Non-Resident Property Tax in France: IFI, Capital Gains and Rental Income After You Leave

A property kept in France remains within the scope of French tax after departure, for its income, for holding it and for selling it. The rule is settled: real estate is taxed where it is located, and tax treaties confirm this allocation. What changes with departure is the applicable regime and, often, the amount.

The full path of a departure is set out on our leaving France and tax page.

IFI: French real estate wealth tax for non-residents

Article 964 of the French Tax Code (code général des impôts, CGI) makes individuals not domiciled in France liable to IFI (French real estate wealth tax), but only on their real estate assets and rights located in France. Property held abroad falls outside the tax base.

The threshold remains the same: €1,300,000 of net taxable value, assessed on 1 January. The 30% allowance on the main residence under Article 973 of the CGI no longer applies once the French property ceases to be the taxpayer’s main residence.

The consequence is frequent and counter-intuitive: a household not liable before its departure may become liable afterwards, because the 30% allowance on its former main residence disappears.

Renting out property in France as a non-resident: tax on rental income

Income from real estate located in France is among the French-source income listed in Article 164 B of the CGI. It remains taxable in France, wherever the landlord resides.

The minimum rate of Article 197 A applies: 20% up to the upper limit of the second band of the scale, i.e. €29,579 of net taxable income, then 30% above. The taxpayer may request application of their worldwide average rate when it is lower, by substantiating all of their income.

The choice between unfurnished and furnished letting remains fully relevant: the former falls under rental income (revenus fonciers), the latter under industrial and commercial profits (bénéfices industriels et commerciaux), with different depreciation and deduction rules.

Capital gains tax on a sale by a non-resident

Article 244 bis A of the CGI subjects non-resident individuals to a 19% levy on French-source real estate capital gains, plus social levies. The tax base is determined under the rules applicable to individuals’ capital gains, as for a resident, with the holding-period allowance of Article 150 VC.

The exemption reserved for former residents

Article 150 U, II 2° provides a specific exemption that is often overlooked. It benefits, for the sale of a dwelling located in France, the non-resident seller who is a national of a European Union Member State or of another State party to the Agreement on the European Economic Area that has concluded with France an administrative assistance agreement to combat tax fraud and tax evasion, and who was tax-domiciled in France continuously for at least two years at any time before the sale.

• It is limited to one residence per taxpayer and to €150,000 of net taxable capital gain.
• It applies to sales completed no later than 31 December of the tenth year following the transfer of domicile outside France.
• It applies without any time condition where the seller has had the property at their free disposal since at least 1 January of the year preceding the sale.

This capped exemption is not the same as the main residence exemption, which requires the property to be the main residence on the day of the sale.

The tax representative

Article 244 bis A provides for the appointment of an accredited tax representative, responsible for paying the levy. This obligation does not apply to sellers established in a European Union Member State or in a European Economic Area State bound to France by an administrative assistance and recovery agreement.

For a move to a third country, the cost of the representative is part of the calculation of the transaction.

A worked example

A couple transfers their domicile to Geneva in January 2026. They keep their former main residence in Lyon, valued at €1,450,000 and acquired for €700,000 in 2012, and let it for €34,000 a year.

• IFI: before departure, the 30% allowance brought the value down to €1,015,000, below the threshold. After departure, the property is no longer the main residence: it counts for €1,450,000, above the €1,300,000 threshold. The couple becomes liable to IFI in France.
• Rental income: €34,000 taxable in France. The minimum rate applies: 20% up to €29,579, i.e. €5,915.80, then 30% on the remaining €4,421, i.e. €1,326.30. The minimum tax comes to around €7,242, excluding social levies and before deductible expenses.
• Sale in 2029: the gross capital gain amounts to €750,000 before the holding-period allowance. The exemption under Article 150 U, II 2° may apply up to €150,000 of net capital gain, as the sale takes place before the end of the tenth year following departure, provided that the spouses are nationals of the European Union or the European Economic Area and were domiciled in France for more than two years.
• Tax representative: as Switzerland is neither a member of the European Union nor a party to the European Economic Area, the couple must in principle appoint an accredited tax representative (Article 244 bis A, IV of the CGI).

Sell before or after leaving France?

The question is decided case by case, based on four factors.

1. The main residence exemption requires the property to still be the main residence on the day of the sale. The tax authorities only accept a sale within a normal period, in principle one year, of a home occupied until it was put up for sale and neither let nor lent in the meantime.
2. The exemption under Article 150 U, II 2° only exists after departure, but it is capped at €150,000 of net capital gain.
3. IFI may arise from the departure, through the loss of the 30% allowance.
4. The tax representative adds to the cost of the sale for departures outside the European Union and the European Economic Area.

Key points

• A non-resident remains liable to IFI on their French property only, above €1,300,000, without the main residence allowance.
• French rental income bears a minimum rate of 20%, then 30% above €29,579.
• The exemption reserved for former residents is capped at €150,000 of net capital gain and at one residence per taxpayer.

FAQ

Does a non-resident pay IFI?
Yes, on their real estate assets and rights located in France only, when their net taxable value exceeds €1,300,000 on 1 January. Property held abroad falls outside the tax base.

What rate applies to a non-resident’s real estate capital gain?
A 19% levy under Article 244 bis A of the CGI, plus social levies, on a base determined as for a resident, with the holding-period allowance.

Can the main residence exemption still be used after departure?
In principle, no. It requires the property to be the main residence on the day of the sale, with the tax authorities only accepting a sale within a normal period, without letting in the meantime. The non-resident does, however, have the specific exemption under Article 150 U, II 2°, capped at €150,000 of net capital gain and limited to one residence.

Is a tax representative mandatory to sell?
It is not for sellers established in the European Union or in a European Economic Area State bound to France by an assistance agreement. It may be for others.

Must rent be declared both in France and in the State of residence?
French rental income is taxable in France. The State of residence generally takes it into account according to the method for eliminating double taxation provided for by the treaty, either by exemption with progression or by tax credit.

Deciding what to do with your property

We quantify the effect of departure on IFI, on rental income and on the sale, and we indicate the order of the transactions. See our article on the treatment of gifts with regard to exit tax, the one on inheritance tax and expatriation, the one on tax optimisation and abuse of law, and our tax expatriation practice. Every situation is different and calls for a specific analysis.

Official sources

• Article 964 of the French Tax Code, real estate wealth tax (IFI) – Légifrance (in French)
• Article 973 of the French Tax Code, 30% allowance on the main residence – Légifrance (in French)
• Article 244 bis A of the French Tax Code, levy on non-residents’ real estate capital gains – Légifrance (in French)
• Article 150 U of the French Tax Code, real estate capital gains exemptions – Légifrance (in French)
• Article 150 VC of the French Tax Code, holding-period allowance – Légifrance (in French)
• Article 197 A of the French Tax Code, minimum rate applicable to non-residents – Légifrance (in French)
• Article 164 B of the French Tax Code, French-source income – Légifrance (in French)

This article presents the law for general information purposes, verified at the date of publication. It does not constitute legal advice. Every situation is different and calls for a specific analysis. Content compliant with the professional conduct rules of the legal profession.