What are the four French tax residency tests under Article 4B CGI?

France's Article 4B Code Général des Impôts defines French tax residency via four alternative tests — any single one is sufficient to establish French tax residency regardless of time spent abroad: (1) Foyer fiscal: your habitual home, or your family home (where your spouse/PACS partner and children normally reside) is in France. This is the strongest and most litigated trigger — if your family remains in France, DGFiP argues your foyer is in France even if you personally live in Dubai. (2) Lieu de séjour principal: you spend more time in France than in any other country, OR more than 183 days in France in the tax year. (3) Professional activity: your main professional or employment activity is exercised in France. (4) Centre of economic interests: your main investments, business, or primary income source is in France. Breaking all tests requires genuinely relocating your entire economic and family life to UAE.

What is Article 167 bis CGI and how does it affect French Dubai expats?

Article 167 bis CGI is France's exit tax (taxe sur les plus-values latentes) on individuals who cease French tax residency while holding substantial assets. It applies when: (1) your shareholdings in one or more companies exceed EUR 800,000 in total market value, OR (2) you hold more than 50% of a company's share capital. On the date you cease to be a French tax resident, Article 167 bis deems you to have disposed of all qualifying shareholdings at market value. The gain (market value minus acquisition cost) is taxed at the flat PFU rate of 30% (12.8% IR + 17.2% social charges). Deferral is available by providing collateral (sûreté — bank guarantee, pledge of assets, or escrow) to the DGFiP. The exit tax is permanently waived if: you remain non-resident for 15 years and do not sell the shares during that period. For large company founders, this can be a EUR 500,000–several million euro liability on departure.

What is the France-UAE double taxation convention and how does it protect me?

France and the UAE signed a Convention fiscale pour l'évitement de la double imposition in 1989. It follows the OECD model and allocates taxing rights between the two countries to prevent double taxation. Key article allocations: Art. 15 — employment income taxed where work physically performed (UAE employment: 0% France for genuine UAE residents); Art. 6 — real property income taxed in source country (French rental property: taxed in France); Art. 10 — dividends: source country withholding capped at 0% (UAE) or 15% (France) maximum; Art. 11 — interest: residence country (UAE); Art. 18 — pensions: source country for state pensions (CNAV taxed in France); Art. 13 — capital gains: non-real property gains taxed in residence country (UAE). A UAE TRC (Tax Residency Certificate from the UAE FTA) is submitted to the DGFiP to invoke treaty protection.

How does the IFI (Impôt sur la Fortune Immobilière) apply to non-residents?

The IFI replaced the ISF from 1 January 2018. Unlike the old ISF, the IFI applies only to real estate assets (not financial portfolios). The critical point: the IFI applies to ALL French real estate worth more than EUR 1.3M NET — this includes NON-RESIDENTS. A French national living in Dubai who owns a Paris apartment worth EUR 2M (with EUR 400K mortgage) has an IFI-taxable base of EUR 600K above the EUR 1.3M threshold — owing approximately EUR 3,000/yr in IFI. Rates: 0.5% on EUR 1.3M–2.5M; 0.7% on EUR 2.5M–5M; 1% on EUR 5M–10M; 1.25% above EUR 10M. French mortgage debt on the property reduces the IFI base. SCI (Société Civile Immobilière) structures are also included. File the 2042-IFI declaration annually at Centre des Impôts des Non-Résidents.

How is the France-UAE DBA 'centre of vital interests' tie-breaker applied?

When both France and UAE could claim an individual as tax resident, the France-UAE DBA applies a sequential tie-breaker under Article 4: (1) Permanent home: where does the person have a permanent home available? If only in UAE, UAE wins. If in both, proceed to (2). (2) Centre of vital interests: where are the individual's personal and economic relations closest? If the family is in Dubai, the UAE bank is primary, the business is in UAE, and French visits are social — UAE wins this test. If the family is in France, if the French employer remains primary, or if the main business decisions are made in France — France wins. (3) Habitual abode: where does the person spend more time? If >183 days UAE and <90 France, UAE wins. (4) Nationality. In practice, the DGFiP challenges most aggressively on test (2) — centre of vital interests. Bringing family to Dubai, surrendering personal use of French property, and demonstrating genuine UAE economic integration is the strongest position.

When must I close my PEA (Plan d'Épargne en Actions)?

