International mobility, foreign-source income

Secondary home abroad: reporting the property and the rental income

A house in Spain, a flat in Lisbon, a riad in Marrakech: as long as you are a French tax resident, the property and the income it generates remain within the scope of French tax. Article 4 A of the French tax code subjects individuals domiciled in France to income tax on their worldwide income, French and foreign alike. Ownership alone triggers three obligations: real-estate wealth tax where net worldwide real-estate assets exceed 1,300,000 euros on 1 January, reporting of the foreign bank account opened to collect rent or pay charges, and reporting of rental receipts from the first euro. The double-taxation relief mechanism cannot be guessed: it differs from one country to the next. The firm assists French-resident owners in bringing their foreign property holdings into compliance.

Paris · Geneva · Marseille · Cannes · Lisbon
— In brief
Principle
French tax resident: taxation on worldwide income (art. 4 A). The foreign property does not leave the French tax net
Wealth tax
Net worldwide real-estate assets above 1,300,000 euros on 1 January: form 2042-IFI, foreign property included
Foreign account
Form 3916 / 3916 bis every year. Fine of 1,500 euros per account, 10,000 euros for certain States (art. 1736, IV)
Holiday letting
Business income (BIC), never property income. Micro-BIC: 30 % and 15,000 euros for unclassified tourist accommodation, 50 % and 77,700 euros where classified
Relief method
Spain, Italy, Greece: credit equal to the French tax, box 8TK. Portugal, Morocco: exemption with effective-rate progression, box 8TI
Social levies
18.6 % on furnished-letting business income since the 2026 social security financing act, against 17.2 % maintained on property income
— 01

The property is abroad, the reporting obligation is in France

The answer fits in one sentence: yes, you must report, even where the country of situation has already levied its own tax. Article 4 A of the French tax code provides that persons whose tax domicile is in France are liable to income tax on the whole of their income. The tax treaty with the State of situation does not remove that obligation: it merely governs how double taxation is neutralised once the income has been entered on the French return.

The most widespread misconception is that tax paid in Spain, Italy or Portugal settles the matter. It does not. The income must appear on form 2047, be carried over into the relevant French category, and then be entered in the treaty box that triggers double-taxation relief. An omission, even in good faith, exposes the taxpayer to a reassessment with late-payment interest and, depending on the circumstances, a surcharge.

Ownership itself generates obligations distinct from those attached to the rent. The foreign property falls within the base of the real-estate wealth tax, whose threshold of 1,300,000 euros of net taxable real-estate assets on 1 January was maintained by the 2026 finance act. The account opened locally to collect rent, pay the local property tax or settle service charges is a foreign account within the meaning of article 1649 A of the French tax code, to be reported annually.

The firm takes on a limited number of matters so that partners remain directly involved in each file, and systematically assesses the relevance of an intervention before any engagement.

— 02

The obligations, point by point

01

Real-estate wealth tax: the foreign property counts

A French resident is taxed on worldwide real-estate assets, wherever they are located.

  • Base: all real-estate assets and rights held directly or indirectly, in France and outside France (art. 964 et seq.)
  • Threshold of 1,300,000 euros of net taxable assets on 1 January, maintained by the 2026 finance act after the proposed tax on unproductive wealth was dropped
  • Progressive scale from 0.5 % to 1.5 %, the first rate applying from 800,000 euros once the 1,300,000-euro threshold is crossed
  • Reporting on form 2042-IFI filed with the income tax return; where applicable, credit for foreign wealth tax under the relevant treaty
  • A secondary home attracts no allowance: the 30 % allowance is reserved for the main residence
02

The foreign bank account: the costliest omission

An account used to collect three rental payments a year and pay the service charges is a reportable account.

  • Obligation to report accounts opened, held, used or closed abroad, on form 3916 / 3916 bis filed with the income tax return (art. 1649 A)
  • Fine of 1,500 euros per account and per non-time-barred year (art. 1736, IV), raised to 10,000 euros where the account is held in a State that has not concluded with France an administrative assistance agreement allowing access to banking information
  • Reassessment period extended to ten years (Tax Procedure Code, art. L. 169), provided the aggregate balance of the unreported accounts exceeded 50,000 euros at any point during the year
  • A 80 % surcharge may apply to tax reassessments resulting from the failure to report the account (art. 1729-0 A)
  • The obligation also covers payment accounts and digital-asset accounts held outside France: collecting rent through a foreign platform warrants a review
03

Holiday letting: business income, not property income

Letting a furnished dwelling falls within business income, whatever the duration and whatever the country of situation.

