{"id":2119001,"date":"2026-09-11T00:14:40","date_gmt":"2026-09-10T22:14:40","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/"},"modified":"2026-09-11T00:14:40","modified_gmt":"2026-09-10T22:14:40","slug":"british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/","title":{"rendered":"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax"},"content":{"rendered":"

You have completed on the house in Surrey, the flat in Edinburgh or the buy-to-let in Manchester that paid for your move, and two tax offices now want a share of the same gain. HM Revenue and Customs tells you that Capital Gains Tax on UK residential property must be reported and paid within 60 days of completion. The French tax office, the service des imp\u00f4ts des particuliers<\/em>, expects the same disposal on your next French income tax return, the d\u00e9claration d’ensemble des revenus<\/em>, at a flat 19 per cent plus social charges, the pr\u00e9l\u00e8vements sociaux<\/em>. Many British sellers in France pay twice by mistake: once in a hurry in the United Kingdom, and again in France because they never claimed the treaty tax credit, the cr\u00e9dit d’imp\u00f4t<\/em>. Others declare nothing in France, convinced that a house standing in England is none of the French fisc’s business. Both reactions are expensive.<\/p>\n

Since Brexit nothing in this mechanism has become simpler. The United Kingdom still taxes disposals of UK land, including by people who have left. France still taxes its tax residents on their worldwide income. Only the France\u2013United Kingdom double tax treaty of 19 June 2008, as quoted by the Conseil d’\u00c9tat in decision n\u00b0 435907 of 12 February 2020<\/a>, decides how the two bills fit together. The trap that hurts most is the mismatch of reliefs. UK principal private residence relief can wipe out the HMRC bill, while the French r\u00e9sidence principale<\/em> exemption, which looks at whether the house was your actual main home on the day of sale, often fails once you already live in France. A nil UK tax then means a nil treaty credit, and the French 19 per cent stands. This article explains who taxes what, how the credit is computed, which documents the French office will ask for, and how to challenge a reassessment before the claim deadline.<\/p>\n

I. Who taxes the sale of your UK house once you live in France<\/h2>\n

A. Does France tax a British resident on a house still sitting in England or Scotland<\/h3>\n

The starting point is not the postcode of the house. It is your French tax domicile. Article 4 A of the code g\u00e9n\u00e9ral des imp\u00f4ts<\/a> (the French tax code) provides that “Les personnes qui ont en France leur domicile fiscal sont passibles de l’imp\u00f4t sur le revenu en raison de l’ensemble de leurs revenus.” In other words, a person whose tax home is in France is liable to French income tax on all of his or her income, not merely on French-source income. Article 4 B<\/a> then treats as French-domiciled, among others, “Les personnes qui ont en France leur foyer ou le lieu de leur s\u00e9jour principal”: those whose household, or whose principal place of stay, is in France. Once that test is met, a gain on a house in Kent is, as a matter of French domestic law, as much a French tax event as a gain on a house in the Dordogne. The counterpart is the person who is not French-domiciled: that person is taxed in France only on French-source income, and a UK house is then outside the French net. The first fight, if there is a fight, is therefore whether you were French-domiciled in the year of completion, not whether the bricks sit in Britain. Couples who split their time between the two countries should also read our note on how to prove tax residence after Brexit<\/a>.<\/p>\n

