Property Investment in France vs. Belgium: A Practical Overview

Investing in property and managing real estate in France and Belgium involves important legal, fiscal, and administrative differences. Below you will find a useful glossary and an overview of the key considerations for real estate entrepreneurs operating in both countries.

Glossary: Key terms for property investors

Belgium	France	Meaning
Cadastral income	Valeur locative cadastrale	An indication of the rental value of a property
Notary	Notaire	Responsible for the legal registration of property transactions
Registration duties	Droits d’enregistrement	Tax on the purchase of property
Cadastral Income	Taxe Foncière	Annual land/property tax
Property withholding tax	Taxe d’Habitation (afgeschaft voor hoofdverblijven)	Local tax for property owners/occupants
Tenancy agreement	Bail	Legal contract between landlord and tenant
Property manager (syndic)	Syndic de copropriété	Manager of a co-owned building (VME in Belgium)
Right of superficies	Droit de superficie	Right to construct on someone else's land
Mortgage loan	Crédit Immobilier	Property financing through a loan
VAT on new builds	TVA sur l’immobilier neuf	21% in Belgium, 20% in France (with exceptions)

Practical Differences in Real Estate Entrepreneurship in France and Belgium

1. Purchase process and notary fees

In Belgium, the buyer pays registration duties of 12% (or 3% in Flanders for a first home) along with notary fees.
In France, registration duties are 7–8% for existing property and 2–3% for new builds. Notary fees are similar to those in Belgium.
French notaries have a more comprehensive role, including collecting taxes on behalf of the state.

2. Fiscal differences: property taxes and income

In Belgium, cadastral income is used as the basis for property tax, while in France the valeur locative cadastrale determines the amount of tax due.
In France, you pay the taxe foncière (owner’s tax) and, until 2023, also the taxe d’habitation as an occupant (now largely abolished for main residences).
Rental income in France is taxed either as BIC (Industrial and Commercial Profits) or as property income (revenus fonciers), depending on the rental type. In Belgium, residential rental income is typically taxed on a flat-rate basis according to the cadastral income. See this article for more on income from holiday rentals.

3. Letting and rental legislation

In France, tenant protection rules and rent indexing caps are stricter, depending on the area (e.g. Paris).
In Belgium, rules vary by region (Flanders, Wallonia, Brussels), but there is greater flexibility in rental agreements and rent setting.
France offers tax advantages for furnished lettings under the LMNP scheme (Loueur Meublé Non Professionnel), which can be beneficial for investors.

4. Co-ownership and property management

In France, a syndic de copropriété is required for multi-owner buildings, and co-ownership rules are strictly regulated.
In Belgium, a Co-Owners’ Association is mandatory for apartment buildings, but management regulations are slightly more flexible than in France.

5. Inheritance tax and transfer

In France, inheritance tax rates are generally higher than in Belgium, particularly for property passed to non-relatives.
In Belgium, inheritance taxes vary by region: inheritance tax in Flanders is generally lower than in Wallonia and Brussels, especially for family transfers.

Conclusion

Investing in real estate in France and Belgium presents various legal and fiscal challenges. France offers attractive benefits for furnished rentals and new developments, whereas Belgium features simpler inheritance and tenancy legislation. For optimal management of your property in France, it is crucial to consider local regulations and fiscal optimisation. RFN is available to assist you with expert advice!