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Real Estate Tax Accountant

Accounting and tax firm for French real estate structuring: SCI under IR or IS, LMNP or LMP, property VAT, holding companies, resale tax and family transmission.

Updated 02 July 2026
VAT
Real-estate VAT
Choice
IS vs IR
Exit
Capital gains
Setup
Holding & SCI
Key points

As your real estate tax accountant, we structure your property portfolio so your net return survives over time. We arbitrate SCI under income tax or corporate tax, LMNP under the real regime, patrimonial holdings and usufruct arrangements, then handle the accounting, the 2072 and 2031 returns, IFI and family transmission. Every regime choice follows a quantified 5-10 year model.

What we bring
  • Quantified 5-10 year model before every regime choice: SCI IR/IS or LMNP
  • Déficit foncier offsetting global income up to €10,700 per year (€21,400 for energy renovation)
  • Illustrative case: €41,200 annual tax saving and €162k of transfer duties saved

Who is this for?

  • SME directors and professionals holding rental or patrimonial property
  • Property investors and SCI shareholders arbitrating between bare rental (property income) and furnished rental (LMNP/LMP)

When to contact us

  • Before any acquisition: the tax regime is the most structuring decision and the hardest to correct afterwards
  • When furnished rents approach €23,000 and 50% of household income (LMNP to LMP crossing)

What you get

  • A quantified asset audit within 4-6 weeks with 2 or 3 alternative scenarios
  • Annual management of your structures: bookkeeping, 2072 and 2031 returns, IFI filing

You look for a real estate tax accountant when the issue is no longer just filing rental income correctly. The question is how to choose the right structure and tax regime so your net return survives over time. In practice, the same comparisons come back again and again: SCI under income tax or corporate tax, LMNP under the real regime or micro-BIC, real estate holding company, property VAT, resale capital-gains treatment, family transmission or a move toward a property-dealer model.

In real estate, a good tax decision cannot be judged only in the acquisition year. It affects the holding period, borrowing capacity, cash circulation between entities, tax on resale and the way the portfolio is transmitted. A specialist real-estate tax accountant therefore has to reason asset by asset and structure by structure, not only at the level of one annual return.

The aim is to help property investors, SCI shareholders, furnished-rental landlords, family holding structures and more active operators choose a tax path that remains coherent from acquisition to resale and from one generation to the next.

The tax choices that change net return

SCI under IR or SCI under IS

This is still the most common real-estate tax question, and it depends entirely on the project's horizon and economics.

SCI à l'IR (income tax) keeps fiscal transparency: each partner is taxed on their share of net property income at their marginal rate (up to 45% + 17.2% social charges). It allows the déficit foncier rule: losses from deductible works can offset other taxable income up to €10,700 per year. The property is not depreciable, but the capital gain on sale benefits from full IR exemption after 22 years and full social-charge exemption after 30 years.

SCI à l'IS (corporate tax) allows depreciation of the property (typically 25-30 years for the building, excluding land), full deduction of director compensation and a more favourable interest profile. IS rates are 15% on the first €42,500 of profit (SME), 25% beyond. But on sale, the capital gain is taxed as corporate profit (25%) without holding-period relief, making the IS option costly if a near-term sale is planned.

We model both regimes over a 5-10 year horizon, factoring in your marginal tax rate, planned works, expected rents, exit timing and family transmission plans.

LMNP, LMP and furnished rentals

LMNP (Loueur Meublé Non Professionnel) under the real regime can neutralise much of the tax burden through depreciation, but it requires clean accounting, a defensible depreciation schedule and a clear view of how the landlord's status may evolve if the portfolio grows.

Under LMNP at real regime, the building (excluding land, typically 15-20% of total value) is depreciated over 25-30 years, furniture over 5-10 years, and works over 10-15 years. The depreciation often reduces taxable rental profit to zero for 10-15 years.

Once rental income from furnished property exceeds €23,000 per year and 50% of household income, the LMP (professional) status applies automatically, with major implications: rental losses become deductible against global income, but the operator falls under URSSAF social contributions on profits, and the activity is included in the IFI base differently. We monitor this threshold for every client approaching the limit.

Property VAT and optional VAT on rents

In property matters, VAT mistakes can be expensive. Commercial-rent VAT options, VAT on margin (for marchands de biens), VAT on total sale price and para-hotel activity rules all need proper qualification and documentation before the deal is executed.

VAT on commercial rent: leases of commercial premises are by default exempt from VAT, but the lessor can elect VAT (the election cannot be withdrawn before 1 January of the ninth year following the year it was made), allowing recovery on acquisition/works costs (~20% saving). The election must be formally notified to the tax office and the tenant.

VAT on margin (marchands de biens): taxes only the difference between sale and purchase prices. Eligibility depends on the original acquisition (must not have given rise to VAT deduction), the nature of the asset and the scale of works. Misqualification triggers full-price VAT, which can erase the deal's margin.

