Key Takeaways
  • The theoretical 36.2% rate (19% income tax + 17.2% social contributions) is substantially reduced by progressive holding-period allowances
  • Full income tax exemption after 22 years of ownership; full social contributions exemption after 30 years
  • Your primary residence is fully exempt with no time or amount conditions — this is the foundational rule
  • Five optimisation levers can significantly reduce or eliminate the tax on property sales: deductible costs, timing, pre-sale gift, share contribution, and ownership dismemberment

01

How French Real Estate Capital Gains Tax Works

When you sell a property other than your primary residence — a secondary home, a rental investment, shares in a non-listed property company (SCI under income tax regime), or a building plot — the gain realised is subject to a specific tax regime, separate from the progressive income tax scale.

The gross capital gain is calculated simply: sale price minus adjusted acquisition cost. This cost base can be increased by acquisition fees (a flat-rate 7.5% or actual fees if higher), documented renovation works (a flat-rate 15% if held over 5 years, or actual costs with invoices), and certain disposal costs. Maximising the cost base is therefore the first reflex to adopt.

Two separate taxes then apply to this gross gain: income tax (IR) at a flat rate of 19%, and social contributions (PS) at 17.2%. The theoretical total tax burden reaches 36.2% — the starting point, rarely the ending point.

« French real estate capital gains tax is one of the rare forms of capital income where the effective tax rate mechanically decreases over time. Every additional year of ownership has concrete fiscal value. »

Core principle of French real estate tax planning

02

Holding-Period Allowances: The Heart of the System

The French legislature has created a system of progressive allowances that reward long-term ownership. These allowances apply differently depending on whether they relate to income tax or social contributions.

For income tax: the allowance is 6% per complete year of ownership from years 6 through 21 (totalling 96% after 21 years), then 4% in year 22. Full income tax exemption is achieved after 22 complete years of ownership.

For social contributions: the pace is slower: 1.65% per year from years 6 through 21, 1.60% in year 22, then 9% per year from years 23 through 30. Full exemption from social contributions is only achieved after 30 years of ownership.

Cumulative Allowances by Holding Period
Percentage of capital gain exempted — income tax (IR) and social contributions (PS)
5 years — IR

0%

10 years — IR

30%

15 years — IR

60%

22 years — IR

100% exempt

10 years — PS

8.25%

22 years — PS

28%

30 years — PS

100% exempt

Income tax allowance (full exemption at 22 years)
Social contributions allowance (full exemption at 30 years)

The asymmetry between the two allowance schedules is significant. After 22 years, income tax is fully eliminated, but social contributions remain due on 72% of the gain. It is only from year 23 onwards that the 9% annual allowance dramatically accelerates the reduction — making the 22 to 30-year period particularly rewarding in fiscal terms.

03

Full Exemptions Regardless of Holding Period

Beyond progressive allowances, several situations grant full exemption from capital gains tax regardless of how long the property has been held.

The primary residence is the most common and most advantageous case. Capital gains on the sale of your primary residence are fully exempt with no cap and no time condition. The property must constitute your actual and principal home at the time of sale. Effective occupation until the date of completion is therefore essential.

First-time sellers who have not owned their primary residence for at least 4 years may benefit from a partial or full exemption on the sale of another property, subject to reinvestment within 24 months for the purchase or construction of a primary residence.

Sales where the price is below €15,000 are fully exempt, even for secondary homes. This threshold is assessed at the sale price level, not on a pro-rata basis in cases of ownership dismemberment.

Elderly or disabled persons in care homes who meet income conditions may benefit from exemption on the sale of their former primary residence, provided it has not been rented since their departure.

04

Five Levers to Optimise Your Capital Gains Tax

Capital gains tax on real estate is not inevitable. Several levers can significantly reduce its impact, provided sales are anticipated and integrated into a comprehensive wealth management strategy.

Maximise the Cost Base

All renovation works carried out by registered contractors are deductible with supporting invoices. Actual notary fees (if higher than the 7.5% flat rate), connection fees and certain disposal costs further reduce the taxable gain.

→ Direct reduction of the taxable gain

Time the Sale Strategically

Each full year of additional ownership generates a 6% income tax allowance (or 1.65% to 9% for social contributions). Deferring a sale by a few months to cross an anniversary threshold can represent thousands of euros in tax savings at zero additional cost.

→ Immediate fiscal gain, no additional cost

Gift Before Sale

Gifting a property to children prior to selling can effectively wipe out the latent capital gain: the acquisition cost for the recipients is the market value at the date of the gift (as declared in the notarial deed). This strategy combines estate planning with capital gains elimination.

→ Estate transfer + capital gains elimination

Share contribution (Art. 150-0 B ter of the French Tax Code): for properties held through a company subject to corporate tax, contributing the shares to a holding company can allow a deferral of capital gains tax, subject to strict reinvestment conditions. This mechanism is suited to patrimonies structured through IS-regime SCIs or property holding companies, and requires a thorough case-by-case analysis.

Ownership dismemberment: in certain configurations, gifting the bare ownership (nue-propriété) before a sale can reduce the taxable base to the sole value of the usufruct. The bare ownership value, determined by the statutory scale under Article 669 of the French Tax Code, can be significantly lower than the full ownership value. A comprehensive approach considering gift tax and family circumstances is essential before proceeding.

05

Worked Example: Apartment Sold After 18 Years

A practical illustration: an apartment purchased in 2008 for €180,000 including notary fees, sold for €320,000 net in June 2026, with €25,000 of documented renovation works carried out by registered contractors.

Item Amount Detail
Sale price €320,000 Net to seller, excluding agency fees
Acquisition cost (incl. fees) €180,000 Actual notary fees exceed 7.5% flat rate
Deductible works €25,000 Contractors, with supporting invoices
Adjusted cost base €205,000 €180,000 + €25,000
Gross capital gain €115,000 €320,000 − €205,000
IR allowance — 18 years 78% 6% × 13 years (years 6 to 18)
Taxable base IR €25,300 €115,000 × 22%
IR due (19%) €4,807 vs €21,850 without allowance
PS allowance — 18 years 21.45% 1.65% × 13 years
Taxable base PS €90,333 €115,000 × 78.55%
PS due (17.2%) €15,537 vs €19,780 without allowance
Total effective tax €20,344 vs €41,630 theoretical — saving of €21,286

In this example, the holding-period allowances save over €21,000 compared to the theoretical rate. Waiting until 22 years of ownership (i.e. 2030) would have eliminated all income tax entirely (an additional €4,807 saved) and further reduced social contributions. The decision to sell now or defer by a year or two always merits a detailed financial simulation.

Key Takeaways
  • The 36.2% headline rate is substantially reduced by progressive allowances: income tax is eliminated at 22 years, social contributions at 30 years
  • The primary residence is fully exempt — effective occupation until completion is essential to preserve this exemption
  • Maximising the cost base (documented works, actual fees) directly reduces the taxable gain
  • Timing a sale to cross an annual anniversary threshold can generate significant tax savings at zero additional cost
  • Pre-sale gift, share contribution and ownership dismemberment are advanced strategies requiring dedicated wealth management advice

This document is provided for informational purposes only and does not constitute investment advice, a personalised recommendation, or an offer to buy or sell financial products. Past performance is not indicative of future results. All investments carry risk, including the risk of loss of capital. The information in this article reflects Riviera Wealth Management’s analysis as at the date of publication and is subject to change. Riviera Wealth Management is a registered investment adviser (CIF), registered with ORIAS and a member of CNCGP.