If you are French-domiciled, the gain is not taxed as ordinary salary or as rental income. It is taxed as a private real-estate capital gain, a plus-value immobili\u00e8re<\/em>. Article 150 U, I<\/a> of the same code provides that “les plus-values r\u00e9alis\u00e9es par les personnes physiques ou les soci\u00e9t\u00e9s ou groupements qui rel\u00e8vent des articles 8 \u00e0 8 ter , lors de la cession \u00e0 titre on\u00e9reux de biens immobiliers b\u00e2tis ou non b\u00e2tis ou de droits relatifs \u00e0 ces biens, sont passibles de l’imp\u00f4t sur le revenu dans les conditions pr\u00e9vues aux articles 150 V \u00e0 150 VH”. The same article, at II, 1\u00b0, excludes buildings “Qui constituent la r\u00e9sidence principale du c\u00e9dant au jour de la cession”. The article does not confine itself to buildings standing on French soil. The Conseil d’\u00c9tat, France’s highest administrative court, has applied those same provisions to a building situated abroad. In decision n\u00b0 439987 of 9 December 2021<\/a>, it recalled article 150 U, I in these terms: “les plus-values r\u00e9alis\u00e9es par les personnes physiques (…) lors de la cession \u00e0 titre on\u00e9reux de biens immobiliers (…) sont passibles de l’imp\u00f4t sur le revenu dans les conditions pr\u00e9vues aux articles 150 V \u00e0 150 VH (…)”. The case concerned a building in the United States, resold in 2015. The court did not say that foreign situs took the gain outside article 150 U. It said the opposite: the French computation applies, including the conversion of the dollar prices into euros.<\/p>\n

The Lyon administrative court of appeal has said the same of a London house. In decision n\u00b0 21LY03673 of 27 April 2023<\/a>, the court recorded that “l’administration a tax\u00e9 \u00e0 l’imp\u00f4t sur le revenu la plus-value immobili\u00e8re r\u00e9alis\u00e9e lors de la cession par l’int\u00e9ress\u00e9, le 10 f\u00e9vrier 2014, d’un immeuble \u00e0 Londres (Royaume-Uni) au prix de 618 000 livres sterling, soit 741 600 euros apr\u00e8s conversion.” The taxpayer “ne conteste pas que la plus-value en litige pouvait \u00eatre impos\u00e9e en France”. He argued instead that the London house was his main home on the day of sale. The court rejected that claim on the evidence: the house had been let in 2010, 2011 and 2012; his 2013 and 2014 French returns gave an address in Is\u00e8re; notarial deeds in 2011, 2012 and 2013 recorded that he lived at Mont-de-Lans. The court held that “les \u00e9l\u00e9ments avanc\u00e9s par M. A… ne sauraient suffire \u00e0 \u00e9tablir que l’immeuble londonien constituait sa r\u00e9sidence principale au jour de la cession” and that he therefore could not claim the exemption in article 150 U, II, 1\u00b0. That is the case that should sit on the desk of every British seller in France: France does tax the London (or Manchester, or Edinburgh) disposal, and the main-home exemption is a question of proof on the day of completion, not a question of passport or of where the house happens to be.<\/p>\n

The French exemption itself is narrowly drawn. Article 150 U, II, 1\u00b0, quoted above, excludes the buildings which constitute the seller’s principal residence on the day of the sale. Service-Public, updated on 15 April 2026, describes that home as the dwelling you occupy for the greater part of the year, and adds that the dwelling must be your principal residence at the moment of the sale. A house you left for France, even if you still keep a bedroom and still collect post, will rarely meet that test. There is a second, conditional exemption in article 150 U, II, 1\u00b0 bis, for the first sale of a dwelling other than the principal residence where the seller has not owned his or her principal residence, directly or through an interposed person, during the four years before the sale, and remploys the sale price, within twenty-four months, in a home that is then used as the principal residence. That route can help a British arrival who sells the UK house and buys or builds a genuine French main home, and who did not already own a main home. It does not help the seller who already lives in a French house he or she owns, and it is lost if the twenty-four-month remployment condition is missed.<\/p>\n

The amount of the French gain is not a matter of impression. Article 150 V<\/a> provides that “La plus ou moins-value brute r\u00e9alis\u00e9e lors de la cession de biens ou droits mentionn\u00e9s aux articles 150 U \u00e0 150 UC est \u00e9gale \u00e0 la diff\u00e9rence entre le prix de cession et le prix d’acquisition par le c\u00e9dant.” Where those prices were paid in sterling, they must be converted into euros at the rates of the acquisition date and of the sale date respectively. In decision n\u00b0 439987 of 9 December 2021<\/a> the Conseil d’\u00c9tat held that the acquisition and sale prices in article 150 V must be determined in euros, converting at the exchange rates applicable on the acquisition date and on the sale date respectively, so that any exchange gain or loss forms part of the gross gain taxed under article 150 U. A pound that has strengthened against the euro between purchase and sale therefore swells the French gain even if the sterling prices have barely moved. A pound that has weakened shrinks it. You cannot convert the sterling gain at a single rate on completion day and call the work finished.<\/p>\n