Para-hotel VAT (10%) on furnished rentals: requires at least three of four services (breakfast, regular cleaning, linen, reception) and proper service-invoicing structure. The option allows VAT recovery on acquisition and works.

Property holding companies and family transmission

Once several assets, several shareholders or several generations are involved, the holding patrimoniale structure becomes relevant. It offers:

  • Régime mère-fille: dividends from SCI subsidiaries subject to corporate tax flow to the holding at quasi-exemption (1.25% effective tax rate); an SCI under income tax pays no dividends, its share of profit being taxed directly at the holding.
  • Cash mutualisation: cash from one SCI can finance acquisitions in another via current-account loans or capital injections, without exiting the holding's tax shelter.
  • Transmission via share donation: with usufruct reservation, the donation tax base is reduced by 30-60% depending on the donor's age. Combined with the €100,000 per parent/per child allowance renewable every 15 years, this lever can pass a significant portfolio with minimal duties.
  • Dutreil pact: under conditions, transmission of shares in an operating real-estate company (marchand de biens, hotellerie) can benefit from an exemption from gift and inheritance duties on 75% of their value.

How we work on a real-estate tax file

1. Start from the actual project

We look at the asset type, use model, expected holding period, lenders, shareholders, income goals and exit scenario to understand whether the logic is rental yield, patrimonial holding, active development or family transmission.

2. Build comparative scenarios

Each scenario integrates current tax, depreciation, available cash, refinancing capacity, dividends, resale tax and the shareholders' personal position. This avoids tax choices that later damage flexibility or liquidity. The scenarios are quantified across a 5-10 year horizon.

3. Move into execution

We then help create or update the structure, organise the accounting setup, prepare the right returns (2072 for SCI à l'IR, 2065 for SCI à l'IS, 2031 for LMNP), secure tax options, document sensitive steps and coordinate with the notaire, lawyer or bank where needed.

Common pitfalls we help investors avoid

1. Choosing SCI à l'IS purely for depreciation, without modelling the exit

The IS option is attractive during operating years (depreciation reduces current tax) but punitive on sale (25% IS on the gain with no relief). For a 7-10 year hold with planned exit, IR often wins.

2. Missing the LMP threshold

Crossing the €23,000 + 50% threshold without preparation can trigger URSSAF reassessment and a fundamentally different tax position. We monitor this for every active LMNP client.

3. Skipping the VAT option file

The VAT option on commercial rent must be in writing, formally notified, and kept in place until at least 1 January of the ninth year following the year it was made. Many investors recover VAT informally on works and find themselves reassessed.

4. Confusing investment SCI and marchand de biens

A real estate operator who flips properties may be requalified as a marchand de biens, losing capital-gains tax relief and triggering full BIC taxation plus VAT-on-margin obligations. Activity qualification must be set from the first deal.

5. Leaving the family transmission until too late

Donations with usufruct reservation are most powerful when the donor is young. Waiting reduces the discount. We build the transmission roadmap as part of the initial structuring.

What to check before acquisition or restructuring

Before acting, review acquisition method, price allocation, financing structure, fees, planned works, intended use, income qualification, shareholder agreement and exit strategy. Those choices directly shape both future accounting quality and the tax strength of the file. The right structure for a long-term rental property may not be the right one for a commercial property, a serviced residence, a family SCI or a quick resale project.

What you should get in the first 90 days

The first quarter delivers:

  • a clear view of the relevant structures and the rationale for each;
  • the immediate tax risks worth addressing (VAT option, LMP threshold, IFI exposure);
  • the realistic options on IR, IS, VAT and holding design;
  • the supporting documents or cleanups still required;
  • a more readable link between tax choices and true net return;
  • a roadmap that stays usable from acquisition to exit and from one generation to the next.

Hayot Expertise for your real estate tax file

We combine accounting expertise with real-estate tax knowledge: SCI IR / IS arbitrage, LMNP real-regime depreciation, para-hotel VAT structuring, marchand-de-biens qualification, holding patrimoniale, Dutreil pact, and capital-gains optimisation. We work nationally with a digital model: same delivery quality, faster turnaround.

Free quote within 24 hours, first meeting on the house to review your portfolio, identify quick wins (VAT option, LMNP regime, IR vs IS arbitrage) and define a 12-24 month roadmap aligned with your patrimonial goals.

