Since May 28, 2026, executives and high‑net‑worth individuals with cross‑border assets face a markedly more intrusive tax environment. Multilateral frameworks, EU directives and new domestic datasets have materially increased the visibility of overseas property and financial holdings to the French tax authorities.

This article explains practical defenses,compliant, litigation‑aware and tailored to executives,against increased scrutiny following recent OECD guidance, the EU transparency wave and French domestic measures affecting beneficial‑ownership, real‑estate databases and reporting obligations. The recommendations below prioritise legal certainty, documentation and preventive engagement with the tax administration.

Understand the new global minimum tax landscape

The OECD’s Pillar Two minimum tax regime and its consolidated administrative guidance have changed multinational tax contours and the incentives for shifting profits and assets into low‑tax jurisdictions; those rules and ongoing administrative guidance remain a critical context for any cross‑border wealth structure used by corporate groups or executives.

Pillar Two implementation and related domestic safeguards (including QDMTT and UTPR mechanisms in many jurisdictions) can affect holding companies and service‑company models that historically sheltered income or reduced local effective tax rates. Executives should therefore reassess whether an entity used to hold or operate property overseas now triggers top‑up tax or countermeasures in France or other jurisdictions.

Where groups face potential Pillar Two charges, planning must shift from secrecy to robustness: coherent transfer‑pricing, demonstrable substance, contemporaneous documentation and, where appropriate, coordination of group elections and elections under domestic regimes to avoid unilateral adverse adjustments.

Monitor evolving transparency and reporting regimes

EU and OECD information‑exchange instruments have expanded in scope. The EU DAC7 (platforms) is active and DAC8/CARF bring crypto and transaction‑level reporting into the transparency perimeter, with many EU states implementing the new rules and transaction reporting expected from 2026,2027. Executives must assume that custodial, platform and crypto flows will be visible to tax authorities.

France has reworked access to its beneficial‑owner register: public access to the Registre des Bénéficiaires Effectifs (RBE) was restricted and the modalities refocused after EU case law and transposition of recent AML rules, but competent authorities and obliged entities continue to have wide access. At the same time, national projects,such as a consolidated property‑ownership database,have created new linkable datasets for the tax administration. These developments materially increase the probability that ownership chains that rely on opaque intermediaries will be reconstructed.

The Common Reporting Standard (CRS) and its technical updates remain a cornerstone of automatic exchange; financial institutions and many custodial platforms are upgrading reporting systems and XML schemas, increasing the reliability and timeliness of cross‑border data exchanges. In short: hiding assets in financial or digital platforms is increasingly ineffective.

Reassess ownership structures and residency exposures

For non‑residents and new French residents the Impôt sur la Fortune Immobilière (IFI) still focuses on real property; French residents are taxed on worldwide real‑estate assets, while non‑residents are subject only to French‑located property above the statutory threshold (the IFI threshold and brackets remain set by the tax code). Executives who hold French property directly or through entities (SCI, corporate vehicles) must revalidate whether their structure creates French tax exposure or an IFI filing requirement.

Common holding structures,SCIs, foreign corporate wrappers, trusts and PPLI arrangements,have differing French tax profiles. Trusts and many foreign vehicles generate mandatory French reporting obligations (e.g., the trust declaration regime under article 1649 AB of the CGI) and penalties for non‑disclosure can be material; these regimes should be audited urgently by counsel where a trustee, settlor or beneficiary has a French nexus.

French CFC‑type rules (notably Article 209 B CGI and related provisions) allow France to attribute profits of controlled foreign companies to French taxpayers in defined circumstances; this continues to be a key anti‑avoidance lever that can reach passive income parked in foreign entities lacking real substance. Review any low‑tax subsidiaries, the economic rationale for their place of operations and the documentation that proves substance.

Strengthen documentation, valuations and advance rulings

Contemporaneous documentation is the first line of defence: asset valuations, independent appraisals of real property, intercompany agreements, minutes evidencing commercial purposes and policies that prove economic substance materially reduce the risk of successful reassessments. Auditors and tax inspectors focus on gaps between declared economics and observable data. (Where valuations are complex, obtain independent expert reports and keep them on file.)

Use formal administrative tools: France’s advance‑ruling and rescrit procedures (including rulings on permanent‑establishment status and specific transactions) provide binding or protective certainty in many scenarios and can be decisive for executives contemplating restructuring. A rescrit or an advance ruling should be sought early for any novel structure or transaction that materially affects French tax exposure.

Where transfer pricing or group service allocations matter to the allocation of profits to French taxable bases, contemporaneous transfer‑pricing studies and, where feasible, APAs or documented bilateral approaches are essential. These records are also critical if you face a MAP or treaty‑based dispute.

Prepare for higher audit intensity and cross‑checks

The DGFiP has enlarged specialised patrimonial‑control units and invested in data analytics and coordinated controls: recent parliamentary reporting and administrative documents show targeted efforts on high‑value taxpayers and patrimonial controls, with a national support centre for complex cases. In practice, this means faster, deeper and more data‑driven audits for executives and groups.

Tax administrations are combining new datasets,property registers, corporate registries, CRS/CARF/AEOI feeds and platform disclosures,to identify mismatches. French authorities also increasingly use analytical tools and, in some contexts, AI to prioritise cases; this raises the probability that previously safe structures will attract inquiries. Good recordkeeping, prompt responses and legal representation materially improve outcomes during these audits.

If an audit begins, engage specialised tax litigation counsel immediately. Early procedural steps (requests for precisions, proposals of regularisation, and negotiated settlements) are time‑sensitive: an experienced adviser can limit penalties, demonstrate good faith and, if necessary, prepare an administrative or judicial challenge that preserves rights while stabilising exposure.

Practical planning checklist for executives and families

Map and document. Create a comprehensive, dated inventory of all real‑estate interests (direct and indirect), corporate wrappers, trustee arrangements and custodial accounts; keep independent valuations for high‑value assets and contemporaneous minutes explaining business reasons for each entity.

Test substance and purpose. For each foreign entity ask: what employees, premises, contracts and real commercial activity support the entity’s profit? If substance is thin, either remediate quickly or migrate the activity to an appropriately staffed and resourced entity. Where applicable, align legal form and accounting treatment to the underlying economics to reduce look‑through risk.

Use preventive procedures. Seek rescrits/advance rulings for novel structures or transactions; maintain contemporaneous transfer‑pricing files; register and comply with trust and foreign‑account declarations; and, when gaps are found, consider structured voluntary regularisation with counsel rather than ad hoc secrecy. These steps materially reduce both exposure and penalty risk.

Protecting executive wealth and overseas property in France is no longer primarily about opacity,but about legal certainty, robust documentation and timely engagement with evolving international and domestic rules. Effective prevention combines careful legal structuring, substantive business reality and proactive dialogue with advisers and, when necessary, the tax administration.

Given the speed of change since 2024,2026 in OECD, EU and French regimes, every cross‑border holding should be audited by a specialist team that can coordinate tax, corporate and estate law solutions,and if you have material exposure, start that review without delay.