A divorce buy-out of the other spouse’s share is another frequent trap. Article 150 U, IV<\/a> provides that certain partitions of jointly owned property between original co-owners, spouses or PACS partners “ne sont pas consid\u00e9r\u00e9s comme translatifs de propri\u00e9t\u00e9 dans la mesure des soultes ou plus-values”: they are not treated as transferring ownership to the extent of any balancing payment, the soulte<\/em>, or of any gain. In decision n\u00b0 21LY03673 of 27 April 2023<\/a> the Lyon court applied that rule to the London house. The seller had paid his former wife \u00a3100,000 in 2003 when the former matrimonial home was attributed to him. He wanted that sum in the acquisition cost. The court refused. Because of the declaratory effect of the partition, he was “r\u00e9put\u00e9 d\u00e9tenir le bien immobilier depuis l’origine de l’indivision”, deemed to have held the property from the origin of the joint ownership, and the administration was right to take the 1995 purchase price of \u00a3165,000 and the 2014 sale price of \u00a3618,000 “sans prendre en compte le versement d’une soulte”. A British seller who topped up a former spouse on a UK transfer or consent order should not assume that the extra sterling will reduce the French gain.<\/p>\n

Once the net gain is computed, French income tax is not charged at the household sliding scale. Article 200 B<\/a> provides that “Les plus-values r\u00e9alis\u00e9es dans les conditions pr\u00e9vues aux articles 150 U \u00e0 150 UC sont impos\u00e9es au taux forfaitaire de 19 %.” Service-Public, verified on 15 April 2026, states the same 19 per cent rate and adds social charges at 17.2 per cent. Those social charges rest, for a person fiscally domiciled in France, on article L. 136-6 of the code de la s\u00e9curit\u00e9 sociale<\/a>, which assujettit “Des plus-values, gains en capital et profits soumis \u00e0 l’imp\u00f4t sur le revenu”. A further tax, the taxe sur les plus-values immobili\u00e8res \u00e9lev\u00e9es<\/em>, applies under article 1609 nonies G<\/a> where the taxable gain exceeds \u20ac50,000, at rates from 2 per cent to 6 per cent; the Lyon court recorded that this tax was assessed on the London disposal alongside income tax and social contributions. Service-Public also describes a holding-period allowance, the abattement pour dur\u00e9e de d\u00e9tention<\/em>, which reaches full exemption from income tax after twenty-two years and from social charges after thirty years, with no allowance at all for the first five years. That table is an administrative presentation of the computation you will have to support with completion statements, improvement invoices and exchange-rate evidence. It is not a reason to leave the gain off the French return.<\/p>\n

Two warnings close this first sub-part. First, do not confuse your position with that of a non-resident selling a French house, which we have examined in a separate note on capital gains and social charges when a British owner sells a house in France<\/a>. That is a different levy, the 19 per cent withholding of article 244 bis A, collected through a French notary. You are the opposite person: a French resident selling a UK house, with no French notary on the file and no automatic French withholding at completion. Second, article 170<\/a> still requires every person chargeable to income tax to file a detailed return of income. The UK completion does not file itself in France. The French office learned of the London sale in the Lyon case through a contr\u00f4le sur pi\u00e8ces<\/em> and through information obtained from the British authorities. Silence is not a planning technique.<\/p>\n

