For individuals relocating to France with significant property holdings, advance planning around Impôt sur la Fortune Immobilière (IFI) can be essential. Because IFI applies to real estate held both directly and indirectly, the structure of ownership can significantly affect exposure.

In this episode, we explore how IFI works and what planning considerations may arise before establishing French tax residency.

🏠 IFI Looks Through Ownership Structures

IFI is not limited to property held in your personal name.

It can also apply to real estate held through:

• Companies

• Trusts

• Investment funds

• Other legal entities

The tax applies in proportion to the value of underlying real estate assets within the structure.

These rules are set out in the Code général des impôts.

⚖️ Business Asset Exemption

One potential mitigation mechanism exists where the property qualifies as a business asset used in a professional activity.

Under Article 975 of the French Tax Code, certain assets used in qualifying operational businesses may be excluded from IFI.

However, strict conditions apply, including:

• Genuine commercial activity

• Professional involvement

• Property used directly for the business

Passive investment structures generally do not qualify.

📊 Minority Shareholdings

Holding a minority interest in a company does not automatically exempt the investment from IFI.

Instead:

• Only the portion of the company’s value attributable to real estate assets is taken into account.

• Financial assets within the company remain excluded.

IFI therefore requires a look-through valuation approach.

🌍 Pre-Arrival Planning Matters

Because IFI applies once you become a French tax resident, reviewing asset structures before relocating can be important.

Relevant considerations may include:

• Ownership structures

• Nature of property use (investment vs operational)

• Financing arrangements

• Asset allocation between real estate and financial investments

Early planning may help ensure the structure aligns with the French tax framework.

🎯 Key Takeaway

IFI is a targeted wealth tax focused on real estate exposure, whether held directly or through entities.

Before moving to France, it is important to understand:

• How IFI looks through corporate structures

• The limits of minority ownership protection

• When business asset exemptions may apply

• The importance of pre-residency planning

Real estate ownership structures that work in other jurisdictions may produce unexpected results under French IFI rules.