The PEA (Plan d'Épargne en Actions) must be closed within 6 months of the date you lose French tax residency — this is a legal requirement under Article L221-31 of the Code monétaire et financier. There is no exception. On closure: gains accumulated in the PEA are subject to 12.8% IR (impôt sur le revenu) + 17.2% prélèvements sociaux for plans held 5+ years (total 30% PFU); for plans held fewer than 5 years: 22.5% IR + 17.2% social charges. This forced crystallisation can be significant if the PEA has accumulated large gains. Tax optimisation tip: if your PEA gains are very large and the closure tax is high, discuss the timing of your tax residency break with your fiscaliste — sometimes it is more efficient to close the PEA before formally breaking residency in a tax year when other deductions can be used.

What happens to my CNAV French state pension when I live in Dubai?

Your accrued CNAV (Caisse Nationale d'Assurance Vieillesse) state pension rights are fully preserved when you live in Dubai. The CNAV records every trimestre (quarter) you contributed in France — these are permanent records regardless of subsequent residence. From retirement age (between 62 and 67 depending on birth year and trimestres accrued), you can claim the CNAV pension from Dubai or anywhere. The pension is paid to any international bank account. Taxation: CNAV pension is taxable in France per the France-UAE DBA Art. 18 — pensions are allocated to the source country (France). You must file an annual French tax return (2042 NR) for the years you receive CNAV pension. The standard 10% pension abattement applies; the personal allowance (part of the barème) reduces low-pension liabilities.

How does French inheritance tax (DMTG) work with a 6-year tail?

French droits de mutation à titre gratuit (DMTG — succession and gift tax) applies a 6-year tail rule for emigrants. If a French national who was previously French tax resident emigrates to Dubai and either: (1) inherits from a deceased who was French tax resident within 6 years of the inheritance, or (2) is a donor/deceased who was French tax resident within 6 years — then French DMTG can apply to worldwide assets (not just French-situs). This 6-year lookback period is more aggressive than Germany's 5-year equivalent. After 6 years of continuous French non-residency, DMTG applies only to French-situs assets (French real estate, French bank accounts, French company shares) regardless of the heirs' or donor's location. Standard allowances apply: spouse EUR 80,724; child EUR 100,000; sibling EUR 15,932. Tax rates: 5–45% progressive (Class I family).

What are French CGT 'plus-values' for non-residents on French property sales?

Capital gains on French real property sold by a non-resident are taxable in France under the France-UAE DBA Art. 13 (real property gains allocated to source country). The applicable rates: 19% income tax (taux proportionnel) + 17.2% prélèvements sociaux = 36.2% total. However, EU/EEA tax treaty residents may be eligible for a reduced 7.5% social charge rate on the prélèvements part — check DBA terms. Abattements reduce the taxable gain based on holding period: 6% per year from year 6 onwards; full income tax exemption after 22 years; full social charge exemption after 30 years. First EUR 150,000 of gain: additional EUR 1,594–14,529 progressive surtax applies. A notaire handles French property sales for non-residents and witholds the estimated tax at closing.

Does the DGFiP audit French nationals in Dubai?

Yes — the DGFiP (Direction Générale des Finances Publiques) actively reviews French nationals living in countries classified as low-tax or zero-tax, including the UAE. The DGFiP has access to: (1) CRS (Common Reporting Standard) — UAE banks report French-identified account holders' balances to UAE FTA, which shares with DGFiP annually; (2) EU DAC2 — EU-wide financial information exchange; (3) French financial institution records showing prior PEA, Assurance Vie, and Livret A holdings; (4) French administrative records (tax returns, property registers, social security data). Typical audit triggers: spouse/children remain in France; continued French employment; French property used personally during visits; significant French-source income not declared; inconsistent travel patterns. The DGFiP's investigation powers reach back 3 years (standard) or 10 years for fraud.

What should I do about my Assurance Vie as a French non-resident?

Unlike the PEA, the French Assurance Vie (AV) does not require mandatory closure on becoming a non-resident. The AV can remain open and the underlying investments can stay invested. However: (1) Future contributions as a non-resident may be restricted by the insurer — check policy terms; (2) Withdrawals (rachats) made while non-resident are taxed differently: for contracts 8+ years old, the standard 7.5% abattement-enhanced rate may still apply, but some insurers withhold at the PFU rate regardless; (3) The beneficiary clause should be reviewed — cross-border estate planning needs to account for both French succession law and UAE requirements; (4) For large AV portfolios, a bilateral estate planning adviser (French notaire + UAE adviser) should review the structure before any changes.

How is French rental income taxed and what can I deduct?