B. What HMRC still wants within 60 days, and when selling your former home is tax-free in the UK<\/h3>\n

The United Kingdom looks at the land, not at your French utility bills. GOV.UK’s guidance on reporting Capital Gains Tax if you sold a property in the UK is blunt: you must report and pay any Capital Gains Tax due on UK residential property within 60 days of completing the sale of the property. Interest and a penalty may follow a late report. You report your own gain or loss if the property was jointly owned. You work out the gain first, then use a Capital Gains Tax on UK property account to report and pay, and if you are already in Self Assessment you must also include the disposal on the Self Assessment return. The information HMRC wants is practical: address and postcode, the date you acquired the property, the date of exchange, the completion date, values at acquisition and at disposal, buying, selling and improvement costs, and the reliefs you claim. Non-UK residents use the same online account; GOV.UK’s non-resident guidance repeats the 60-day clock and the same list of facts.<\/p>\n

The rates from 6 April 2026, as stated on GOV.UK’s Capital Gains Tax rates page, are 24 per cent for a higher or additional-rate taxpayer and, for a basic-rate taxpayer, 18 per cent on the slice that still falls within the basic-rate band and 24 per cent above it. For the 2026 to 2027 tax year the annual tax-free allowance is \u00a33,000. Trustees and personal representatives pay 24 per cent from 6 April 2026. Those UK figures matter in France, because they are the UK tax paid that the treaty credit will later measure. A seller who still has unused basic-rate band in the UK, or who can use the \u00a33,000 allowance, reduces the UK bill and, by the same stroke, reduces the French credit. A seller who pays 24 per cent in the UK will usually have more credit to set against the French 19 per cent, though never more than the French tax on that gain.<\/p>\n

The relief that changes everything is the UK rule that you do not usually pay tax when you sell your home. GOV.UK says exactly that on the rates page, and points to the dedicated guidance on tax when you sell your home. Principal private residence relief, in UK practice, looks at whether the dwelling was your only or main residence, including for final-period rules that HMRC applies even after you have moved out. That is a UK statutory relief, with UK conditions, UK evidence and a UK claim on the 60-day return. It is not the French r\u00e9sidence principale<\/em> test. The two labels sound like translations of each other. They are not. A house can be fully relieved in the United Kingdom as your former main residence and fully taxable in France because, on the day of completion, you were already living in France and the London or Surrey house had been let, empty, or used as a holiday base. That is the fact pattern the Lyon court tried. The taxpayer said the London house was his main home, that he had filed as a non-resident with the French non-resident service until 2013, and that personal post still went to London until February 2014. The court preferred the letting history, the French returns and the French notarial deeds.<\/p>\n

If you are still a UK tax resident in the year of sale, GOV.UK says you do not need to report the gain online where your total gains are below the tax-free allowance. If you have become a UK non-resident, the non-resident UK property regime still taxes UK land. Brexit did not repeal that. The practical sequence is therefore: decide, with evidence, whether HMRC still treats you as UK-resident; compute the UK gain in sterling, with allowable costs and any principal private residence relief that actually fits the occupation history; file the 60-day return if a UK report is due; keep the HMRC calculation, the payment reference and the completion statement. Those papers are not only a UK compliance file. They are the French credit file. Without proof of the UK tax actually paid, the French office will not give the credit. The same credit logic, on a different treaty article, is the one we have already set out for UK rental income declared by a British resident in France<\/a>.<\/p>\n

Joint owners must not copy one figure across two names. Each reports his or her own gain. Spouses and civil partners have UK gift rules that do not rewrite the French computation. A transfer between spouses before the sale may move the UK gain; it does not, without more, move the French domicile of the seller who still lives in France, and it does not turn a UK house into a French r\u00e9sidence principale<\/em>. If the property is held through a UK company, the treaty’s article 14, paragraph 2, on shares deriving their value from immovable property, may bring the gain back to the State where the land sits. That is a different file, and it is not the ordinary sale of a house in your own name. The ordinary file is already heavy enough: 60 days for HMRC, a French return the following spring, sterling-to-euro conversions at two dates, and a credit that exists only if UK tax was actually paid.<\/p>\n

