France tax treaty Japan : your property in France

France first (Article 6). Japan also taxes them if you are a permanent resident, then grants a credit, up to the amount of Japanese tax on that income (Article 23 § 2 a).

You are in principle a non-permanent resident. Your rents are taxed in Japan only if they are paid or transferred there. After 5 years of presence out of 10, you become a permanent resident and they are taxed in all cases.

In principle yes, if you have been tax-domiciled in France for at least 2 years in a row and meet the 10-year deadline or the free-availability condition. The BOFiP admits it for a national of a third State protected by a non-discrimination clause, and article 24 § 1 is one. It applies only once. Have this point confirmed by your notary or request a ruling before the sale.

Yes under Japanese rules, but a loss linked to the depreciation of an old building, calculated using the simplified period, can no longer be set against anything since 2021. And depreciation reduces the cost taken into account on resale.

The convention lists it among the French taxes, along with the CRDS, and Article 23 § 2 a provides for the credit subject to Japanese law. The solidarity levy is not mentioned. Have your Japanese adviser confirm how they are treated.

Yes, if your French property is worth more than €1.3M net on 1 January. The treaty does not deal with wealth.

France taxes your French real estate. Japan also taxes the property if the heir is subject to its tax on all assets, which is the case for most heirs domiciled in Japan. No convention governs this overlap: only the credit provided by Japanese law can reduce it.

The SCI does not change the French taxation of rents. It deprives you of the €150,000 exemption on resale and the shares remain taxable in France (Article 13 § 3). Its treatment in Japan has not been checked. The MLI anti-abuse clause also allows a treaty benefit to be denied when obtained through an arrangement of which it is one of the principal purposes. To be studied with a tax specialist from both countries.