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Villa blanche moderne

Most real estate advisors begin with the property.

We begin with the questions that determine whether the property is the right decision in the first place.

What is your tax residency, and which bilateral convention applies between your country and France ?  What acquisition vehicle is appropriate for your situation — direct ownership, SCI, or a foreign holding structure ?

How will the purchase be financed, and does that structure reduce your IFI exposure ? What is your succession intention, and does the structure reflect it ?

These are not questions that can be answered after the offer is signed. They must be addressed before the search begins. Getting them wrong costs more than the difference between the right property and the wrong one.

Four dimensions of every acquisition

01 · Tax residency and bilateral conventions

France has fiscal conventions with approximately 60 countries. Each one defines how your French property is taxed during your lifetime — income, IFI — and at death. The convention between France and your country of residence determines everything.

The implications vary significantly by nationality. Swiss buyers benefit from specific provisions on capital gains and wealth. British buyers post-Brexit face a changed landscape on residency and succession. Gulf buyers — from the UAE or Saudi Arabia — operate without a bilateral convention with France, which has direct implications for succession tax exposure on French assets.

We identify the applicable framework before any other analysis begins.

02 · Acquisition structure

Direct ownership. SCI at IR or IS. Foreign holding. Each has a different cost profile over the holding period, a different exit scenario, and different succession implications.

The SCI — Société Civile Immobilière — is the most commonly discussed structure for French property acquisition. It is not always the right answer. For a non-resident with a short time horizon and no succession dimension, it adds complexity without proportionate benefit. For a family with multiple heirs and a long holding horizon, it is often the single most important patrimonial decision they will make.

The right structure depends on your residency, your time horizon, your family situation, and your exit intentions. There is no universal answer — only the right answer for your specific case.

03 · Financing and IFI optimisation

In the prime segment above €3M, most buyers are equity-funded or use Lombard credit — borrowing against an existing investment portfolio rather than placing a mortgage charge on the property title.

A correctly structured Lombard facility reduces the IFI base by the outstanding loan amount. On a €4M property with €2M of eligible Lombard debt, the annual IFI saving approximates €25,000. On a €8M property with €4M of debt, the saving exceeds €50,000 per year.

Beyond IFI, Lombard financing preserves liquidity — the investment portfolio continues to perform while the property is acquired. For buyers with concentrated equity positions or managed portfolios at private banks, this flexibility is often more valuable than the rate differential.

We work with private banking partners in Switzerland, Monaco, and Luxembourg to structure financing that serves both the acquisition and the long-term tax position.

04 · Succession and transmission planning

A French property is subject to French succession law regardless of where the owner is domiciled at death — this is the situs rule. It applies whether the owner lives in Geneva, London, Dubai, or Stockholm.

EU nationals can elect for their national law to govern their succession, including their French assets — this election must be made explicitly in a will (Brussels IV Regulation, 2015). Without it, French law applies by default.

French law guarantees children a minimum share of the estate — the réserve héréditaire — that cannot be waived for assets subject to French law. For one child, this is 50% of the estate. For two children, 66%. For three or more, 75%.

The tools that address this — démembrement de propriété, progressive SCI share donations within annual abattements of €100,000 per parent per child, life insurance structures that sit outside the succession estate — must be put in place at acquisition, not at death.

A 20-year framework, not a transaction

The way we think about a property acquisition on the Côte d'Azur is in three horizons.

Years 0 to 5 — acquisition and structure. The right asset, in the right vehicle, with the right annual tax cost. This is where structural errors are most expensive — not on the purchase price, but on the total cost of ownership over the holding period.

Years 5 to 15 — optimisation. How does the asset integrate with the evolution of the overall portfolio? Are there opportunities — progressive SCI share donations to children within annual abattements, partial démembrement, Lombard refinancing to reduce the IFI base? This phase is often neglected because everything is working. It is precisely where the most significant optimisations are built.

Years 15 to 30 — transmission. How does this asset leave the estate in the best fiscal and family conditions? Progressive donations, family pacts, testamentary clauses adapted to the international situation — all of this is prepared now, not at 70.

 

A prime property on the French Riviera is a long-term patrimonial conviction. It deserves to be treated as one from the very first conversation.

For our professional partners

 

We work regularly alongside private banks, family offices, tax attorneys, and notaires who have clients considering a property acquisition on the French Riviera, in Paris, or in Courchevel.

What we offer their clients: off-market access to a portfolio that does not appear anywhere publicly, combined with a patrimonial advisory approach that speaks the same language as their existing advisors.

What we offer their practices: a reliable, professionally credible counterpart who will not compete for the client relationship — and who will make them look good to their clients.

Our partner network currently includes private banking relationships in Switzerland, Monaco, and Luxembourg; tax attorneys specialising in Franco-international patrimonial structures; and notaires with deep experience in high-value cross-border transactions.

If you are a wealth manager, family office, or attorney with clients who may benefit from an introduction to our portfolio or our advisory approach — we would be glad to speak.

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