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UK Ltd or US LLC Holding French Property: What Owners Need to Know

  • 12 août
  • 8 min de lecture

Many British and American owners hold a French home or rental flat through a UK limited company or a US LLC, either directly on the title or above a French SCI. The structure often looked tidy on paper years ago. In practice, it now creates a stack of French compliance duties that personal ownership, or a simple SCI with individual partners, usually avoids.


This guide is for you if you already own through a Ltd or LLC, or if you are deciding how to buy. It explains the two common ownership patterns, what your bilingual notaire actually does, how France's annual 3% tax (TVVI) changes from 2027, and which practical traps to fix first. For the reform itself, keep French 3% Tax (TVVI): What Changes From 2027 open beside this page.


FrenchNotaires matches you free of charge with vetted bilingual notaires, typically within about 48 hours, in person (for example near Nice, Cannes or Paris) or by video call.


Last verified: August 2026. TVVI doctrine (BOFiP BOI-PAT-TPC) has not yet been rewritten for Law no. 2026-534; confirm filing modalities with your advisers before May 2027.


The two common patterns


Most British and American files fall into one of these shapes:


  1. Direct holding: the UK Ltd or US LLC appears as owner on the French deed and land registry extract.

  2. Holding through an SCI: a French SCI owns the property; the Ltd or LLC owns some or all of the SCI shares.


Both are legal. Both are heavier than buying in your own name. The second pattern is especially common on the Côte d'Azur and in Paris, because advisers once preferred a French company on title with a foreign shareholder behind it. From a French tax transparency angle, that foreign shareholder is often where the 3% tax analysis starts.


Why owners used a Ltd or LLC


Owners rarely chose the structure for French land-registry convenience. Typical motives were:


  • limiting personal liability or ring-fencing an investment from other assets;

  • aligning the French purchase with an existing UK or US group / family investment company;

  • privacy preferences (the company, not the individual, sits on the French title);

  • inheritance or partnership planning designed mainly under English or US law;

  • historical advice given when annual French disclosure for entities felt optional.


Some of those motives still hold. Others collide with French anti-avoidance rules, banking KYC, mortgage practice and the 2027 TVVI reform. Before you keep or create a Ltd/LLC holding, ask what problem the company is still solving in France, not only at home.


Personal title, SCI or foreign company: a practical comparison


Question

In your own name

French SCI (individual partners)

UK Ltd / US LLC (direct or above SCI)

Who is on the French title?

You

The SCI

The Ltd/LLC, or the SCI with the foreign company as partner

Notaire complexity at purchase

Standard foreign-buyer file

SCI creation or share subscription + property deed

Corporate capacity, UBO checks, translations, often longer timelines

Annual French entity filing risk (TVVI)

Not in scope as a legal entity

Often covered via SCI returns (e.g. 2072) if partners are individuals

High: annual 2746-SD logic from 2027 if disclosure exemption is claimed

French representative for TVVI

N/A

Usually N/A for a French-seated SCI

Likely required if no French permanent establishment (CGI art. 990 FA)

Everyday management

Lightest

Assemblies, accounts, partner decisions

Home-country company law + French property compliance


If you are still choosing a vehicle, start with Buying a French Property Through an SCI and SCI Advantages and Disadvantages for Foreigners before defaulting to a foreign company on title.


Buying: what the notaire needs from a foreign company


A French notaire can receive a deed for a UK Ltd or US LLC buyer, but the file is heavier than for an individual. Expect requests for:


  • certificate of incorporation / articles (and recent good-standing evidence where used);

  • proof of directors' or managers' authority to buy and to sign (board minutes, resolutions, operating agreement extracts);

  • ultimate beneficial owner information for AML checks;

  • sworn or certified translations of key corporate documents;

  • apostille or legalisation where the issuing country's formalities require it;

  • a French or bilingual power of attorney if signatories will not attend in person.


Banks and mortgage lenders are often stricter with foreign corporate buyers than with individuals or French SCIs. Many non-resident mortgages assume personal borrowers. Budget extra time between the compromis de vente and the acte authentique.



The 2027 TVVI trap for UK Ltd and US LLC owners


France's annual 3% tax on the market value of French property held by legal entities (TVVI, Articles 990 D et seq. CGI) is the compliance issue most Ltd/LLC owners underestimate. The tax is calculated on gross market value as at 1 January, with no debt deduction. On a €1,500,000 flat, 3% is €45,000 a year if no exemption is secured.


Law no. 2026-534 of 25 June 2026 (JO 26 June 2026) changes the exemption procedure from the 2027 campaign:


  • the old standing engagement de communiquer no longer secures exemption;

  • eligible entities must disclose through an annual filing (in practice form 2746-SD) by 15 May;

  • entities without a French permanent establishment must designate a French contact under new Article 990 FA CGI when they file.


If your UK Ltd bought a Provençal house twenty years ago, signed a commitment letter once, and never filed again, treat 2026 as the year to rebuild the file: ownership chart, shareholders above 1%, 1 January valuation, SIREN / e-filing access, and a French representative arrangement.



Start with the French deeds, not the UK or US company file alone


A bilingual notaire can pull the title, SCI statutes and share register so you know whether the Ltd or LLC owns directly, sits above an SCI, or both across several properties.



When the Ltd or LLC sits above a French SCI


A French SCI with individual partners that files its annual return (often form 2072) has historically often avoided a separate 2746-SD under administration guidance. That comfort does not automatically protect a UK Ltd or US LLC that owns SCI shares.


