An IFI lawyer helps you declare, justify and defend the value of your real estate assets. The French real estate wealth tax (IFI, impôt sur la fortune immobilière) rests on estimates, and the tax authorities can dispute each of them. A value that is too low exposes you to a tax reassessment. A value that is too high makes you pay tax that you do not owe.
Our tax team, headed by Harry Allouche (Maître), acts before you file your return and during a tax audit. This page sets out the rules of the French Tax Code (CGI) that shape IFI, then the periods within which the tax authorities can revisit your returns. It complements the overall support provided by our firm of tax lawyers. Every situation is different: the explanations below remain general and do not replace an analysis of your file.
Are you liable for IFI in France?
Article 964 of the CGI sets the threshold at which the tax applies. IFI is payable when the value of taxable real estate assets exceeds €1,300,000. For a French tax resident, the article covers assets located in France and outside France. A flat abroad is therefore included in the calculation just like a property in Paris.
Taxpayers sometimes cross the threshold without noticing. A rise in prices, an inheritance or the purchase of a second home is enough. Split ownership raises its own questions, which we cover in our article on split ownership and its effects on IFI. If you have left France and kept a property there, see also our analysis of keeping property in France after moving abroad.
Valuing your properties without exposing yourself
Article 973 of the CGI refers to the rules for inheritance duties to determine the value of properties. In practice, you declare the market value, that is, the price a buyer would pay under normal market conditions. No official scale gives this figure for your property. You must therefore build a sound valuation and keep it on file.
The same article provides a 30% allowance on the market value of your main residence. A couple taxed jointly can apply it to one property only. This allowance does not apply to a second home or a let property. Whether a property qualifies as your main residence therefore deserves careful checking.
A solid valuation file includes recent comparable sales, a precise description of the property and any constraints on it. Poor condition, occupation by a tenant or an easement affect the real price. This dated and sourced evidence carries great weight if the tax authorities dispute your valuation.
Which debts are deductible from IFI?
Article 974 of the CGI strictly governs deductible debts for IFI. A debt is only allowed if it exists on 1 January of the tax year. It must have been incurred and actually borne by the taxpayer. Finally, it must relate to taxable assets.
The article covers in particular debts relating to the following:
- the acquisition of a taxable property;
- repair and maintenance expenses;
- improvement, construction, reconstruction or extension expenses;
- taxes due in respect of the properties, except those borne by the occupier.
Each debt deducted must be supported by evidence. Keep loan repayment schedules, invoices for works and tax notices. A debt that is wrongly allocated or undocumented weakens the whole return in an IFI tax audit. The audit then covers liabilities as much as the value of the properties.
Reduction and cap: two mechanisms to check
Article 977 of the CGI provides for a reduction (décote) when net taxable assets are between €1,300,000 and €1,400,000. The tax is reduced by an amount equal to €17,500 minus 1.25% of those net taxable assets. The reduction decreases as the assets increase and falls to zero at €1,400,000. A fair valuation of a few properties can therefore change the tax significantly in this band.
Article 979 sets a cap. The total of IFI and income taxes cannot exceed 75% of worldwide net income for the previous year. If it does, IFI is reduced by the difference. This mechanism mainly concerns large estates that produce little income.
These two calculations are often overlooked or done incorrectly. They require a precise list of the income and taxes that the article takes into account. An error can work either way and calls for a check before each return.
IFI tax audit and reassessment: how long do the tax authorities have?
The IFI limitation period depends on the quality of your return. The French Tax Procedure Code (Livre des procédures fiscales, LPF) distinguishes two reassessment periods. The shorter one rewards a complete return. The longer one applies when the tax authorities were not properly informed.
The three-year reassessment period
Article L. 180 of the LPF applies if you have met the filing obligation under Article 982 of the CGI. The tax authorities can then exercise their right of reassessment until the end of the third year following the year for which the tax is due. This period assumes that the tax liability was sufficiently disclosed by the return.
