#Personal Tax Lawyer in France

Personal Tax Lawyer in France

Personal taxation determines the net value of every decision you make about your wealth: filing your income tax return, investing in property, placing your savings, passing on assets, moving abroad, or a dispute with the tax authorities. A flawed analysis or a missed filing can result in a tax reassessment, late-payment interest and penalties. Our firm assists business owners, executives, investors and families with all the taxes and levies that apply to them.

This page sets out our approach to personal taxation in France: income tax, real estate wealth tax, social levies, capital gains tax, gifts and inheritance, expatriation, tax audits and disputes. Every situation is different, and we review yours against the legislation in force at the time you instruct us.

French income tax and how your income is structured

Income tax follows a progressive scale of brackets, set out in Articles 197 et seq. of the French Tax Code (Code général des impôts (in French), CGI). The tax household, the family quotient (quotient familial), the exceptional contribution on high incomes (Article 223 sexies CGI), withholding at source, tax reliefs and their caps must all be brought together in an overall analysis. Property income, industrial and commercial profits, non-commercial profits and investment income each follow distinct regimes.

Investment income is in principle subject to the single flat-rate levy (PFU, the “flat tax”): 12.8% income tax (Article 200 A CGI), plus social levies. For 2026 income, social levies reach 18.6%, as the CSG (generalised social contribution) on investment income rises to 10.6% (Article L. 136-8 of the French Social Security Code (in French)), giving a total of 31.4%. Dividends may, by a global election, be taxed under the progressive scale instead, with a 40% allowance (Article 158 3° CGI). The choice between the PFU and the progressive scale depends on your effective marginal rate and the make-up of your income.

Capital gains on securities and real estate

Capital gains on the sale of securities are taxed under the PFU (12.8% income tax, plus social levies), with an option for the progressive scale (Article 150-0 A CGI). Shares acquired before 2018 may qualify for holding-period allowances if the progressive scale is elected (Article 150-0 D, 1 ter and 1 quater, of the CGI). The tax deferral on a contribution of shares to a holding company subject to corporate income tax (Article 150-0 B ter CGI (in French)) allows the tax to be postponed. If the holding company sells the contributed shares within three years, it must reinvest at least 70% of the sale proceeds in eligible activities, within three years, and keep those investments for at least five years. These rules apply to disposals made since 21 February 2026.

Capital gains on real estate follow a specific regime (Article 150 U CGI): exemption for your main residence, holding-period allowances, with full exemption from income tax after 22 years and from social levies after 30 years. Sales of building land and of property held through a non-trading property company (société civile immobilière) follow particular rules that call for prior analysis.

Real estate wealth tax (IFI)

The IFI (impôt sur la fortune immobilière), established by Article 964 of the CGI, applies to net real estate assets exceeding €1.3 million. The tax base includes property held directly or through companies (SCI, SCPI, shares in companies whose assets are mainly real estate), after deduction of allowable property-related debts. Exemptions (business assets, woods and forests under a management commitment, shares in forestry groups) are strictly regulated.

Our firm maps your assets, classifies them under the applicable rules, structures how they are held and prepares the annual return. In the event of a tax audit or dispute, we defend you before the tax authorities and the tax courts.

Gifts and inheritance in France

Gifts and inheritance involve Articles 777 et seq. of the CGI (scale of duties), 779 (allowances), 790 G (exemption for family gifts of cash) and 784 (recall of earlier gifts for tax purposes). Allowances depend on the family relationship and are renewed every fifteen years. The Dutreil pact (Article 787 B CGI) allows shares in a company carrying on an operating business to be passed on with an exemption on 75% of their value, subject to collective and individual holding commitments.

We advise on the choice between an outright gift, a gift-sharing deed (donation-partage), a gift with retained usufruct, split ownership (démembrement de propriété) and a transfer through a holding company. Each structure has distinct tax, civil-law and estate consequences, which must be assessed against your personal objectives.

Expatriation and international taxation

Changing your tax residence raises several issues: determining your tax domicile (Article 4 B CGI), applying bilateral tax treaties to avoid double taxation, the exit tax on unrealised gains when you leave (Article 167 bis CGI), and reporting obligations (foreign accounts, IFI on French assets, former residence). A French tax resident is taxed on their worldwide income, subject to tax treaties.

We assist expatriates and inpatriates: the specific inpatriate regime of Article 155 B CGI (tax-exempt inpatriation bonus), interaction with the incentive plans of listed companies, repatriation of funds, regularisation of undeclared assets. For individuals subject to a foreign tax regime, coordination with international correspondents allows a consistent approach.

Tax audits and taxpayer defence

The tax authorities have several procedures at their disposal: requests for information (Article L. 10 of the French Tax Procedure Code, Livre des procédures fiscales (in French) or LPF), an in-depth review of an individual’s overall tax position (examen contradictoire de la situation fiscale personnelle, Article L. 12 LPF), desk audits, and a proposed tax reassessment (proposition de rectification, Article L. 55 LPF). The taxpayer has safeguards: time to respond, an appeal to the auditor’s superior (recours hiérarchique), referral to the Direct Taxes Commission (commission des impôts directs), and proceedings before the tax courts.

Penalties vary with the conduct alleged: late-payment interest (Article 1727 CGI), a 10% surcharge for late filing, 40% for deliberate failure, 80% for fraudulent practices or abuse of law (Articles 1728 and 1729 CGI). The most serious cases may lead to criminal prosecution for tax fraud (Article 1741 CGI), punishable by five years’ imprisonment and a €500,000 fine, increased where aggravating circumstances apply. For these cases, see our page tax fraud lawyer in Paris.

