France tax treaty Colombia : your property in France

Yes. Signed in Bogota on 25 June 2015, it entered into force on 1 January 2022. It applies to income of 2023 and later years.

France first (article 6). Colombia also taxes it, then deducts the tax paid in France within the limit of the Colombian tax on that income (article 22 § 2 a i and article 254 of the ET).

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 23 § 1 is one. It applies only once. Have your notary confirm this point or request a ruling before the sale.

Yes, on the same conditions. With no French tax, you will have no credit to apply: the Colombian tax on the gain remains due in full.

In principle for the CSG and the CRDS: the treaty covers them, and article 254 accepts foreign tax whatever its name. The treatment of the 7.5% solidarity levy is not confirmed. Have your Colombian adviser validate it.

Both may apply. The IFI covers your French properties above €1.3M net. The Colombian tax covers your assets from 72,000 UVT. The treaty provides that the IFI is deducted from the Colombian tax, within its limit and subject to Colombian law.

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. An heir resident in Colombia also pays the tax on occasional gains, at 15%. No text we read guarantees the deduction of French duties.

The SCI does not change the French taxation of rental income. It removes the €150,000 exemption on resale, the shares remain taxable in France (article 13 § 1 b) and subject to the IFI (article 21 § 1 b), and the Colombian controlled foreign entities regime may apply. Article 26 denies the treaty benefits if one of the principal purposes of the transaction is to obtain them.