  • A furnished letting, even for a few weeks a year, is never reported on form 2044: it falls within business income (BIC)
  • Micro-BIC for unclassified tourist accommodation: 30 % allowance, receipts cap of 15,000 euros, from the taxation of 2025 income (act no. 2024-1039 of 19 November 2024)
  • Micro-BIC for classified tourist accommodation and bed and breakfast: 50 % allowance, receipts cap of 77,700 euros
  • Above the cap, the actual-basis regime is mandatory: expenses deducted at their real amount and depreciation of the property, with accounts to be kept
  • A professional lessor is one whose household receipts exceed 23,000 euros and exceed the household's other earned income (art. 155, IV); article 53 of the 2026 finance act adjusted that second condition for non-resident taxpayers only
04

The forms: 2047, then 2042 C PRO, then the treaty box

The reporting chain has three steps, and it is the last one that triggers double-taxation relief.

  • Step 1, form 2047: all foreign-source income is summarised there, at its amount before deduction of the foreign tax, after deducting only the expenses allowable in its own category
  • Step 2, form 2042 C PRO: micro-BIC receipts are carried over to boxes 5NH / 5OH for unclassified tourist accommodation and 5NG / 5OG for classified accommodation and bed and breakfast
  • Step 3, form 2042 C: entry in box 8TK where the treaty grants a credit equal to the French tax, or in box 8TI where it provides an exemption taken into account for the effective-rate calculation
  • Do not confuse them: box 8VL receives the credit representing the foreign tax, a mechanism reserved for certain categories of income, mainly investment income
  • Micro-BIC receipts are reported gross, without deducting platform commissions or management fees, the allowance being deemed to cover them
05

8TK or 8TI: the method changes with the treaty

Two mechanisms coexist, with very different effects on the tax rate applied to the rest of the household's income.

  • Spain (treaty of 10 October 1995, art. 24, 1, a, i): credit equal to the French tax on that income, whatever the amount of Spanish tax. Box 8TK
  • Italy (treaty of 5 October 1989, art. 24): the same method for real-estate income, the credit being equal to the French tax whatever the tax actually levied in Italy. Box 8TK
  • Greece (treaty of 11 May 2022, in force on 30 December 2023 and applicable since 1 January 2024, art. 21): credit equal to the French tax on real-estate income. Box 8TK
  • Portugal (treaty of 14 January 1971, art. 24, 1, a and b) and Morocco (treaty of 29 May 1970, art. 9 and 25, 1): income taxable in the State of situation is exempt in France but retained for the effective-rate calculation. Box 8TI
  • A decisive point often overlooked: under the official form 2047 guidance, the French tax means income tax increased by the social levies. The box 8TK credit therefore also neutralises the social levies on that income
  • The box 8TK credit is in principle subject to the condition that tax has actually been paid in the State of situation
06

A worked example: a furnished let in Spain, then the same in Morocco

Same receipts, same household, two treaty mechanisms, two outcomes.

  • Assumptions: a French-resident couple, marginal rate of 41 %, flat let as unclassified tourist accommodation, gross receipts of 12,000 euros for the year, local tax paid of 1,200 euros
  • French taxable base: 12,000 euros less the 30 % micro-BIC allowance, that is 8,400 euros
  • Theoretical French tax: 3,444 euros of income tax plus 1,562 euros of social levies at 18.6 %, that is 5,006 euros
  • Property in Spain, box 8TK: the credit equal to the French tax, social levies included, neutralises those 5,006 euros. The total cost is limited to the 1,200 euros paid in Spain
  • Property in Morocco, box 8TI: the 8,400 euros are exempt but retained for the effective-rate calculation. The French charge on that income is nil, but the rate applied to the household's other income rises
  • A frequent mistake to avoid: deducting the 1,200 euros of local tax from the receipts reported. Foreign tax is not deductible from income; it is taken into account, where applicable, through the credit mechanism
— 03

Our approach

The firm covers the whole chain: characterising the regime applicable to rental receipts, choosing between micro-BIC and the actual-basis regime, reading the applicable treaty and determining the double-taxation relief method, regularising undeclared foreign bank accounts, computing and reporting the real-estate wealth tax, and handling litigation where the tax authorities challenge the treatment adopted. We also act upstream, where the secondary home is to become a main residence or where ownership is to be held through a foreign company. The firm devoted a column to this subject in Investir (Les Echos), 18 July 2026.

