Social contributions for a non-resident: 17.2%, 18.6% or 7.5%?
Rents and capital gains in France: 17.2%, 18.6% for furnished lets or 7.5% if you are affiliated in Europe. Conditions, de Ruyter ruling, claim.
The essentials
- Your French-source rents and property capital gains bear social contributions, even if you live abroad.
- Since the taxation of 2025 income, the CSG on furnished rental income has risen from 9.2% to 10.6%, i.e. 18.6% in total, while unfurnished rents remain at 17.2%.
- If you are affiliated to a social security scheme of the European Economic Area, Switzerland or the United Kingdom, and are not dependent on a French scheme, you only pay the 7.5% solidarity levy.
Which non-resident income bears social contributions?
Since the second amending Finance Act for 2012 (law no. 2012-958 of 16 August 2012), French-source property income of persons resident outside France is subject to social contributions. Two texts cover it: I bis of article L. 136-6 of the Social Security Code for income from buildings located in France, and I bis of article L. 136-7 for capital gains subject to the levy of article 244 bis A of the CGI.
Furnished rental is covered in the same way as unfurnished rental. The Conseil d’État confirmed this on 13 March 2026 (no. 503496) for a couple resident in Switzerland who rented out a furnished villa as a seasonal let: the rents from a building located in France fall within the scope of the levy, even though they come under industrial and commercial profits.
Social contributions combine three contributions: the general social contribution (CSG), the contribution for the repayment of the social debt (CRDS) of 0.5% and the 7.5% solidarity levy (article 235 ter of the CGI). The first two fund social security, the third funds the State budget: this difference explains the whole regime for non-residents affiliated in Europe.
What rates apply since the 2026 social security financing act (LFSS)?
The 2026 social security financing act (law no. 2025-1403 of 30 December 2025, article 12) raised the CSG on investment income from 9.2% to 10.6%. For declared income, such as rents, the increase applies from the taxation of 2025 income, so from the return filed in spring 2026.
The same law keeps the CSG at 9.2% for several types of income, including property income and property capital gains. Furnished rental, taxed in the category of industrial and commercial profits, is not among these exceptions: it therefore rises to 18.6%.
For capital gains on property sold by non-residents affiliated to a social security scheme outside Europe, impots.gouv.fr (page updated on 27 January 2026) and service-public.fr state 17.2%. The wording of the exception does not expressly cite I bis of article L. 136-7, which is the basis for taxing non-residents, and no BOFiP commentary settles the point. Have the rate confirmed by your notary before the sale.
| Component (affiliated outside Europe) | Loyers nus | Furnished rental | Property capital gain |
|---|---|---|---|
| CSG | 9,2 % | 10,6 % | 9.2% (rate stated by impots.gouv.fr and service-public.fr) |
| CRDS | 0,5 % | 0,5 % | 0,5 % |
| Solidarity levy | 7,5 % | 7,5 % | 7,5 % |
| Total | 17,2 % | 18,6 % | 17,2 % |
| Total if affiliated in Europe, Switzerland or the United Kingdom | 7,5 % | 7,5 % | 7,5 % |
Who may pay only the 7.5% solidarity levy?
Since 1 January 2019, persons affiliated to a compulsory social security scheme of another State of the European Economic Area (European Union, Iceland, Norway, Liechtenstein) or of Switzerland are exempt from CSG and CRDS on their French property income and capital gains. They remain liable for the 7.5% solidarity levy.
What counts is social affiliation, not nationality or country of tax residence. A non-resident affiliated to a scheme of a third State, such as the United States, Canada or the United Arab Emirates, pays the full rates.
- Be affiliated, on 31 December of the income year, to a compulsory social security scheme of the European Economic Area or Switzerland.
- Not be dependent on a compulsory French social security scheme.
- United Kingdom, since 1 January 2021: be affiliated to British social security, be a national or legal resident of France, the United Kingdom or a European Union State, and not be dependent on a French scheme.
- Capital gain placed in deferral: affiliation is assessed on the date the capital gain was realised.
What does the de Ruyter case law change?
On 26 February 2015, the Court of Justice of the European Union ruled in the de Ruyter case (C-623/13) that levies on investment income that fund social security fall under the European law coordinating social security schemes. A person affiliated to the social security of another Member State cannot be subject to a second social security legislation. The Conseil d’État drew the consequences on 27 July 2015 (no. 334551).
On 18 January 2018, in the Jahin case (C-45/17), the Court clarified that this protection does not extend to persons affiliated in a third State. The 2019 social security financing act (law no. 2018-1203 of 22 December 2018, article 26) then wrote the exemption from CSG and CRDS into the code, while keeping the solidarity levy, which is allocated to the State budget.
The Conseil d’État confirmed on 13 March 2026 that the solidarity levy remains due from a couple resident in Switzerland on their furnished rents. Since this levy funds the State budget, the administration also applies it to European affiliates: the exemption only covers the CSG and the CRDS.
How do you apply the right rate on your return?
For your rents, tick box 8SH (filer 1) or 8SI (filer 2) on return no. 2042 C, section “8 - Divers”. Keep a certificate of affiliation from your foreign fund: it will be requested in the event of an audit or a claim. For a sale, give this certificate to the notary, who calculates the levies on the capital gain return.