The six-year period in the event of omission
Otherwise, Article L. 186 of the LPF provides a reassessment period running until the end of the sixth year following the taxable event. An omitted property or an insufficiently disclosed value can thus give rise to an IFI reassessment over a longer period. A complete return therefore reduces your exposure over time.
Default assessment (taxation d’office)
Article L. 66, 4° of the LPF covers a taxpayer who has not stated the net taxable value in their income tax return. They can be assessed by default for registration duties. Article L. 67 makes this assessment conditional on a formal notice that has not been complied with within thirty days. Once the tax has been assessed by default, Article L. 193 places the burden of proof on the taxpayer who requests its discharge or reduction.
How we assist you
We act at every stage, together with your notary and your usual advisers. Our approach is part of an overall view of your personal tax position, because IFI interacts with your income and your plans to pass on your assets. In practice, we assist you with the following:
- building a valuation file for each property, with supporting evidence;
- analysing your debts in the light of Article 974 and documenting each of them;
- checking the main residence allowance, the reduction and the cap;
- correcting an incomplete return before any action by the tax authorities;
- replying to requests from the tax authorities and challenging a proposed tax reassessment.
In an IFI tax audit, we examine whether the procedure was properly followed, then the merits of the upward adjustments. We dispute the values used by the tax authorities by putting forward your own comparables. Our page on assistance during a tax audit describes the stages of this defence. For an initial discussion of your situation, contact our firm.
Frequently asked questions
Above what value of real estate assets do you have to pay IFI in France?
Article 964 of the French Tax Code (CGI) makes IFI payable when the value of taxable real estate assets exceeds €1,300,000. For a French tax resident, properties located in France and outside France are included in the calculation. A sound valuation of each property tells you whether you cross this threshold.
Which debts are deductible from IFI?
Article 974 of the French Tax Code (CGI) allows debts existing on 1 January, incurred and actually borne by the taxpayer, and relating to taxable assets. It covers in particular acquisition loans, repair, maintenance, improvement or construction expenses, and certain taxes due in respect of the properties. Each debt must be backed by documents.
What is the limitation period for IFI?
If you have met your filing obligation and the tax liability was sufficiently disclosed, Article L. 180 of the French Tax Procedure Code (LPF) limits the reassessment to the end of the third year following the year for which the tax is due. Otherwise, Article L. 186 provides a period running until the end of the sixth year following the taxable event.
What happens if you do not state the value of your assets in your return?
Article L. 66, 4° of the French Tax Procedure Code (LPF) allows an IFI taxpayer who has not stated the net taxable value of their assets in their income tax return to be assessed by default for registration duties. This assessment requires a formal notice that has not been complied with within thirty days (Article L. 67). The burden of proof then lies with the taxpayer (Article L. 193).
How does the IFI cap work?
Article 979 of the French Tax Code (CGI) provides that IFI and income taxes together cannot exceed 75% of worldwide net income for the previous year. If they do, IFI is reduced by the difference. The calculation requires a precise list of the income and taxes taken into account by the article.
Official sources
- Article 964 of the French Tax Code (CGI) (IFI threshold): Légifrance (in French)
- Article 973 of the French Tax Code (CGI) (valuation of assets and main residence allowance): Légifrance (in French)
- Article 974 of the French Tax Code (CGI) (deductible debts): Légifrance (in French)
- Article 979 of the French Tax Code (CGI) (IFI cap): Légifrance (in French)
- Article L. 180 of the French Tax Procedure Code (LPF) (reassessment period for registration duties and IFI): Légifrance (in French)
- Article L. 66 of the French Tax Procedure Code (LPF) (default assessment): Légifrance (in French)
Law as at 1 October 2026. Content written under the responsibility of Harry Allouche (Maître). This content provides general information and is not legal advice. Every situation is different: the firm commits to the means it deploys, with no promise of outcome.