  • Foreign-source income
  • Furnished tourist letting
  • Form 2047
  • Foreign accounts
  • Real-estate wealth tax
  • Tax treaties
— FAQ

Secondary home abroad: your questions

Must I report the rent from my house in Spain when I have already paid Spanish tax?

Yes. As a French tax resident you are taxable on the whole of your income, French and foreign alike (art. 4 A). Tax paid in Spain does not remove the French reporting obligation: under article 24 of the treaty of 10 October 1995 it gives rise to a credit equal to the French tax on that income. In practice you report the receipts on form 2047, carry them over as business income on form 2042 C PRO, then enter the same amount in box 8TK of form 2042 C. The credit then neutralises the corresponding income tax and social levies. Without box 8TK you will be taxed twice.

Is my holiday letting property income or business income?

Business income, without exception, where the dwelling is let furnished. The property income category and form 2044 are reserved for unfurnished lettings. The duration is irrelevant: a few weeks each summer are enough to place the receipts within business income. This is not a matter of form: it governs the allowance available, the rate of social levies, now 18.6 % for furnished letting against 17.2 % for property income, and the ability to depreciate the property under the actual-basis regime.

What are the micro-BIC allowances for tourist accommodation in 2026?

Since the taxation of 2025 income, under act no. 2024-1039 of 19 November 2024, two regimes coexist. For unclassified tourist accommodation, the allowance is 30 % and the receipts cap is 15,000 euros. For classified tourist accommodation or bed and breakfast, the allowance is 50 % and the cap is 77,700 euros. These thresholds are assessed on gross receipts, platform commissions not deducted. Above them the actual-basis regime applies, with accounts to be kept and the ability to depreciate the property. Classification of a property located outside France requires a case-by-case review of its equivalence with the French classification.

What is the difference between box 8TK and box 8TI?

They reflect two distinct treaty methods. Box 8TK corresponds to the credit equal to the French tax: the income is taxed in France, then the corresponding tax is entirely neutralised by a credit of the same amount. That is the method for real-estate income arising in Spain, Italy and Greece. Box 8TI corresponds to exemption with effective-rate progression: the income is exempt in France but retained in order to determine the rate applicable to the household's other income. That is the method for Portugal and Morocco. Swapping the two boxes leads either to double taxation or to an understatement of tax exposing the taxpayer to a reassessment.

Must I report the local bank account opened to collect the rent?

Yes, whatever its balance and even if it is used only to pay the local property tax and the service charges. Article 1649 A of the French tax code requires the annual reporting, on form 3916 / 3916 bis, of accounts opened, held, used or closed abroad. Failure to report is penalised by a fine of 1,500 euros per account and per non-time-barred year, raised to 10,000 euros where the account is held in a State that has not concluded with France an administrative assistance agreement allowing access to banking information. The reassessment period is also extended to ten years where the aggregate unreported balances exceeded 50,000 euros at any point during the year.

Does my secondary home abroad fall within the real-estate wealth tax base?

Yes. The real-estate wealth tax applies to the worldwide real-estate assets of a French-resident household. The foreign property is included at its market value on 1 January, less allowable debts. Liability is triggered by net taxable real-estate assets above 1,300,000 euros, a threshold maintained by the 2026 finance act, the proposed tax on unproductive wealth not having been enacted. Since the 30 % allowance is reserved for the main residence, a secondary home is taken at its full value. The applicable treaty may allow a credit for wealth tax paid locally.

What mistakes do you see most often?

Four recur constantly. The first is reporting nothing on the ground that tax was paid locally, which forfeits the credit and invites a reassessment. The second is treating a holiday letting as property income on form 2044 instead of business income, with the wrong allowance and the wrong rate of social levies. The third is confusing boxes 8TK and 8TI, when the method depends on the treaty applicable to the country of situation. The fourth is deducting the foreign tax from the receipts reported: foreign tax is not a deductible expense, it is taken into account through the credit mechanism, which is not the same computation.

What if the secondary home becomes my main residence?

The scale of the question changes. Moving the permanent home may bring about a change of tax residence, assessed under article 4 B of the French tax code and then, in the event of a conflict, under the treaty residence tie-breakers. That move may trigger the exit tax on unrealised gains on shareholdings, with strict reporting obligations and deferral rules. The question of holding through a company, often suggested locally, warrants prior analysis in the light of the real-estate wealth tax, the taxation of distributions and the valuation rules. These decisions are prepared in advance, not at the time of the move.

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A property outside France to report, or a situation to regularise?

Confidential initial discussion, without commitment. We reply within 48 business hours.

Jonathan Bensaid, avocat fondateur

Written by

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