Worked example. Assumptions: two investors each make €10,000 of net property income (unfurnished rental) and, in another case, €10,000 of taxable profit from non-professional furnished rental, for 2025. The first lives in Madrid and is affiliated to Spanish social security. The second lives in Dubai and is affiliated to neither a European nor a French scheme.
- Madrid, location nue : 10 000 × 7,5 % = 750 €.
- Madrid, furnished rental: 10,000 × 7.5% = €750.
- Dubai, unfurnished rental: 10,000 × 17.2% = €1,720.
- Dubai, furnished rental: 10,000 × 18.6% = €1,860, compared with €1,720 before the increase, i.e. €140 more.
- Annual gap between the two profiles for furnished rental: 1,860 − 750 = €1,110.
How do you claim back levies paid in error?
If you met the conditions but did not tick the boxes, file a formal claim through the secure messaging in your impots.gouv.fr account, or by post to the non-resident individuals’ tax office. Attach the certificate of affiliation to the foreign scheme and the tax notice on which the levies appear.
For tax established by notice, the deadline runs until 31 December of the second year following collection. Levies on your 2023 income, collected in 2024, can therefore still be claimed until 31 December 2026. For a capital gain paid at the time of the sale, without a notice, the deadline runs until 31 December of the second year following payment.
Contributions deducted from a salary, a pension or an annuity come under the Social Security Code: they are claimed from the body that deducted them, not from the tax administration.
Frequently asked questions
I am French and I live in Dubai: what rate applies to my rents?
If you are not affiliated to any social security scheme of the European Economic Area, Switzerland or the United Kingdom, you pay the full rates. For an unfurnished rental, the total is 17.2%. For a furnished rental, it is 18.6% since the taxation of 2025 income, because of the CSG increase passed in the 2026 social security financing act.
Does my nationality play a role?
For those affiliated in the European Economic Area and Switzerland, no: only affiliation to a compulsory scheme of one of these States counts, without being dependent on a French scheme. A French person affiliated in Germany benefits from the 7.5% rate, a German affiliated in the United States does not. For the United Kingdom, nationality or legal residence is one of the conditions: France, the United Kingdom or a European Union State.
Does the 18.6% rate already affect my 2025 income?
Yes for furnished rental. Law no. 2025-1403 of 30 December 2025 applies the CSG increase from the taxation of 2025 income, so to income declared in spring 2026. Property income from an unfurnished rental is excluded and stays at 17.2%. If you are affiliated in Europe, Switzerland or the United Kingdom, the increase does not concern you: you stay at 7.5%.
Can my tax treaty exempt me from CSG?
As a general rule, no. The CSG and CRDS exemption for European affiliates rests on the European law coordinating social security schemes, not on tax treaties. The Court of Justice ruled in 2018, in the Jahin case, that a person affiliated in a third State could not rely on it. Read your treaty all the same, and have your situation checked if it refers to these contributions.
Can the 7.5% solidarity levy be challenged?
In practice, no. The Conseil d’État ruled on 13 March 2026 (no. 503496) that a couple resident in Switzerland owed the solidarity levy on the rents of a furnished villa let on a seasonal basis, even though those rents come under industrial and commercial profits. The administration maintains it for European affiliates, because it funds the State budget and not social security. The 7.5% therefore remains due.
Until when can I recover levies paid in error?
For levies established by tax notice, you have until 31 December of the second year following collection. Those on 2023 income, collected in 2024, can be claimed by 31 December 2026 at the latest. Those on 2024 income can be claimed until 31 December 2027. Attach your certificate of affiliation to a European scheme for each year concerned.
Sources
- Légifrance, law no. 2025-1403 of 30 December 2025 on social security financing for 2026, article 12
- Service-public.fr, "Social levies (CSG, CRDS...) on income from assets and investments", non-residents section (checked on 30 June 2026: 17.2% on property income and capital gains, 18.6% on non-professional furnished rentals)
- impots.gouv.fr, 2026 practical brochure, "Main changes" (CSG raised to 10.6%, property income and property capital gains kept at 9.2%, LFSS 2026, art. 12)
- impots.gouv.fr, “Je suis non-résident, suis-je redevable des contributions sociales ?” (boxes 8SH and 8SI, United Kingdom)
- impots.gouv.fr, “Je vends un bien immobilier : comment et à quel taux suis-je imposé ?” (updated on 27 January 2026)
- BOFiP, BOI-RFPI-PVINR-20-20, social contributions of non-residents, EU, EEA, Switzerland and United Kingdom exemption
- Conseil d’État, 13 March 2026, no. 503496
- Court of Justice of the European Union, 26 February 2015, de Ruyter, C-623/13
- Court of Justice of the European Union, 18 January 2018, Jahin, C-45/17
- Conseil d'État, 27 July 2015, no. 334551 (following the de Ruyter judgment of the Court of Justice)
- impots.gouv.fr, “Délais de réclamation”
- BOFiP, BOI-CTX-PREA-10-30, general claim deadline (article R*196-1 of the LPF)
To go further on taxation: Income tax for a non-resident, The tax representative, IFI for a non-resident.
The information on this page is general and does not replace tax, legal or financial advice suited to your situation.
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