How much tax will you actually pay on the capital gain from your French property, depending on where you live? This article provides six worked simulations on the same base case — a Paris apartment bought for €400,000 in 2014 and sold for €650,000 in 2026 — covering ACCREDITAX’s six priority countries. The goal: to visualise the tax gap between destinations.
Common base case
- Property: Paris apartment. Acquisition date: 2014. Sale date: 2026. Holding period: 12 years.
- Purchase price: €400,000. Sale price: €650,000.
- Flat-rate acquisition costs (7.5%): €30,000. Flat-rate improvement allowance (15%): €60,000.
- Adjusted acquisition cost: €490,000. Gross capital gain: €160,000.
- CGT abatement (12 years): 7 x 6% = 42%. Taxable gain for income tax: €92,800.
- Social charges abatement: 7 x 1.65% = 11.55%. Taxable gain for social charges: €141,520.
Simulation 1: US resident
- French income tax: 92,800 x 19% = €17,632.
- French social charges: 141,520 x 17.2% = €24,341.
- Surtax (on the portion above €50,000): €856.
- Total French tax: €42,829.
- US side: long-term capital gains (federal rate 15-20% + state tax depending on state). Foreign tax credit applied against US tax liability — in most cases it fully absorbs the French tax owed.
- Practical outcome: French tax is generally the only amount payable; US top-up only where the US tax exceeds the FTC ceiling.
Simulation 2: UK resident (post-Brexit)
- Total French tax identical to the US case: €42,829.
- UK side: Capital Gains Tax at 24% on residential property; foreign tax credit absorbs the French tax. Pre-Brexit, the French total would have been approximately €13,700 lower (EEA regime: 7.5% solidarity levy instead of 17.2%).
Simulation 3: UAE resident (Dubai)
- Total French tax identical: €42,829.
- UAE side: no personal income tax or capital gains tax. No foreign tax credit to activate.
- If the expatriate qualifies for the “first disposal” exemption (€150,000 threshold): the taxable gain for income tax (€92,800) is fully absorbed — income tax = €0. Potential saving: up to €42,000.
Simulation 4: Swiss resident (AVS-affiliated)
- French income tax: 92,800 x 19% = €17,632.
- Solidarity levy 7.5% (instead of 17.2%) on the social-charges taxable gain: 141,520 x 7.5% = €10,614.
- Surtax (on the portion above €50,000): €856.
- Total French tax: €29,102. Saving versus the non-EEA regime: approximately €13,700.
- Swiss side: exemption with maintenance of the “effective rate”. Treatment varies by canton.
Simulation 5: Canadian resident
- Total French tax identical to the US case: €42,829.
- Canadian side: 50% of the capital gain (calculated under Canadian rules) is taxable at the combined federal + provincial marginal rate. Federal foreign tax credit is capped at Canadian tax owed.
- In Quebec, an equivalent mechanism applies with a specific provincial tax credit.
Simulation 6: Australian resident
- Total French tax identical: €42,829.
- Australian side: included in worldwide income at marginal rate, with a 50% CGT discount for assets held more than one year. Foreign income tax offset is capped at Australian tax owed on the reduced base.
- Depending on the Australian marginal rate, the French credit may not be fully usable.
Comparative summary
- Switzerland (AVS-affiliated): approximately €29,100 in France. The EEA advantage absorbs €13,700 versus the non-EEA regime.
- USA, UK, Canada, Australia, UAE without exemption: approximately €42,800 in France, plus potential local taxation (except UAE).
- UAE with “first disposal” exemption: potentially below €5,000 — the largest saving of all six destinations.
These simulations are indicative and assume a straightforward file (no SCI, no split ownership, no partial disposal). For your actual situation, request a personalised comparison.
FAQ – Capital gains tax simulation for non-residents
Why is the French tax identical for the USA, UK, Canada, Australia, and UAE?
Because France applies the same non-EEA regime to all these countries: 19% income tax + 17.2% social charges + any applicable surtax. The difference arises solely on the country-of-residence side (local tax credit).
What about properties held for more than 22 years?
Income tax is fully exempt. Social charges remain due (or the 7.5% solidarity levy for EEA/Switzerland residents), and they are fully exempt at 30 years of ownership.
How do I factor the surtax into a quick simulation?
The surtax only applies above €50,000 of taxable gain for income tax purposes. Its rate ranges progressively from 2% to 6%. In the examples above, it represents less than 2% of total tax.