Wealth & Non-Residents
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Italian Resident in France: Your Obligations on Both Sides

Settled in France while keeping accounts, assets or income in Italy, an Italian national becomes a French tax resident once their home is established there. They are then taxed on their worldwide income and subject to precise reporting obligations, under the cross-watch of the French and Italian administrations thanks to the automatic exchange of information.

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The firm Bensaid Avocats, tax lawyers admitted to the Paris & Geneva Bars. References to official texts (CGI, BOFiP, DAC 2 directive, OECD CRS standard), current as of 1 July 2026.
— In brief
Taxable base
Worldwide income taxed in France
Key forms
2042, 2047, 3916/3916 bis, IFI
Italian accounts
To be reported via form 3916, even if dormant
Penalty
€1,500 per undeclared account per year
Detection
Automatic CRS/DAC2 exchange every year
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Becoming a French Tax Resident

An Italian national who establishes their home in France becomes a tax resident there, regardless of their nationality. The 1989 treaty confirms this logic: it is the permanent home and then the centre of vital interests that determine residence, not the passport. The shift to French residence carries a major consequence: taxation on worldwide income.

In practical terms, all income received in Italy — rent from an apartment in Milan, dividends from an Italian company, a retirement pension, interest on bank accounts — becomes reportable in France, alongside French-source income. The treaty then intervenes to avoid double taxation, through the offset of a tax credit or through exemption depending on the category of income. But the obligation to report everything in France remains full and entire.

This shift is often underestimated by newcomers, who sometimes continue to report certain income only in Italy. The firm, present in Paris and Geneva, secures this transition by mapping out all sources of income and determining, category by category, the competent State under the treaty.

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Issues and obligations

The Forms Not to Be Missed

The form 2042 is the foundation: it gathers all worldwide income. Italian-source income is attached to it via form 2047, dedicated to foreign-source income, which allows it to be reported and then reallocated to the correct headings and the treaty mechanism for eliminating double taxation to be applied. The form 3916 / 3916 bis is the one that generates the most litigation. It requires the reporting of any bank account, digital-asset account, capitalisation or life-insurance contract held abroad, including in Italy. The obligation applies as soon as one is a holder, joint holder or beneficiary of a power of attorney, even on an inactive or low-funded account. A simple Italian current account kept after the move must therefore be reported. In addition comes the IFI for substantial real estate holdings. A resident of France is taxable on their worldwide real estate holdings, Italian assets included, once the net taxable value exceeds 1.3 million euros, the scale applying from 800,000 euros. The family second home kept in Italy falls squarely within this base.

Automatic Exchange: Why Omission Is Detected

France and Italy exchange, every year and automatically, information on the financial accounts of their residents. This mechanism rests on the OECD Common Reporting Standard (CRS), approved on 15 July 2014, and, at European Union level, on the DAC 2 directive (2014/107/EU of 9 December 2014). The two countries are, moreover, co-founders of the initiative, within the group of five early adopters launched in 2013. In practice, the accounts of a French resident held in Italy are transmitted automatically to the French administration each year, and vice versa. The balance, the financial income and the identity of the holder are reported without any action by the taxpayer. This means that an Italian account not reported via form 3916 is easily spotted by simple cross-checking. The penalties are dissuasive: a €1,500 fine per undeclared account per year under article 1736 of the CGI, raised to €10,000 per account where the account is located in a non-cooperative State. Tax reassessments and surcharges may be added to this. The era of banking opacity between European countries is over, and voluntary correction always remains preferable to an audit.

Coming Into Compliance, Step by Step

Correcting a French-Italian situation follows a method. First step: establish the exact date of the shift of tax residence to France, as it determines the years to be corrected and the scope of taxable worldwide income. Second step: list all accounts, contracts and assets held in Italy, including dormant accounts and powers of attorney, in order to prepare the corresponding form 3916 for each year concerned. Third step: reconstitute Italian-source income year by year — rent, dividends, interest, pensions — and apply the 1989 treaty to determine the competent State and any tax credit. Fourth step: file the amended returns (2042, 2047, 3916, and if applicable IFI) and, where necessary, open a dialogue with the administration to frame the surcharges and penalties. This process is best carried out with counsel, both to secure the calculation and to manage the relationship with the administration. The firm Bensaid Avocats, admitted to the Paris and Geneva Bars, assists Italian nationals settled in France throughout this journey, from the initial diagnosis to the filing and follow-up of the correction, also anticipating the succession stakes specific to the French-Italian axis.

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Lead counsel — Me Jonathan Bensaid

Me Jonathan Bensaid, founding partner, advises UHNWIs, family offices, executives and non-residents on international wealth taxation and cross-border compliance. The firm is admitted to the Paris & Geneva Bars.

  • Italian resident in France
  • worldwide income
  • form 3916
  • automatic exchange CRS
  • DAC2
  • IFI
  • tax compliance
— Frequently asked questions

The Essentials for an Italian Resident in France

I am Italian and I live in France: where am I taxed?

If your home is in France, you are a tax resident there, whatever your nationality, and you are taxed there on your worldwide income. Italian income is reported in France, the 1989 treaty then allowing double taxation to be avoided through a tax credit or exemption.

Must I report my Italian bank account that remained open?

Yes. Form 3916 requires the reporting of any account held abroad, including in Italy, even inactive or low-funded, as soon as you are a holder, joint holder or beneficiary of a power of attorney. Omission is penalised at €1,500 per account per year.

Can the French administration see my Italian accounts?

Yes, automatically. Thanks to the OECD CRS standard and the DAC 2 directive, Italy transmits to France each year the information on the financial accounts of its residents. An undeclared account is therefore easily detected by cross-checking.

Is my house in Italy subject to the IFI in France?

Yes, if you are a French tax resident. The IFI covers worldwide real estate holdings once the net taxable value exceeds 1.3 million euros, the scale starting at 800,000 euros. Assets located in Italy are included in the base.

How do I correct several undeclared years?

By first establishing the date of the residence shift, then listing all Italian accounts and income, reconstituting income year by year from a treaty angle, and finally filing the amended returns. Support from a lawyer makes it possible to master the calculation and the dialogue with the administration.

Cité par

Securing Your Position as an Italian Resident in France

Settling one's life in France without neglecting one's Italian ties requires a reporting rigour that the automatic exchange of information makes unavoidable. The firm Bensaid Avocats, present in Paris and Geneva, assists you in determining your residence, correctly reporting your Italian income and accounts, and calmly correcting past years where applicable. An initial discussion makes it possible to assess the stakes and define the way forward.

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Jonathan Bensaid, avocat fondateur

Written by

Me Jonathan Bensaid, avocat fiscaliste, fondateur du cabinet Bensaid Avocats, inscrit aux Barreaux de Paris & Genève.

This content is provided for general information purposes and does not constitute personalised legal or tax advice. The data is current as of 1 July 2026 and is subject to change. Any correction decision must be the subject of an individual analysis by a lawyer.