France tax treaty China : your property in France

France first (article 6). China also taxes it at 20% after an allowance, then grants a credit for the tax paid in France, limited to the Chinese tax on that income (article 23 § 2 a). If you are a foreigner with no domicile in China, the 6-year rule may exempt you.

No. The agreement applies to neither Hong Kong, nor Macao, nor Taiwan (BOFiP, § 110). Hong Kong falls under the agreement of 21 October 2010: see the corresponding page.

If you have no domicile in China and any one of the previous 6 years shows fewer than 183 days of presence, or a single departure of more than 30 days, your foreign income paid from abroad is exempt for that year. The count started in 2019.

In principle yes, if you were tax resident in France for at least 2 consecutive years and meet the 10-year deadline or the free-disposal condition. The BOFiP accepts it for a national of a third State protected by a non-discrimination clause, and article 25 § 1 is one. It applies only once. Have your notary confirm this point or request a ruling before the sale.

The Chinese calculation of rental income rests on an allowance of 800 yuan or 20%. In the texts we read, it does not provide for deducting your actual French expenses. Have your Chinese adviser check this point.

This point is not confirmed. France links them to the agreement, but we have not found a Chinese position. Have your Chinese adviser validate how they are treated.

Yes, if your French properties are worth more than €1.3M net on 1 January. The agreement does not deal with wealth.

France taxes your French properties, and your other assets if the heir has been resident in France for at least 6 of the last 10 years. China has no inheritance tax.

The SCI does not change the French taxation of rental income. It removes the €150,000 exemption on resale and the shares remain taxable in France (article 13 § 4, with a 36-month look-back). Its treatment in China has not been checked. The anti-abuse clause of the MLI also allows a treaty benefit to be denied when it was obtained through an arrangement of which this is one of the principal purposes. To be reviewed with a tax specialist in both countries.