Accord fiscal France Taiwan : your property in France

No. An agreement was signed on 24 December 2010 between the representative offices, without treaty status. France applies it through article 77 of the amending finance law for 2010. The content follows that of a convention, but a French law can amend it, and it stops if Taiwan ceases to apply equivalent rules.

France (VI). In Taiwan, they are outside ordinary income tax and enter only the minimum tax, above 1 million Taiwan dollars of foreign income per household and a base of 7.5 million.

Yes, if the gain takes your foreign income and your base above these thresholds. French tax is then set off, up to the increase in tax due to that gain, with an endorsed supporting document.

Perhaps. XXIII of article 77 prohibits treating you less favourably than a French person in the same situation, but the BOFiP refers to a treaty clause, and article 77 is a law. Ask for a written answer before the sale.

Yes, if your French real estate is worth more than €1.3M net on 1 January. Article 77 does not deal with wealth.

France taxes your French real estate, and your other assets if the heir has been domiciled in France for at least 6 of the last 10 years. If the deceased is a national ordinarily residing in Taiwan, Taiwan also taxes these assets, with a credit for French duties, up to the increase in tax due to these assets.

The SCI does not change French taxation of rents. It removes the €150,000 exemption on resale, and the shares remain taxable in France if more than 50% of their value derives from French real estate (XIII). XXVII also withdraws the benefit of article 77 from a transaction one of whose main purposes it is.

A foreigner is one if they stay there at least 183 days in the calendar year. A national registered in the household register is also one, unless they spent less than 31 days there and their centre of vital interests is elsewhere.