Key tax positions we monitor each year

PositionWhen it mattersAction
LMNP real-regime depreciationEvery year, on every furnished unitUpdate schedule and 2031
LMP threshold (€23k + 50% test)Yearly, when furnished rents growFlag 3 months ahead of crossing
Property capital-gains reliefOn every sale, IR-regime SCICalculate holding period and abatements
Mère-fille electionAfter holding restructuringConfirm at least 5% ownership and the two-year holding period
Para-hotel VAT optionAcquisition of new build, refurbished assetSet up services and invoicing
IFI baseYearly, JanuaryReconcile properties, debt and exemptions
Dutreil pactOperating real-estate companiesMulti-year commitment tracking

These positions are reviewed at every major transaction (acquisition, sale, refinancing, donation) and at the annual close, so the tax trajectory stays defensible across the holding period and the eventual exit. For investors with international exposure (cross-border SCIs, non-resident partners, foreign properties), we coordinate with the relevant tax treaty rules and ensure consistent treatment in France and the residence country.

The IFI (real estate wealth tax) in 2026

The IFI (impôt sur la fortune immobilière) applies to households whose net real estate assets exceed €1.3m on 1 January, with a progressive scale from 0.5% to 1.5%. We work on four main levers:

  1. Deductibility of debts actually taken out to acquire, keep or improve a taxable property. Interest-only (in fine) loans have been restated under a specific formula since 2018.
  2. Split ownership: the bare owner is not taxed on the full value; the usufructuary is generally taxed on the full value, except in the legal cases where the value is split between them. The position has to be checked asset by asset.
  3. Holding through an operating company: a property held by an active commercial company falls outside the IFI base when it is used for the activity (for example offices or warehouses used by the owner's SME).
  4. Business-asset exemption for furnished letting (Article 975 of the French Tax Code): furnished premises can be exempt when the household earns more than €23,000 a year in receipts from the activity and derives more than 50% of its professional income from it, provided the activity is profitable. The Dutreil pact, often wrongly cited here, does not reduce IFI: it concerns gift and inheritance duties.

Property capital gains: three very different regimes

Type of holdingRegimeAllowanceRate
Individual or SCI under income taxPrivate property capital gainProgressive: income tax exemption at 22 years, social levies at 30 years19% income tax + 17.2% social levies + 2 to 6% surtax
SCI under corporate taxBusiness capital gainNoneCorporate tax at 15 to 25% on (price minus net book value)
LMP (professional furnished letting)Business capital gain, Article 151 septiesFull exemption after 5 years if receipts are below €90kVariable

The real difference in tax between these three regimes can reach €200k to €500k on a property bought for €600k and sold for €1m after 15 years. It is the most structuring decision at the time of acquisition, and the hardest to correct afterwards.

Other topics we handle routinely

Property development and off-plan sales (VEFA). For construction or heavy refurbishment operations intended for resale, the tax and accounting treatment follows specific rules: an operation account per programme, the treatment of deductible VAT on works, and monthly follow-up in coordination with the developer, the notaire and the sales agents. We regularly support small and medium-sized operations (5 to 50 units).

Withholding at source and instalments. Property income and LMNP furnished-letting profits are subject to monthly or quarterly instalments collected by the tax authority (DGFiP). The right settings avoid unnecessary cash outflows and allow an immediate adjustment when income falls (rental vacancy, works). We review this modulation every year with our clients.

Non-Resident and Foreign Investors in French Property

If you live abroad and hold property in France, your tax treatment is not decided by French rules alone. It depends on the bilateral tax treaty between France and your country of residence, and each treaty is different. The same applies in reverse, for a French resident owning property abroad. Getting this wrong on rental income, or on a resale capital gain (plus-value immobilière), is a common and costly mistake in cross-border files.

A departure from France can also trigger the exit tax (Article 167 bis of the French Tax Code) on latent gains on shares, where the taxpayer was French tax resident for at least six of the previous ten years and holds at least 50% of a company or shares worth more than €800,000. We handle these files with international tax lawyers, notably for owners moving between Europe, North America and the Maghreb.

Real-estate tax positions we monitor

Déficit foncier offset against global income

Formula

Deductible charges minus rents, within the annual cap

Target

€10,700/yr (€21,400 for energy renovation)

LMNP to LMP crossing threshold

Formula

Furnished rents above €23,000 AND above 50% of household income

Target

€23,000 and 50%

SCI corporate-tax (IS) rate

Formula

15% up to the profit cap, then 25%

Target

15% up to €42,500, then 25%

Capital-gains exemption (individual / SCI IR)

Formula

Progressive relief by holding period

Target

22 years (IR) / 30 years (social charges)

IFI wealth-tax threshold

Formula

Net real-estate assets on 1 January

Target

€1.3M (0.5% to 1.5% scale)

Dividend upstreaming in a holding (mère-fille regime)

Formula

Dividends from IS-taxed subsidiaries (including IS SCIs) flowed up at quasi-exemption

Target

95% exempt

The market and its segments

French real estate combines several overlapping tax logics: rental income, BIC, corporate tax, property VAT, capital gains, SCI ownership, furnished rentals and transmission planning. The role of the real-estate tax accountant is to arbitrate between net return, legal flexibility and patrimonial goals.

