuary assets (vehicles, yachts, aircraft, jewellery, horses, wines, housing used by the shareholders) held by companies with assets of at least EUR 5m and mainly passive income, for financial years closing from 31 December 2026. The bill first proposed 2% on all non-operating assets, cash and securities included; securities were removed from the base during the debates. A pure portfolio holding is not caught, but the family home must not go into it. (2) Apport-cession (art. 150-0 B ter): reinvestment raised from 60% to 70%, the reinvestment period from 2 to 3 years, and a 5-year holding of the reinvestment.
• Costs: EUR 10,000 a year (accountant, IS return, legal secretariat). No statutory audit: only one of the three thresholds, the balance sheet, is exceeded. Setup about EUR 3,000. These are estimates.
• Exit: an emigrating shareholder pays the art. 167 bis exit tax on the holding shares (EU deferral). On liquidation, the surplus is taxed as a dividend.
• Unverified: the art. 235 ter C text was not read on Légifrance. The IS foreign-tax-credit mechanics and the exit-tax thresholds are from general knowledge.

Company taxation (kept separate from personal tax)

Headline CIT rate in JSON: 25% (0.25).

Standard corporate income tax 25%; 15% on the first EUR 42,500 for SMEs (turnover up to EUR 10 million, at least 75% held by individuals). An exceptional contribution on large companies (turnover EUR 1 billion+ in 2025; extended by the 2026 Finance Law to EUR 1.5 billion+ for one more year, at 20.6%/41.2% of CIT) does not affect a family holding. Participation exemption: 95% of dividends exempt for holdings of at least 5% held two years (from general knowledge).

Special zones: None relevant.

Cost of living notes

Paris (16th, 7th, 6th and 8th arrondissements).

• Prime family rent: EUR 5,839/month. Median asking rent of 5 flats of 165-233 m2 in family areas in and next to Paris, read 2026-10-15: Neuilly-sur-Seine (Foncia: 165 m2 EUR 4,650; 205 m2 EUR 5,839; 233 m2 4 bedrooms EUR 6,000, charges included), Ville-d'Avray (188 m2, 5 bedrooms, EUR 4,990) and Paris 9e (169 m2, 4 bedrooms, EUR 7,297 furnished), the last two on LesiteImmo. Range EUR 4,650-7,297. Paris 15e/16e/17e family flats of 150 m2 or more were almost absent from portals that load; Paris 8e (200 m2, EUR 11,000) left out as prime. Cross-check: OLAP January 2026 median rents are EUR 41/m2 (15e), 43 (17e) and 48 (16e), i.e. about EUR 7,000-8,000 for 165 m2 at the medium-size average. Thin sample; replaces EUR 9,150 from two listings. Source: Foncia, Neuilly-sur-Seine 5 pieces ou plus.
• International school: American School of Paris (Saint-Cloud), Grades 9-12, EUR 41,400 tuition + EUR 2,000 mandatory security fee = EUR 43,400 a year for 2026-27; capital assessment EUR 12,200 and application fee EUR 1,450 once.
• Not sourced: price per m², family health insurance, housekeeper.

Open questions

• (standard / dividends) Whether the treaty credit can also be imputed on the 18.6% social charges was not settled: art. 200 A imputes it on the flat-rate income tax, but the DGFiP notice 2047 describes the credit cap as income tax plus social charges. The 25.8% above assumes income tax only.
• Finance Law 2026 measures on holding companies, Dutreil and IFI should be checked against the promulgated text.
• The 2026 Finance Law was promulgated in February 2026 (PwC corporate page: measures applying from 19 February 2026); its personal-tax measures beyond the CSG increase were not reviewed.
• (standard / capital_gains) Exit tax parameters (art. 167 bis) and real estate taper details were not re-read in the code.
• (standard / capital_gains) Real estate surtax on gains above EUR 50,000 not re-verified.
• (standard / wealth_tax) Status of the 2026 budget proposals on unproductive wealth and holding companies should be re-checked against the promulgated Finance Law 2026.
• (standard / inheritance) Life-insurance allowance (art. 990 I / 757 B) and Dutreil details were not re-read in the code; check for 2026 Finance Law changes to the Dutreil pact.
• (standard / inheritance) Notary fees on a succession (regulated emoluments, mandatory where real estate is involved) were not sourced; other_transfer_cost_rate set to 0.
• (impatriate_155b / capital_gains) Resolved 2026-10-16: art. 224 II 3° CGI deducts the income exempt under art. 155 B from the CDHR base, so the exempt half does not count and the 28.6% lower bound is the right figure. The CEHR base (art. 223 sexies, revenu fiscal de référence) was not checked for the same exclusion.
• (impatriate_155b / capital_gains) The branch of art. 155 B for non-salaried persons (founders bringing an exceptional economic contribution) was not checked.
• (impatriate_155b / dividends) Same CDHR point as capital gains under this regime: resolved by art. 224 II 3° CGI.

US citizens: The US-France income tax treaty gives a special credit for US citizens resident in France on US-source income; CSG/CRDS on investment income have been treated as creditable by the US since the 2019 treaty-related changes (not re-verified). The 1978 US-France estate and gift tax treaty applies.

• Family rent (EUR 5,839) is the median of only 5 flats (3 in Neuilly-sur-Seine, 1 in Ville-d'Avray, 1 in Paris 9e); OLAP per-m2 medians for the 15e/16e/17e suggest EUR 7,000-8,000 for 165 m2, so it may understate a Paris family flat.