Voluntary disclosure and advance tax rulings

Voluntary disclosure (régularisation spontanée) allows you to correct your tax position before the tax authorities take any action. It involves filing amended returns and may, depending on the case, be accompanied by a request for remission (remise gracieuse) or a settlement on penalties. Filed voluntarily before the reassessment period expires and accompanied by payment of the tax, the amended return reduces late-payment interest by 50% (Article 1727 V of the CGI).

The advance tax ruling (rescrit fiscal, Article L. 80 B LPF) offers the highest level of legal certainty: the tax authorities give a written position on the actual situation described, which constitutes a safeguard for you under the conditions laid down by law. We prepare and defend ruling requests for the most sensitive transactions (Dutreil pact, contribution and sale, intra-group agreement, characterisation of income).

How our firm assists you

Our team acts in wealth planning, in structuring transactions (contribution, sale, transfer of wealth, expatriation), and in tax audits and disputes. We work alongside our corporate practice for business owners, and with our tax planning for company directors practice on matters specific to the remuneration and retirement of business owners. For company and group taxation, see tax lawyer in Paris.

Our work draws on the legislation in force, the administrative guidance published in the Official Public Finance Bulletin (Bulletin officiel des finances publiques, BOFiP) and recent case law of the Conseil d’État and the French Supreme Court (Cour de cassation). To present your situation, please contact us via the firm’s contact form.

Taxation of couples: marriage, Pacs and the family quotient

Marriage or a Pacs (French civil partnership) in principle leads to joint taxation of the couple’s income (Article 6 of the French Tax Code). In the year of the union, spouses or partners may opt for separate taxation of their personal income. This choice changes the tax payable by each of them and is worth simulating beforehand.

The family quotient then adjusts the tax to the composition of the household. Each configuration produces different effects, within the applicable caps: minor children, adult children attached to the household, shared custody. Separation, divorce and certain marital situations, by contrast, lead to separate taxation. We help you weigh these options, secure your household’s returns and anticipate the tax consequences of a change in your family situation.

Regularising accounts held abroad

Every individual domiciled in France must declare accounts opened, held, used or closed abroad, together with their income tax return (Article 1649 A of the French Tax Code). Failing this, sums that have passed through these accounts are presumed to be taxable income, unless proven otherwise. Failure to declare also incurs a fine of €1,500 per undeclared account, increased to €10,000 where the account is located in a State that has not concluded an administrative assistance agreement with France (Article 1736 of the CGI).

Voluntary disclosure remains the safest route: filing amended returns, reconstructing assets and income, and dialogue with the tax authorities on penalties. We structure the file, quantify what is at stake and defend your position in the event of a tax audit. Every situation is different: the age of the assets and their origin determine the strategy.

Frequently asked questions

What is the difference between a tax lawyer and a chartered accountant?

The chartered accountant (expert-comptable) keeps the accounts and prepares recurring returns. The tax lawyer advises on legal and tax choices (characterisation, structuring, optimisation), drafts sensitive documents and argues tax disputes. The two professions are complementary; the lawyer’s professional secrecy, established by Article 66-5 of the Law of 31 December 1971, covers all consultations and exchanges.

How can you legally optimise your personal taxes in France?

Legal optimisation relies on detailed knowledge of the applicable regimes and specific schemes: the choice between the PFU and the progressive scale, the use of allowances (holding period, business owners retiring), tax deferral schemes (contribution and sale), preferential regimes (Dutreil), tax-advantaged wrappers (PEA equity savings plan, life insurance). No optimisation can rest on artificial arrangements that would be recharacterised as an abuse of law (Article L. 64 LPF).

How do you declare bank accounts held abroad?

Accounts opened, held, used or closed abroad by an individual domiciled in France must be declared on form 3916, filed with the annual income tax return (Article 1649 A of the CGI). Failure to declare is penalised by a fine and extends the tax authorities’ reassessment period to ten years, unless the total credit balances of these accounts did not exceed €50,000 during the year (Article L. 169 LPF).

What is the Dutreil pact?

The Dutreil pact (Article 787 B of the CGI) is a scheme under which, when shares in a company carrying on an operating business are passed on free of charge (by gift or inheritance), 75% of the value subject to duties is exempt. It requires a prior collective holding commitment of at least two years, an individual holding commitment of six years by each beneficiary (Article 787 B as in force since 21 February 2026), and a management role during the period.

What should you do if you face a personal tax reassessment?

The first step is to analyse the proposed reassessment point by point (facts, provisions relied on, calculations, penalties) and respond within thirty days, a period that can be extended once. If you disagree, several routes are open: an appeal to the auditor’s superior, referral to the competent commission, a prior administrative claim, then proceedings before the tax courts. Early intervention can significantly limit the financial risk.

How is the gain on the sale of your main residence taxed in France?

The gain on the sale of your main residence is exempt from income tax and social levies (Article 150 U II 1° of the CGI), provided the property is actually the seller’s main residence on the day of the sale or, in the case of a delayed sale, the property has remained unoccupied since the move for a reasonable period and the seller has not derived income from it.

What is the French exit tax?

The exit tax (Article 167 bis CGI) taxes unrealised gains on shares held when your tax domicile is transferred outside France, above certain thresholds. A deferral of payment is available: automatic for a move to a European Union State, on request in other cases. The tax is discharged if you return to France or after a holding period, under the applicable rules.

Is an advance tax ruling binding on the tax authorities?

Yes. When the ruling is obtained under the conditions of Article L. 80 B of the LPF and the actual situation matches the facts set out, the tax authorities cannot challenge the position they expressed. The ruling is a powerful tool for securing sensitive wealth transactions (transfer, contribution and sale, characterisation of income).