II. How the treaty credit works, and how to challenge a French bill<\/h2>\n

A. Why a UK tax-free sale can still leave a full French bill<\/h3>\n

The treaty does not choose one country and silence the other. Article 14, headed Gains en capital in the French text of the 19 June 2008 treaty, as applied through the credit rules quoted below by the Conseil d’\u00c9tat, allocates taxing rights over gains from immovable property to the State where that property is situated. Gains from the alienation of a house, flat or plot of land in the United Kingdom are therefore taxable in the United Kingdom. Article 6 defines immovable property by the law of the State where the property is situated, and includes in any event the accessories of the property and rights to which the private law of land ownership applies. A house, a flat, or a plot of land in the United Kingdom is therefore taxable in the United Kingdom. That allocation means that the United Kingdom may tax. It does not mean that France must exempt. France, as the State of residence, still takes the gain into account and then eliminates double taxation by a credit, not by wiping the line off the return.<\/p>\n

The credit is in article 24, paragraph 3. The Conseil d’\u00c9tat quoted it in decision n\u00b0 435907 of 12 February 2020<\/a>. After recalling that the treaty’s French taxes include income tax, the contribution sociale g\u00e9n\u00e9ralis\u00e9e<\/em> and the contribution pour le remboursement de la dette sociale<\/em>, the court quoted article 24, 3, a): “nonobstant toute autre disposition de la pr\u00e9sente Convention, les revenus qui sont imposables ou ne sont imposables qu’au Royaume-Uni conform\u00e9ment aux dispositions de la pr\u00e9sente Convention sont pris en compte pour le calcul de l’imp\u00f4t fran\u00e7ais lorsqu’ils ne sont pas exempt\u00e9s de l’imp\u00f4t sur les soci\u00e9t\u00e9s en application de la l\u00e9gislation interne fran\u00e7aise. Dans ce cas, l’imp\u00f4t du Royaume-Uni n’est pas d\u00e9ductible de ces revenus, mais le r\u00e9sident de France a droit, sous r\u00e9serve des conditions et limites pr\u00e9vues aux alin\u00e9as (i) et (ii) et au paragraphe 4, \u00e0 un cr\u00e9dit d’imp\u00f4t imputable sur l’imp\u00f4t fran\u00e7ais.” UK tax is not deducted from the income. The French resident is entitled to a tax credit against French tax.<\/p>\n

The amount of that credit is not always the French tax itself. For some classes of income, paragraph 3, a), (i) gives a credit equal to the French tax corresponding to the income, provided the resident is subject to UK tax on that income. That mechanism, often described as a credit equal to the French tax, can wipe the French charge where UK tax has bitten. Property gains do not follow that route. They follow paragraph 3, a), (ii). In decision n\u00b0 435907 of 12 February 2020<\/a> the Conseil d’\u00c9tat quotes that limb as covering, among other items, “les revenus vis\u00e9s \u00e0 l’article 11, aux paragraphes 1, 2 et 6 de l’article 14”. For those items the credit is “au montant de l’imp\u00f4t pay\u00e9 au Royaume-Uni conform\u00e9ment aux dispositions de ces articles ; toutefois, ce cr\u00e9dit d’imp\u00f4t ne peut exc\u00e9der le montant de l’imp\u00f4t fran\u00e7ais correspondant \u00e0 ces revenus”. The credit is the UK tax actually paid, capped at the French tax corresponding to the gain. Article 14, paragraph 1, the paragraph on immovable property, sits inside that list. A British resident in France who sells a UK house therefore gets a credit of UK Capital Gains Tax paid, not a credit equal to the whole French 19 per cent merely because the United Kingdom had the right to tax.<\/p>\n

The arithmetic is unforgiving. Suppose the French tax on the gain, after any holding-period allowance, is 19 per cent, and the UK tax after principal private residence relief is nil. The credit is the UK tax paid, which is nil, capped at the French tax. France keeps the 19 per cent, and the social charges computed on the French gain. Suppose instead that HMRC charged 24 per cent on a fully taxable buy-to-let and France charges 19 per cent on a similar base. The credit is capped at the French 19 per cent. France is paid by the credit; the extra five points stay with HMRC and are not refunded by Paris. Suppose the bases differ, because France converts at two dates and includes the exchange-rate gain, or because France refuses the soulte, or because the holding-period allowances do not match UK costs. Then the “imp\u00f4t fran\u00e7ais correspondant” and the “imp\u00f4t pay\u00e9 au Royaume-Uni” are computed on different numbers, and a residual French charge appears even where the UK rate looks higher. The Paris administrative court of appeal, in decision n\u00b0 23PA02576 of 11 April 2025<\/a>, applied the same article 24 text to a claim for credit on UK employment income and quoted the condition that the credit is given “\u00e0 condition que le r\u00e9sident de France soit soumis \u00e0 l’imp\u00f4t du Royaume-Uni \u00e0 raison de ces revenus”. Subject to UK tax is a condition, not a slogan. A gain that the United Kingdom has fully relieved is a poor candidate for a full French credit.<\/p>\n