Sources

• Code general des impots (consolidated text of 2026-09-01): art. 200 A, 223 sexies, 224 — codes.droit.org (Legifrance open data) (legislation)
• Guide usager: acompte de contribution differentielle sur les hauts revenus (CDHR) — Direction generale des Finances publiques (tax_authority)
• France - Individual - Income determination — PwC Worldwide Tax Summaries (professional)
• France - Individual - Taxes on personal income — PwC Worldwide Tax Summaries (professional)
• France - Individual - Significant developments — PwC Worldwide Tax Summaries (professional)
• Impôt sur la fortune immobilière (IFI) — Service-Public.fr (DILA) (government)
• France - Individual - Other taxes — PwC Worldwide Tax Summaries (professional)
• Droits de succession : calcul — Service-Public.fr (DILA) (government)
• Droits de donation — Service-Public.fr (DILA) (government)
• France - Corporate - Taxes on corporate income — PwC Worldwide Tax Summaries (professional)
• LuxuryEstate.com: luxury properties for rent in Paris (listing sample) — LuxuryEstate.com (other)
• American School of Paris: Tuition and fees 2026-27 — American School of Paris (other)
• BOFiP ACTU-2026-00104: IR - Création d'une contribution différentielle sur les hauts revenus (loi n° 2025-127 art. 10; loi n° 2026-103 du 19 février 2026 de finances pour 2026, art. 2) — Direction générale des Finances publiques (BOFiP-Impôts) (tax_authority)
• Impôt sur le revenu - Revenus d'épargne et de placement - Revenus 2026 — Service-Public.fr (Direction de l'information légale et administrative) (government)
• BOFiP BOI-RSA-GEO-40-10-10 (11 August 2025): Régime des impatriés - champ d'application et durée — Direction générale des Finances publiques (BOFiP-Impôts) (tax_authority)
• BOFiP BOI-RSA-GEO-40-10-30 (21 June 2017): Impatriés - exonération partielle de certains revenus de source étrangère — Direction générale des Finances publiques (BOFiP-Impôts) (tax_authority)
• BOFiP BOI-RSA-GEO-40-10-30-10 (16 February 2023): Impatriés - revenus passifs, conditions communes — Direction générale des Finances publiques (BOFiP-Impôts) (tax_authority)
• Lois de finances pour 2026 (première partie) : analyse des mesures les plus significatives — Deloitte Société d'Avocats (professional)
• France - Corporate - Income determination — PwC Worldwide Tax Summaries (professional)
• France - Corporate - Group taxation — PwC Worldwide Tax Summaries (professional)
• LesiteImmo: location appartement 6 pieces Paris 16 (viewed 15 Oct 2026): https://www.lesiteimmo.com/louer/appartement-6pieces/paris-16-75016
• Location appartement 5 pieces ou plus, Neuilly-sur-Seine — Foncia (other)
• Prix loyer m2 a Paris (OLAP, janvier 2026) — NousGerons (other)
• Location appartement 5 pieces, Neuilly-sur-Seine (LesiteImmo nearby listings: Ville-d'Avray, Paris 9e) — LesiteImmo (other)

Change log

• 2026-10-15: initial research.
• 2026-10-15: CDHR confirmed for 2026 income (BOFiP ACTU-2026-00104; loi n° 2026-103 art. 2) and 18.6% social charges / 31.4% PFU from 1 January 2026 confirmed on Service-Public; dividends raised to high/verified. Art. 155 B regime re-checked on BOFiP (eligibility, 8-year duration, treaty-state condition, full social charges); foreign securities/dividend rate changed from 25% to 28.6% to apply the CDHR consistently with the standard regime (lower bound; still low confidence). Added prime rent (LuxuryEstate sample, EUR 13,400/month) and American School of Paris fee (EUR 43,400, 2026-27).
• 2026-10-15: flagged impatriate_155b as requiring employment or a qualifying activity (requires_qualifying_activity), so it is no longer used as the best regime for a passive investor family unless the user opts in.
• 2026-10-15: added structure regime holding_is (holding company at IS: 25% on portfolio gains/dividends, PFU 31.4% on payouts; 2026 holding tax on sumptuary assets does not reach securities) and a Holding structures section.
• 2026-10-15: family rent re-checked against the upper-middle-class standard: changed from EUR 13,400 to EUR 9,150 (Paris 9e and 8e).
• 2026-10-15: family rent re-checked against the upper-middle-class standard: changed from EUR 9,150 to EUR 5,839 (5 flats of 165-233 m2: Neuilly-sur-Seine, Ville-d'Avray, Paris 9e); still thin.
• 2026-10-16: added surviving-spouse treatment.
• 2026-10-16: foreign-dividend treaty credit clarified (imputed on the 12.8% flat tax only, art. 200 A; added back in the CDHR formula, art. 224 IV A 2°); foreign-dividend credit capped at 12.8 points (credit_cap; French tax left on a foreign dividend 25.8% instead of 23.6%); IFI main home counted at 70%; structure running costs deductible at 25%; art. 155 B CDHR question resolved (exempt half excluded, art. 224 II 3°); holding payout note corrected (a EUR 400,000 net payout needs about EUR 583,000 gross, above the EUR 500,000 CEHR/CDHR threshold).