What non-residents need to know about French tax on property, bank accounts, and cryptocurrency — and how offshore PPLI addresses each one.

The assumption many internationally mobile clients make is a reasonable one: if I don’t live in France, France can’t tax me. For the most part, that is correct. But “for the most part” is doing a lot of work in that sentence. France has a long reach when it comes to assets with a French connection, and the gaps in that assumption — inheritance tax on French property, withholding tax on French income, wealth tax on French real estate above the threshold — can be expensive for clients who have not planned around them.

France imposes succession tax on French real estate at rates up to 60% for non-family beneficiaries — regardless of where the deceased was domiciled. This is not a theoretical risk. It is a bill that arrives after death, with no warning and limited time to pay.

This article addresses three groups of non-resident clients: those who hold French financial assets (bank and brokerage accounts); those who own French property; and those who are planning to move to France and hold cryptocurrency or other investment portfolios they want to protect before residency begins. For each group, offshore PPLI provides a targeted and legally sound response.

Group 1: Non-Residents with French Bank and Brokerage Accounts

Holding a French brokerage account or a French bank account as a non-resident is more expensive than many clients realise. From 1 January 2026, the French tax authority changed its withholding tax procedure for non-residents: French companies now apply the domestic 25% withholding tax rate at source on dividend payments, regardless of the applicable double tax treaty rate. Treaty relief — which may reduce this to 12.8% or 15% depending on the treaty — is then claimed retrospectively via a refund process.

The practical effect: a non-resident receiving a €50,000 dividend from a French equity holding has €12,500 withheld at source. If the treaty rate is lower, they file a refund claim and wait — sometimes for over a year — for the excess to be returned. Meanwhile, the capital is sitting with the French tax authority rather than in their portfolio.

Inside a PPLI policy, the insurer is the direct owner of the portfolio assets. Dividend withholding is managed at the policy level by the insurer and custodian, who handle the treaty reclaim process. The non-resident policyholder’s tax obligation is determined by their country of residence at the point of policy surrender — not by France at each dividend payment date. The annual French withholding friction disappears.

Also relevant:  French bank accounts held by non-residents must be declared to the French tax authorities if there is any French-source income connection. Failure to declare attracts a fine of up to €10,000 per unreported account per year. Assets inside a properly declared PPLI structure replace multiple individual account declarations with a single contract declaration.

Group 2: Non-Residents Who Own French Property

French property is the category where non-resident exposure is most significant — and where PPLI’s role is more nuanced. Let’s be clear at the outset: French real property cannot be held directly inside a PPLI policy. PPLI holds financial assets. So for the property itself, PPLI is not a direct solution.

But French property creates three distinct tax problems, and PPLI addresses two of them:

The SCI and PPLI Structure

For non-residents holding French property through an SCI (Société Civile Immobilière — a French property holding company), there is a structuring opportunity worth understanding. SCI shares are financial assets, not real property. In principle, SCI shares can be held as an asset within a PPLI policy.

The succession tax benefit is significant: SCI shares inside a PPLI policy pass under Article 990I rather than as standard succession assets. For a non-resident’s French holiday property worth €2 million held through an SCI, that shift — from 60% succession tax for a non-family beneficiary to the Article 990I levy of 20–31.25% above the €152,500 exemption — is transformative.

Two important caveats: first, the IFI position is not improved by holding SCI shares in PPLI — French law looks through the SCI to the underlying real estate for IFI purposes, and the PPLI wrapper does not change that analysis. Second, this is a complex structure requiring specialist legal advice from both a French notaire and an international PPLI adviser. It should not be implemented without proper tax opinion.

The French property succession problem is not solved by owning less French property. It is solved by structuring ownership correctly — ideally before the property is acquired, not after.

Group 3: Non-Residents with Cryptocurrency Planning to Move to France

This is the group for whom timing matters most — and where the cost of not acting before the move is highest.

France applies a flat 30% tax (PFU — prélèvement forfaitaire unique) to all cryptocurrency disposals: selling for euros, swapping one coin for another, converting to stablecoins. Every transaction is a taxable event from the day you become a French tax resident. For a client with a €10 million crypto portfolio and a €1 million cost basis, the embedded gain is €9 million — a potential €2.7 million tax liability the moment they begin realising it in France.

If the portfolio is inside a PPLI policy before French residency is established, the position changes fundamentally:

• All subsequent rebalancing, conversion, and diversification inside the policy is tax-neutral — no French PFU on internal transactions
• The policy’s 8-year clock starts running from inception — reaching the qualifying rate of approximately 24.7% before most clients would otherwise begin meaningful withdrawals
• The insurer manages custodial and reporting obligations (CRS, CARF/DAC8) at the policy level
• The gain is ultimately taxed at surrender — but on the policyholder’s terms and timeline, not France’s

The pre-residency window:  The optimal time to establish a PPLI is six to twelve months before establishing French tax residency. This ensures the policy is properly settled, the investment mandate is in place, and the assets are inside the wrapper before French tax jurisdiction attaches. Once residency is established, a transfer of existing direct crypto holdings into PPLI may itself constitute a taxable disposal. Pre-residency structuring avoids this problem entirely.

Jurisdiction Choice for Non-Residents

For non-residents with French asset connections, Luxembourg remains the standard PPLI jurisdiction — it has the deepest recognition in France, the strongest policyholder protection framework, and the most established practice for French-connected clients. Liechtenstein is a strong alternative for clients who require more flexibility in alternative asset allocation.

For clients whose primary asset is cryptocurrency, Mauritius offers direct crypto integration under the VAITOS Act framework — enabling in-kind transfer of Bitcoin and Ethereum to the policy custodian without a forced fiat conversion. Mauritius participates in CRS and CARF, holds investment-grade sovereign ratings, and is on OECD and EU white lists. It is a legitimate, regulated financial centre, not an offshore secrecy jurisdiction.

What PPLI Can and Cannot Do for Non-Residents

The Succession Summary: Article 990I in Numbers

For non-residents with French assets who want to pass wealth to heirs, the difference between PPLI and direct asset ownership is starkest in the succession context. The following illustrates the impact on a non-family beneficiary receiving a €1 million benefit:

The Non-Resident Adviser Conversation

The PPLI conversation for non-residents is different from the resident conversation. Deferral of annual income tax is less central — in many cases, the client’s home country may not impose income tax at all. The value propositions that matter most for non-residents are: succession planning efficiency on French assets; elimination of annual French withholding friction on financial portfolios; and — for clients planning to move to France — the pre-residency structuring window that is only open once.

For advisers working with internationally mobile clients who have French property, French financial connections, or plans to relocate, these conversations belong at the planning table proactively — not reactively after the succession event has occurred or the residency has been established.

The non-resident who structures their French asset connections correctly today is protecting their family from a tax bill they will never have to pay. That conversation happens once. The benefit lasts for generations.