
The European Court of Justice recently offered a favourable decision that will impact whether non-French residents owning French real estate will be subject to French Social contributions.
As many people know, since 2012, French non-residents have been subject to French social contributions (at a rate of 15.5%) on their French source rental income and their French capital gains.
In the case of a UK resident and domiciled individual this meant that they would be subject to French income tax and French social contributions on rental income generated in France. Under the UK-French double tax treaty, an individual is able to offset income taxes paid in both jurisdictions, but they are unable to offset the French social contributions.