As a French non-resident (Dubai resident), French rental income (revenus fonciers) remains taxable in France. Rates: minimum 20% income tax on net income (or progressive if higher) + 17.2% prélèvements sociaux (social charges). For UAE DBA residents, there may be a claim for reduced social charge rates — seek specialist advice as this has been litigated. You can deduct: mortgage interest (intérêts d'emprunt), property management fees (honoraires de gestion), insurance premiums (assurance), maintenance and repair costs (not improvements), property tax (taxe foncière), and building depreciation-equivalent charges. File form 2044 (régime réel) or 2042 (micro-foncier for <EUR 15,000 gross rental) at Centre des Impôts des Non-Résidents. Deadline: same as residents (late May) with 2-week additional window for non-residents.

How do I get a UAE Tax Residency Certificate (TRC)?

Apply to the UAE Federal Tax Authority (FTA) via their online portal at tax.gov.ae. Requirements for individual TRC: (1) UAE residence visa (valid); (2) Emirates ID; (3) UAE entry/exit certificate from ICA showing 183+ UAE days in the relevant 12-month period (available from ICA-UAE app or service centre); (4) UAE bank account statements (last 3–6 months showing UAE activity); (5) Ejari-registered tenancy contract for UAE property; (6) Employer letter (if employed) or UAE trade licence (if business owner); (7) Passport copy. FTA processing: 4–8 weeks. Fee: AED 1,000 for individuals. The TRC is issued per calendar year. For the France-UAE Convention Fiscale, present the TRC to your Centre des Impôts des Non-Résidents file with a French cover letter asserting UAE treaty residency.

What documentation should I keep to defend my UAE tax residency against DGFiP?

Maintain a comprehensive paper trail from your first day in Dubai: (1) Passport entry/exit stamps with French days tracked and UAE days confirmed; (2) UAE ICA entry/exit certificate (annual download); (3) UAE bank statements showing regular salary deposits and UAE spending; (4) Ejari certificate (UAE lease registration); (5) Emirates ID and UAE residence visa; (6) UAE TRC from FTA; (7) Dubai utility bills (electricity/water/internet) in your name; (8) UAE employer letters confirming employment start date and UAE presence; (9) Credit/debit card transaction records showing day-to-day UAE spending; (10) Evidence of family in Dubai (school enrolment letters, spouse's UAE visa, children's UAE IDs); (11) French property commercially rented — lease agreement with tenants, no personal use. The DGFiP can request documentation going back 3–10 years. Digital archiving with date-stamped cloud backups is strongly recommended.

Taxes for French Expats in Dubai 2026

Q: When must I close my PEA (Plan d'Épargne en Actions)?

The PEA (Plan d'Épargne en Actions) must be closed within 6 months of the date you lose French tax residency — this is a legal requirement under Article L221-31 of the Code monétaire et financier. There is no exception. On closure: gains accumulated in the PEA are subject to 12.8% IR (impôt sur le revenu) + 17.2% prélèvements sociaux for plans held 5+ years (total 30% PFU); for plans held fewer than 5 years: 22.5% IR + 17.2% social charges. This forced crystallisation can be significant if the PEA has accumulated large gains. Tax optimisation tip: if your PEA gains are very large and the closure tax is high, discuss the timing of your tax residency break with your fiscaliste — sometimes it is more efficient to close the PEA before formally breaking residency in a tax year when other deductions can be used.

Q: What happens to my CNAV French state pension when I live in Dubai?

Your accrued CNAV (Caisse Nationale d'Assurance Vieillesse) state pension rights are fully preserved when you live in Dubai. The CNAV records every trimestre (quarter) you contributed in France — these are permanent records regardless of subsequent residence. From retirement age (between 62 and 67 depending on birth year and trimestres accrued), you can claim the CNAV pension from Dubai or anywhere. The pension is paid to any international bank account. Taxation: CNAV pension is taxable in France per the France-UAE DBA Art. 18 — pensions are allocated to the source country (France). You must file an annual French tax return (2042 NR) for the years you receive CNAV pension. The standard 10% pension abattement applies; the personal allowance (part of the barème) reduces low-pension liabilities.

Q: How does French inheritance tax (DMTG) work with a 6-year tail?