In a chain such as "US LLC → French SCI → apartment", analyse each entity:


  • the SCI may meet French domestic filing duties;

  • the LLC may still need its own TVVI disclosure analysis and, from 2027, a French representative if it has no French PE;

  • interposed entities can be jointly liable for unpaid TVVI (Article 990 F CGI).


If you leave the representative box blank on the foreign company's filing, notices may be deemed served on the entity closest to the property, often the SCI. That can surprise French-resident co-partners who never agreed to manage a foreign parent's tax correspondence.



Ongoing French duties beyond the 3% tax


Even when TVVI is handled, a Ltd/LLC holding still sits inside a wider French cost stack:


  • Local property taxes (taxe foncière, and any remaining occupancy-related charges where applicable);

  • IFI exposure for individuals who ultimately hold French real-estate wealth above the threshold through shares;

  • rental income reporting if the property is let (rules differ for furnished vs unfurnished, and for corporate vs transparent structures);

  • home-country reporting (UK corporation tax / US federal and state rules, check-the-box elections, CFC regimes) that your French notaire does not replace.



Selling or transferring: notaire, capital gains and representatives


Exit can mean selling the property, selling SCI shares, or transferring Ltd/LLC shares abroad. Each path has different French formalities.


  • Property sale by the company: the notaire handles the acte authentique, capital-gains calculation and registration. Corporate sellers often need a French fiscal representative under Article 244 bis A when tax is due; that role is not the same as the new TVVI representative under Article 990 FA.

  • SCI share sale: partner approvals, pre-emption clauses and valuation rules matter; form 2048-M-SD may apply instead of 2048-IMM-SD.

  • Transferring only the UK Ltd or US LLC shares: the French land registry may not change, but French tax and reporting analysis can still be triggered depending on asset composition and the parties involved. Do not assume an offshore share deal is invisible in France.



Death, divorce and family planning


Owning through a Ltd or LLC does not erase French forced-heirship questions for French-situs assets, nor does it automatically import English probate or US estate administration into the French land registry. On death, your heirs may face:


  • proof of who controls the foreign company;

  • French succession formalities if French property or French-situs rights are involved;

  • possible mismatch between the company's constitutional documents and French notarial expectations.


If estate planning was the original reason for the company, stress-test that plan with a bilingual notaire and counsel in your home country. Starting points: Inheriting Property in France as a Non-Resident, International Succession in France and Tax Residence and French Notarial Matters.


Action checklist if you already own through a Ltd or LLC


Step

Action

1

Collect the French title deed, any SCI statutes and the current share register.

2

Draw the ownership chart from ultimate owners down to the French property.

3

Find any old TVVI commitment letter and note whether anyone ever filed 2746-SD.

4

List shareholders or members holding more than 1%, with current addresses.

5

Ask advisers whether each foreign entity needs 2746-SD from 2027 and a French representative.

6

Start SIREN / impots.gouv.fr access early if electronic filing will be required.

7

Diarise 15 May 2027 and align valuation support as at 1 January 2027.

8

If you plan to sell or gift, book a bilingual notaire before marketing or transferring shares.


When unwinding the structure makes sense


Keeping a Ltd or LLC can still be rational for multi-asset groups, institutional investors or genuine commercial holdings. For a single holiday home held for family use, many owners eventually prefer:


  • personal ownership; or

  • a French SCI with individual partners only.


Unwinding is itself a notarial and tax project: capital gains, registration duties, lender consents, and home-country exit charges can all appear. Do not dissolve or transfer "on paper abroad" without a French deed plan. A bilingual notaire can map the French steps; your UK or US tax adviser must confirm the domestic consequences.


Commercial or mixed-use assets raise extra issues: see Buying Commercial Property in France Through a Company.


Frequently asked questions


Can a UK Ltd or US LLC buy French property?


Yes. A French notaire can receive the deed, subject to corporate capacity documents, AML checks, translations and, often, longer banking timelines than for individual buyers.


Is a foreign company better than an SCI?


Not by default. For many non-resident families, a French SCI with individual partners, or personal title, is simpler for day-to-day French formalities. A Ltd or LLC is usually justified by group, liability or home-country reasons, not by French conveyancing convenience.


Does Brexit change anything for a UK Ltd?


The company can still own French property. Brexit does affect some EU-linked tax dispensations in other areas (for example certain sale-side fiscal representative rules for individuals). For TVVI, the key tests are the entity's seat, treaty position, filing and permanent establishment, not British nationality alone.


We signed a commitment years ago. Are we safe until 2027?


Past years covered by a valid commitment are not rewritten solely by the reform. From the 2027 campaign, exemption that once rested on the commitment requires actual annual filing. Start preparation in 2026.


Our LLC owns an SCI with French individual co-partners. Who files what?


Analyse each layer. The SCI may meet French domestic returns; the LLC may still need its own TVVI filing and French representative from 2027. Joint liability rules can pull the SCI into recovery if the foreign layer defaults.


Can the notaire be our TVVI representative?


Usually no. The notaire handles deeds and structure mapping. The Article 990 FA contact and any sale-side accredited fiscal representative are separate roles. Ask at matching stage so expectations are clear.


How quickly does FrenchNotaires respond?


FrenchNotaires aims for bilingual notaire introductions within about 48 hours across a network exceeding 340 practitioners.


Sources


Ready to review your Ltd or LLC holding with a bilingual notaire?


Tell FrenchNotaires whether the company owns directly or through an SCI, where the property sits, and whether you plan to keep, sell or unwind the structure.



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