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Buying a property in France from Portugal: tax, financing, inheritance, visas

Many Portuguese residents (and Franco-Portuguese dual nationals) buy in France. The cross-border community is one of the most structured. Language, the euro and direct flights make the project natural. EU resident status simplifies everything: no tax representative imposed on resale, social levies reduced to 7.5% if you are affiliated to a social security scheme in Portugal, free movement with no stay limit, and no currency risk since France and Portugal share the euro.

The Arcachon seafront, its turreted villa and its boats moored on the bay
Arcachon, Atlantic Coast

By Jean Mascla, founder of Home Select Updated · 5 min read

Buying from Portugal

The French notaire follows a clear process, and the euro avoids any conversion. You can sign in person or by notarised power of attorney.

What changes for you

  • 10-day cooling-off period, then authentic deed 2 to 3 months later.
  • 5 to 10% deposit on the notaire’s escrow account.
  • Power of attorney possible at a notary in Portugal or a consulate, apostilled.

Points to watch

  • Check borrowing capacity in France if your income is in Portugal.
  • The compromise clauses are binding: a partner notary’s advice secures the process.

Financing from Portugal

The euro eliminates currency risk. French banks lend to EU residents, with a usual down payment of 10 to 20%.

What changes for you

  • 10 to 20% down payment generally required for non-resident EU buyers.
  • Income proof from Portugal accepted, translated if necessary.
  • Borrower insurance: possible from France, check cross-border coverage.

Points to watch

  • Compare the offered rate with conditions in Portugal: competition helps.
  • Early repayment penalty may be capped by French law.

Ownership tax from Portugal

The Franco-Portuguese treaty avoids double taxation. Portugal taxes via AIMI (real estate wealth tax), with a tax credit for IFI.

What changes for you

  • French rental income taxed at a minimum 20% rate (non-resident), with a tax credit in Portugal via the treaty.
  • IFI beyond €1.3M net real estate wealth in France.
  • Property tax and second-home residence tax to budget for.

Points to watch

  • Declare French rental income to both tax authorities (France then Portugal).
  • IFI is declared annually: a partner wealth adviser can optimise.

Capital gains on resale

As an EU resident, you are not subject to mandatory tax representation below €150,000. Taxation follows the general French regime.

What changes for you

  • 19% tax + social levies (7.5% or 17.2% depending on affiliation).
  • Holding-period allowances: total exemption at 22 years (income tax).
  • No mandatory tax representative as long as the sale price is under €150,000.

Points to watch

  • Keep all renovation invoices: they reduce the taxable gain.
  • Above €150,000, an accredited tax representative becomes mandatory.
The Arcachon seafront, its turreted villa and its boats moored on the bay

Arcachon, Sud-Ouest

Social levies: the EU regime

As an EU resident affiliated to a social security scheme in Portugal, you may qualify for the reduced 7.5% rate instead of 17.2%.

What changes for you

  • Reduced 7.5% rate (solidarity levy) if you hold an S1 form issued in Portugal.
  • The gap between 17.2% and 7.5% directly affects the net income of a let.
  • Application to file with the URSSAF non-residents (2-year retroactive limit).

Points to watch

  • Without S1, the full 17.2% rate applies to rents and capital gains.
  • Status may change: annual monitoring prevents surprises.

Inheritance and transfer

Portuguese law has legítima (forced heirship), close to French law. The EU regulation applies.

What changes for you

  • European Succession Regulation (EU 650/2012): you can choose the law of your nationality by will.
  • France-Portugal succession treaty: avoid double taxation.
  • SCI or usufruct structures possible, to be structured before signing.

Points to watch

  • French forced heirship applies if French law is chosen.
  • Indivision between heirs can block management: structure early.

Stay and travel

EU citizen or resident: full freedom of movement, no length-of-stay limit in France.

What changes for you

  • No day limit: you can stay in France year-round.
  • No visa required: national ID card or passport is enough.
  • Tax residence: beware not to shift it unintentionally (more than 183 days/year).

Points to watch

  • Tax residence is determined globally (home, stay, economic interests).
  • Prolonged presence may turn a second home into a primary residence for tax purposes.

Structuring ownership

SCI, usufruct, joint ownership: several structures exist. The choice depends on your tax position in Portugal and wealth goals.

What changes for you

  • SCI: tax-transparent in France, but its treatment in Portugal varies (to be checked).
  • Usufruct (bare ownership / usufruct): IFI and succession optimisation tool.
  • Joint ownership: simple but can block management if heirs disagree.

Points to watch

  • SCI may have an unfavourable tax status in Portugal: check beforehand.
  • Usufruct must be decided BEFORE purchase, not after.

Frequently asked questions

Can I sign from Portugal?

Yes, by notarised power of attorney at a notary in Portugal or a French consulate. The partner notary coordinates the process.

Do I need a tax representative on resale?

As an EU resident, a tax representative is only mandatory if the sale price exceeds €150,000. Below that, you handle it directly.

Is an SCI attractive from Portugal?

SCI is tax-transparent in France, but its tax treatment in Portugal depends on your situation. A partner wealth adviser analyses the structure before purchase.

How is the capital gain taxed if I resell while living in Portugal?

As an EU resident, you are not subject to mandatory tax representation below €150,000. Taxation follows the general French regime.

Which social levies apply to a resident in Portugal?

As an EU resident affiliated to a social security scheme in Portugal, you may qualify for the reduced 7.5% rate instead of 17.2%.

Can I borrow in France while living in Portugal?

The euro eliminates currency risk. French banks lend to EU residents, with a usual down payment of 10 to 20%.

How long can I stay in my French property?

EU citizen or resident: full freedom of movement, no length-of-stay limit in France.

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