French droits de mutation à titre gratuit (DMTG — succession and gift tax) applies a 6-year tail rule for emigrants. If a French national who was previously French tax resident emigrates to Dubai and either: (1) inherits from a deceased who was French tax resident within 6 years of the inheritance, or (2) is a donor/deceased who was French tax resident within 6 years — then French DMTG can apply to worldwide assets (not just French-situs). This 6-year lookback period is more aggressive than Germany's 5-year equivalent. After 6 years of continuous French non-residency, DMTG applies only to French-situs assets (French real estate, French bank accounts, French company shares) regardless of the heirs' or donor's location. Standard allowances apply: spouse EUR 80,724; child EUR 100,000; sibling EUR 15,932. Tax rates: 5–45% progressive (Class I family).

Q: What are French CGT 'plus-values' for non-residents on French property sales?

Capital gains on French real property sold by a non-resident are taxable in France under the France-UAE DBA Art. 13 (real property gains allocated to source country). The applicable rates: 19% income tax (taux proportionnel) + 17.2% prélèvements sociaux = 36.2% total. However, EU/EEA tax treaty residents may be eligible for a reduced 7.5% social charge rate on the prélèvements part — check DBA terms. Abattements reduce the taxable gain based on holding period: 6% per year from year 6 onwards; full income tax exemption after 22 years; full social charge exemption after 30 years. First EUR 150,000 of gain: additional EUR 1,594–14,529 progressive surtax applies. A notaire handles French property sales for non-residents and witholds the estimated tax at closing.

Q: Does the DGFiP audit French nationals in Dubai?

Yes — the DGFiP (Direction Générale des Finances Publiques) actively reviews French nationals living in countries classified as low-tax or zero-tax, including the UAE. The DGFiP has access to: (1) CRS (Common Reporting Standard) — UAE banks report French-identified account holders' balances to UAE FTA, which shares with DGFiP annually; (2) EU DAC2 — EU-wide financial information exchange; (3) French financial institution records showing prior PEA, Assurance Vie, and Livret A holdings; (4) French administrative records (tax returns, property registers, social security data). Typical audit triggers: spouse/children remain in France; continued French employment; French property used personally during visits; significant French-source income not declared; inconsistent travel patterns. The DGFiP's investigation powers reach back 3 years (standard) or 10 years for fraud.

Comprehensive guide to French tax obligations for Dubai residents: Article 167 bis exit tax, four residency tests, IFI wealth tax on French real estate, mandatory PEA closure, France-UAE DBA treaty, CNAV pension, and 6-year inheritance tail.

Last updated: May 2026

James Ho· Digital Nomad & Tax Correspondent

5 years location-independent, 3 of them in Dubai. Chartered accountant (ICAEW). Holds a UAE Virtual Working visa.

French Tax — Six Unique Risks for Dubai Expats

French expats in Dubai face a more complex tax transition than most other nationalities. France has four separate tax residency triggers (any one is sufficient to maintain French residency), an exit tax on substantial shareholdings, a permanent wealth tax on French real estate, and a mandatory PEA account closure requirement on departure. Done correctly, French Dubai residents can achieve a very clean 0% UAE tax position. Done incorrectly, the DGFiP can maintain significant tax claims for years after departure.

This guide covers the key French tax issues specific to Dubai residents: the Article 167 bis exit tax, the four Article 4B CGI residency triggers, the IFI real estate wealth tax for non-residents, PEA mandatory closure, the France-UAE double taxation convention (1989), the 6-year inheritance tail, and the 8-step process to establish clean UAE tax residency.

Six critical French tax risks for Dubai expats

(1) Article 167 bis exit tax:Substantial shareholdings (>EUR 800K or >50%) — 30% deemed disposal on departure. No installment plan available. (2) Four residency triggers: Article 4B CGI — any one (foyer, 183 days, economic interests, professional activity) maintains French tax residency. (3) IFI wealth tax:French real estate >EUR 1.3M — applies to non-residents permanently. (4) PEA mandatory closure: Within 6 months of non-residency — forced gain crystallisation. (5) 6-year inheritance tail: French DMTG on worldwide assets for 6 years post-departure. (6) CSG/social charges: 17.2% prélèvements sociaux applies on French-source investment income even for non-residents. All six require specialist advice from a French fiscaliste before departure.

Article 167 bis CGI — Exit Tax on Departure

Article 167 bis CGI is France's most significant individual tax risk for business owners emigrating to Dubai. It applies if you hold qualifying shareholdings on the date you cease to be a French tax resident:

Shareholdings with a total market value exceeding EUR 800,000, OR
Shareholdings representing more than 50% of a company's share capital

The tax is calculated as if you sold all qualifying shares at market value on departure date. Market value minus acquisition cost equals the taxable gain, taxed at 30% PFU (12.8% IR + 17.2% social charges).

