Residing in Switzerland with assets in France, receiving income from foreign sources, preparing a cross-border transfer of assets between generations… Structuring your assets between France and Switzerland is never a matter of standard logic. Each choice, whether it concerns the form of ownership, place of residence, matrimonial property regime or investment vehicle, has tax, civil and inheritance consequences. To ensure that these choices are secure and form part of a coherent wealth strategy, a few structuring principles need to be taken into account from the outset.   Integrated approach to Franco-Swiss heritage   In an international context, wealth structuring cannot be limited to an isolated tax or legal approach. It must be based on a cross-reading of domestic law rules, bilateral tax treaties, civil law (inheritance and matrimonial law) and personal and family objectives.The place of tax residence, which largely determines the taxation of income and capital gains, is one of the key points to anticipate. But simply changing your address is not enough to change your tax domicile. The Franco-Swiss tax treaty of September 9, 1966, interpreted in the light of administrative doctrine, requires a concrete analysis of the center of vital interests, the location of assets, the household and the professional activity.   Securing asset ownership: choice of vehicle and terms and conditions   Poorly structured cross-border assets can quickly generate tax friction, conflicts of classification (professional or private assets, income from movable or immovable property), and even cases of double taxation. It is important to structure the

Holding assets in several countries raises complex and sometimes sensitive issues when it comes to preserving them over the long term. Entrepreneurs, managers and families whose assets are split between France, Switzerland and other jurisdictions are exposed to the risk of recharacterization, conflict of laws and blockage in the event of death or changes in their situation. Wealth protection cannot be approached in a one-size-fits-all manner. It is based on arbitrations adapted to the nature of the assets, their location, local rules of civil and tax law, and the long-term strategy adopted.   Anticipating the tax risks of cross-border ownership   Cross-border wealth is often exposed to a double constraint: on the one hand, excessive tax optimization can lead to contestation or recharacterization; on the other, a lack of structuring can increase taxation or render certain transfers inapplicable. Certain forms of ownership, which are tolerated in France, can produce very different tax effects in Switzerland, and vice versa. This is particularly the case with non-resident non-trading property companies or family holding companies. When poorly managed or inadequately justified, these structures can be assimilated to structures set up primarily for tax purposes, exposing their holders to potential reassessments, the questioning of exemptions or taxation in several states. Conversely, direct ownership of assets without an appropriate legal shield can lead to excessive exposure to inheritance or property risk, particularly in the event of separation, litigation or transfer of residence.   Combining governance, detention and mobility   Protecting an estate means adapting the

Death knows no borders. When heirs are domiciled in two countries, when assets are divided between France and Switzerland, or when civil regimes differ, succession can become a complex operation, subject to interpretation and even litigation. Preparing for a cross-border transfer requires a rigorous approach, integrating civil law rules, local tax particularities and the effects of bilateral agreements. It’s not just a question of passing on the property, but also of doing so clearly, without friction, and with respect for the wishes of the person making the transfer.   Anticipating conflicts between civil rules   When it comes to inheritance, France applies the principle of hereditary reserve, which imposes a minimum share on heirs in the direct line. Switzerland, on the other hand, allows greater freedom of disposal. This discrepancy can create tension when the deceased resided in one country but held assets in the other, or when his heirs are established on both sides of the border. Since European Regulation no. 650/2012 came into force, anyone can designate the law applicable to their succession in their will, based on their place of residence or nationality. This choice of law is often overlooked, even though it is a structuring lever in an international succession. In addition, certain asset structures frequently used in France, such as non-trading property companies and life insurance policies, may not produce the same civil and inheritance effects when an heir is domiciled in Switzerland. It is therefore essential to analyze the interaction of national rules and

Asset relocation, whether to France or Switzerland, is a delicate operation that requires a clear understanding of the tax consequences, legal impacts and asset strategies to be put in place. Whether you’re a French expatriate wishing to return or a Swiss resident transferring assets to France, a rigorous analysis of the consequences is necessary to ensure a smooth transition, free of unforeseen events. Anticipating the tax implications of residency, capital gains taxation and property management is essential to avoid unexpected tax adjustments. The tax and inheritance implications of returning to France A return to France after a period of expatriation, whether voluntary or taxed, has significant tax implications, especially in terms of unrealized capital gains, income taxation and inheritance tax. First of all, if you return to France permanently, you may need to declare any capital gains accumulated during the expatriation period. This exit tax (or tax on unrealized capital gains) may apply if assets have been transferred abroad prior to relocation, particularly real estate or shares in companies. Although France offers tax deferral arrangements in certain cases, a prior strategy is essential to avoid immediate taxation on these capital gains. Secondly, the return to France may lead to a reassessment of inheritance regimes: French inheritance reserve rules and inheritance taxes then apply, often more restrictive than in Switzerland. It is therefore important to take into account the tax implications of the transfer and management of assets, so as to plan ahead for any gifts or distributions between heirs, particularly

Families with significant wealth, often spread across different countries, face complex management, governance, tax and inheritance challenges. Between family governance, ownership structures and estate planning, every decision taken today influences not only asset management, but also the integrity of wealth for future generations. Whether in a Franco-Swiss or international context, the establishment of a family office, the organization of family governance and the management of intergenerational transfers must be part of a long-term vision, structured and capable of adapting to changing family and fiscal needs.   Family office: a pillar of wealth management   A family office enables a family to centralize and coordinate the management of its wealth across different jurisdictions. Whether for real estate, financial investments, private securities management or even philanthropy, setting up a family office is a lever for organization and optimization. In France and Switzerland, families are often confronted with different tax regimes, making cross-border asset management a complex task. A family office can centralize the management of these assets, while guaranteeing tax compliance, particularly in terms of tax declarations, cross-border VAT and inheritance tax. It also offers the possibility of establishing wealth diversification strategies that take into account the tax specificities of each country and the reality of international markets.   Family governance: anticipating to secure the transfer of ownership   Family governance is one of the most effective tools for ensuring consistent management of family assets over the long term. It defines clear rules for asset management, voting rights, roles within the family