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United KingdomIsle of Man Government

France–Isle of Man TIEA covered tax switches to real-estate wealth tax

Exchange-of-information requests under the France–Isle of Man TIEA track the former wealth tax only up to 31 December 2017; for periods from 1 January 2018 they track the wealth tax on real estate.

By Taxxa AI OyPublished 10 October 2026

Tax

France has notified the Isle of Man under Article 2.2 of their Tax Information Exchange Agreement that the French covered tax known as the wealth tax was replaced by the wealth tax on real estateGOV with effect from 1 January 2018GOV.

The change has been agreed by the parties. Assistance in the form of exchange of information on request under the TIEA will be provided up to 31 December 2017 in respect of the wealth tax, and thereafter in respect of the wealth tax on real estate.

The France TIEA was signed on 26 March 2009 and took effect on 4 October 2010, and its status remains in force. It sits alongside the France shipping and aircraft agreement in the Isle of Man's published table of international agreements.

For practitioners, the consequence is period-specific. An exchange-of-information request concerning French wealth taxation for a period ending on or before 31 December 2017 falls under the former wealth tax as the covered tax.GOV A request concerning a period from 1 January 2018 onwards falls under the wealth tax on real estate.GOV Requests spanning the turn of the year straddle the two covered taxes, with each part of the period governed by the tax in force for it. The cut-over date therefore matters twice: it determines which tax a request can lawfully target, and it determines how a request covering several years must be framed.

Advisers preparing outgoing requests from the Isle of Man to France should therefore name the covered tax that matches the period in question, rather than defaulting to the tax named in older requests. Those responding to incoming French requests, or reviewing historic wealth-tax positions with a cross-border element, should check which of the two taxes the request invokes before assessing its scope. Where a matter covers both sides of the cut-over, the request should distinguish the wealth-tax period from the real-estate-wealth-tax period explicitly.

Legal basis: the France–Isle of Man Tax Information Exchange Agreement, Article 2.2, as notified between the parties.

Name the covered tax matching the request period: the former wealth tax for periods up to 31 December 2017, the wealth tax on real estate for periods from 1 January 2018.

Sources

All Agreements