Article 167 bis — deferral vs payment vs waiver

Unlike Germany's §6 AStG (which has an EU/EEA 7-year installment plan), France's exit tax applies uniformly regardless of destination. Options: (1) Pay upfront— clean break, no ongoing obligations. (2) Defer with collateral (sûreté):provide DGFiP with bank guarantee, asset pledge, or escrow — up to 8 years. Tax still due if shares sold during deferral. (3) 15-year waiver: if you remain non-resident continuously for 15 years AND do not sell the qualifying shares, the exit tax liability is permanently waived. Many business owners plan for the 15-year waiver as the optimal strategy.

Article 167 bis scenarios and options

Article 167 bis CGI: exit tax scenarios and planning options for Dubai emigrants
Emigration Scenario	Tax Rate Applied	Deferral Options	Permanent Waiver	Planning Notes
Emigrating to UAE (Dubai) with qualifying shareholdings (>EUR 800K or >50% of company)	30% PFU flat (12.8% IR + 17.2% social charges) on unrealised gain at market value on departure date	Deferral available with collateral (sûreté) provided to DGFiP — up to 8 years; no installment plan like Germany's EU-only 7-year plan	Exit tax permanently waived if: (1) remained non-resident continuously for 15 years AND (2) shares not sold during those 15 years	Engage fiscaliste 12–18 months before departure; restructure shareholdings pre-exit if possible; value shares accurately; consider phased sale vs deferral
Emigrating to EU/EEA country first, then UAE	Art. 167 bis CGI applies on actual departure from France (country of destination does not affect the French trigger)	Deferral available; no installment plan; collateral required regardless of EU/non-EU destination	15-year continuous non-residency from France (not from any one country); must not sell shares	Multi-step emigration via EU does not avoid Art. 167 bis; France applies it on departure from France regardless
Return to France within 15 years (shares not sold)	Exit tax deferred liability waived on return — deemed departure reversed	N/A — return cancels the tax event	Automatic if: return to France and re-establish French tax residency within 15 years	Some business owners plan 15-year non-residency to achieve permanent waiver; then return to France with clean capital position
Shares sold while non-resident (during 8-year deferral or 15-year waiver period)	Deferred tax becomes immediately payable on share disposal — crystallised at original departure-date valuation	Deferral ends on disposal	Waiver condition broken; tax due	If planning to sell shares while non-resident, assess whether paying Art. 167 bis upfront on departure is more efficient than deferral

Emigration ScenarioEmigrating to UAE (Dubai) with qualifying shareholdings (>EUR 800K or >50% of company)

Tax Rate Applied30% PFU flat (12.8% IR + 17.2% social charges) on unrealised gain at market value on departure date

Deferral OptionsDeferral available with collateral (sûreté) provided to DGFiP — up to 8 years; no installment plan like Germany's EU-only 7-year plan

Permanent WaiverExit tax permanently waived if: (1) remained non-resident continuously for 15 years AND (2) shares not sold during those 15 years

Planning NotesEngage fiscaliste 12–18 months before departure; restructure shareholdings pre-exit if possible; value shares accurately; consider phased sale vs deferral

Emigration ScenarioEmigrating to EU/EEA country first, then UAE

Tax Rate AppliedArt. 167 bis CGI applies on actual departure from France (country of destination does not affect the French trigger)

Deferral OptionsDeferral available; no installment plan; collateral required regardless of EU/non-EU destination

Permanent Waiver15-year continuous non-residency from France (not from any one country); must not sell shares

Planning NotesMulti-step emigration via EU does not avoid Art. 167 bis; France applies it on departure from France regardless

Emigration ScenarioReturn to France within 15 years (shares not sold)

Tax Rate AppliedExit tax deferred liability waived on return — deemed departure reversed

Deferral OptionsN/A — return cancels the tax event

Permanent WaiverAutomatic if: return to France and re-establish French tax residency within 15 years

Planning NotesSome business owners plan 15-year non-residency to achieve permanent waiver; then return to France with clean capital position

Emigration ScenarioShares sold while non-resident (during 8-year deferral or 15-year waiver period)

Tax Rate AppliedDeferred tax becomes immediately payable on share disposal — crystallised at original departure-date valuation

Deferral OptionsDeferral ends on disposal

Permanent WaiverWaiver condition broken; tax due

Planning NotesIf planning to sell shares while non-resident, assess whether paying Art. 167 bis upfront on departure is more efficient than deferral

French vs UAE Tax Treatment by Income Type

Once genuine UAE tax residency is established and French unlimited tax liability broken, French taxation is limited to French-source income under the France-UAE DBA. The table below shows each income type and which country taxes it.