IR vs IS
Core comparison
SCI, LMNP, commercial property
Typical assets
bad exit economics
Main risk
cash + resale + transmission
Decision lens
family SCI structuresLMNP and LMP landlordsproperty holding companiescommercial-property investorsmulti-asset portfoliosfamily transmission situations
Practical framework

Practical guide before structuring a real estate portfolio

01

Define the real objective

Clarify whether the project is mainly about yield, capital accumulation, family transmission, resale or shared ownership before choosing a structure.

02

Compare structures before acquisition

Test direct ownership, SCI under IR, SCI under IS, LMNP and holding-company routes before signing, because the best decision is rarely made after closing.

03

Check VAT and income qualification

Rental type, works, commercial use and tax options should be qualified early to avoid expensive VAT or classification mistakes.

04

Model the exit, not just the first year

A structure that looks efficient in year one can become costly on resale or transmission if the long-term path is ignored.

FAQ

Frequently Asked Questions

What is the difference between an accountant and a real estate tax accountant?

A real estate tax accountant combines bookkeeping and tax advice on patrimonial transactions: SCI IR/IS arbitrage, LMNP optimisation, real estate holding, VAT on margin. Unlike a tax lawyer, they also produce the tax filings (2072, 2031, full tax pack) and provide annual follow-up on the property investments.

SCI under IR or IS: how to choose for rental property?

An SCI under IR is fiscally transparent: rental income is taxed at the partners' marginal rate, with property-deficit relief available. It suits long-term holding. An SCI under IS allows the property to be depreciated and reduces current taxation, but the capital gain on sale is heavily taxed. The choice depends on duration and strategy.

How do you optimise VAT on margin for a property dealer (marchand de biens)?

VAT on margin taxes only the difference between sale and purchase prices, not the full price. It applies when the initial purchase did not allow VAT recovery (existing property, sold by an individual). The accountant documents each deal, checks eligibility and secures the option to avoid requalification as VAT on full price.

What is the LMNP real regime and when is it advantageous?

The LMNP real regime allows depreciation of the building (excluding land) over 20-30 years and deduction of all real expenses (interest, works, taxes, fees). It becomes advantageous from €25,000-€30,000 of annual rent, often neutralising 100% of taxation for 15-20 years after acquisition.

How do you set up a real estate holding company and what are the benefits?

A real estate holding (SAS or SARL under IS) holds shares in subsidiary SCIs. It enables quasi-exempt upstream dividend flows from subsidiaries subject to corporate tax (mère-fille regime, residual taxation ~1.25%), cash pooling to reinvest, optimised transmission via share donation, and a clean split between personal assets and real estate holdings.

What tax applies to the capital gain of an SCI under IS?

Under SCI à l'IS, the capital gain is calculated on the difference between the sale price and the net book value (after depreciation), then taxed at the 25% corporate rate (or 15% within the €42,500 SME band). There is no holding-period relief, unlike the IR regime.

How can you pass on a real estate portfolio while limiting gift duties?

The main levers are: donation of bare ownership with usufruct retention (taxable base reduced by 30-60%), temporary démembrement of an SCI, donation of holding shares (consolidated debt deducted from value), and the €100,000 per parent and per child allowance renewable every 15 years. A succession simulation is essential.

Should you opt for VAT on commercial-rental income?

Opting for VAT on commercial rent allows recovery of VAT on acquisition or renovation works (up to 20% of cost). In exchange, rent is invoiced with VAT, neutral for a VAT-registered tenant. This option cannot be withdrawn before 1 January of the ninth year following the year it was made and must be formally notified to the tax authority.

Your guarantees

A Paris firm working remotely across France

We can work with you remotely anywhere in France, using online steering tools that keep your documents and your figures in one place.

Regulated firm

Samuel Hayot is a French chartered accountant registered with the Ordre of Paris Île-de-France, and a statutory auditor on the list drawn up by the H2A, member of the CRCC de Paris.

National reach

The firm is in Paris 8. It works remotely and can support a business located anywhere in France.

Modern tools

Pennylane, Dext and Silae, with as many tasks automated as possible, so your figures stay visible and the work moves quickly.

Direct contact

The phone number is at the bottom of every page, getting in touch is simple, the engagement letter comes quickly and the mandate is scoped without detours.

Useful resources

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Perspectives

Related articles

Samuel Hayot, Chartered Accountant registered with the French Order (OEC Paris-IDF)

Written by Samuel Hayot

Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.

Regulated French firmUpdated 02 July 20262 sources cited

Regulated French accounting firm based in Paris 8, whose founder is also a statutory auditor, built to support companies across France with a digital and decision-oriented approach.

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Official and operational sources cited for this page.