French vs UAE tax treatment by income type for Dubai-resident French nationals (2026)
Income Type	French Tax Treatment (while Dubai resident)	UAE / Dubai Tax Treatment	DBA Treaty Allocates To	Key Notes
UAE employment income (Dubai salary)	0% (France-UAE DBA: employment income taxed where work performed; UAE is country of performance; genuine UAE tax residency required)	0% — no UAE income tax	UAE (country of employment)	Must establish genuine UAE tax residency; break all four Article 4B CGI tests; obtain UAE TRC after 183 days
French employment days (working physically in France)	Taxable in France — proportionate to days physically in France	0% UAE tax	France (source country — work physically performed in France)	Even a few French working days create French taxable income; track carefully; avoid French work days or minimise
French rental property income	Taxable in France at 20% minimum (or progressive if higher) + 17.2% prélèvements sociaux. Net: ~37.2% on income	0% UAE tax	France (real property sourced to France — DBA Art. 6)	File annual 2042 NR at Centre des Impôts des Non-Résidents; deductible: mortgage interest, property management, repairs, taxe foncière, Abschreibung-equivalent
French dividends (company shareholding in France)	30% prélèvement forfaitaire unique (PFU) at source: 12.8% IR + 17.2% prélèvements sociaux; DBA may reduce for substantial shareholders	0% UAE tax	France (source); maximum 15% for most shareholders per DBA Art. 10	Art. 167 bis exit tax may have already crystallised gain on departure; avoid PFU complications via advance ruling or adviser
Capital gains on French shares (non-Art. 167 bis)	30% PFU for non-residents; may be 0% for non-resident individuals under DBA if not French property-rich company	0% UAE tax	UAE (residence country) for most securities gains (not property-rich companies)	If Art. 167 bis exit tax already applied, further gains on those shares are post-exit and potentially UAE-only
Capital gains on French real property	19% tax + 17.2% social charges (total 36.2%); EU/EEA DBA residents may get 7.5% social charge rate	0% UAE tax	France (real property rule — DBA Art. 13)	Abattements for long holding: 6% per year from year 6; total exemption after 22 years (income tax) / 30 years (social charges)
French state pension (CNAV / ARRCO-AGIRC)	Taxable in France per DBA Art. 18 (pensions); progressive rates apply; standard abattement 10% on pension income	0% UAE tax	France (source country for state and mandatory supplementary pensions)	File annual French tax return once drawing French pension; taxed in France regardless of UAE residence; UAE residence reduces rate via DBA tie-breaker protections
Interest income (French bank accounts / bonds)	30% PFU at source; DBA may apply — interest generally allocated to residence country (UAE)	0% UAE tax	UAE (residence country) per DBA Art. 11	Reclaim excess French withholding via French tax return if DBA rate applies; notify French bank of non-residency to apply DBA rate at source
Inheritances / gifts from French relatives	French DMTG (droits de mutation) applies for 6 years post-emigration on worldwide assets; after 6 years: French-situs assets only	0% UAE inheritance/gift tax	No specific DBA inheritance article; domestic French law applies	6-year tail more aggressive than Germany (5yr); includes worldwide assets if either party was French resident within 6yr; critical for large anticipated inheritances
French real estate — IFI (Impôt sur la Fortune Immobilière)	IFI applies to French real estate >EUR 1.3M for NON-RESIDENTS. Rates: 0.5–1.5% on net value above EUR 1.3M	0% UAE equivalent	No specific DBA wealth tax article; IFI is a French domestic tax on French-situs real estate	File annual 2042-IFI; French mortgage debt reduces taxable base; SCI structure also caught; applies indefinitely to French RE for non-residents

Income TypeUAE employment income (Dubai salary)

French Tax Treatment (while Dubai resident)0% (France-UAE DBA: employment income taxed where work performed; UAE is country of performance; genuine UAE tax residency required)

UAE / Dubai Tax Treatment0% — no UAE income tax

DBA Treaty Allocates ToUAE (country of employment)

Key NotesMust establish genuine UAE tax residency; break all four Article 4B CGI tests; obtain UAE TRC after 183 days

Income TypeFrench employment days (working physically in France)

French Tax Treatment (while Dubai resident)Taxable in France — proportionate to days physically in France