That is why a “tax-free” UK sale of a former home is, for a French resident, often the most expensive outcome. The 60-day return shows a nil liability because principal private residence relief applies. There is then no UK tax to credit. France, looking at the same completion, asks whether the house was the r\u00e9sidence principale<\/em> on the day of sale. If you already live in France, the answer is usually no, as it was for the London house in Lyon. The French 19 per cent and the social charges are then due in full, plus article 1609 nonies G if the taxable gain exceeds \u20ac50,000. The treaty has worked as designed: the United Kingdom taxed or relieved according to its own law, France taxed according to its own law, and the credit could not exceed the UK tax paid. The seller who assumed that “the UK dealt with it” discovers the bill on the following year’s French assessment, the avis d’imposition<\/em>.<\/p>\n

The credit also has to be claimed in the right place, on the right gain, against the right French tax. Article 24, 3, b), as quoted by the Conseil d’\u00c9tat in decision n\u00b0 435907 of 12 February 2020<\/a>, defines the “montant de l’imp\u00f4t fran\u00e7ais correspondant \u00e0 ces revenus”. Where the French tax is a proportional rate, it is the product of the net income and the rate actually applied; where it is a progressive scale, it is the product of the net income and the ratio of the tax actually due on the global net income to that global net income. Article 200 B is a flat 19 per cent, so the corresponding French income tax is in principle 19 per cent of the net French gain. Social charges are a separate question. The treaty’s article 2, as quoted in the same Conseil d’\u00c9tat decision, includes CSG and CRDS among “imp\u00f4t fran\u00e7ais”. Whether a given assessment has allowed the credit against those charges, or only against the 19 per cent, is a reading of the notice you actually received, not a matter to be guessed from a blog. If the credit has been omitted, or applied to the wrong line, or computed on the sterling gain instead of the euro gain, that is a ground of claim, not a reason to ignore the assessment.<\/p>\n

Exchange of information makes concealment a short-lived strategy. In the Lyon case the administration had obtained, through international administrative assistance, the last UK return to 5 April 2011 and valuation-office information showing the 1995 purchase at \u00a3165,000 and the 2014 sale at \u00a3618,000. Article L. 76 B of the livre des proc\u00e9dures fiscales<\/a> (the tax-procedure book) requires the administration to tell the taxpayer the content and origin of third-party information on which it has based the assessment, and to give a copy on request before collection. The court found that the documents had been communicated after the taxpayer’s request of 14 February 2018, and that no other third-party documents had been used. The lesson is double: HMRC data can found a French assessment of a London sale, and you are entitled to see what was used. Ask for the file. Do not assume that a UK “no tax to pay” letter has been sent to Paris and understood.<\/p>\n

B. How to contest the computation, a refused r\u00e9sidence principale claim and a missing credit<\/h3>\n

A French challenge begins with a claim, a r\u00e9clamation<\/em>, not with a letter to HMRC. Article L. 190 of the livre des proc\u00e9dures fiscales<\/a> places in the contentious jurisdiction the claims that seek the correction of errors in the base or the calculation of the tax, or the benefit of a right arising from a legislative or regulatory provision. A missing treaty credit is such a right. A refused r\u00e9sidence principale<\/em> exemption is such a right. A gain inflated by a wrong exchange rate, or by the refusal of a documented acquisition cost, is an error of calculation. Article R* 196-1<\/a> of the same book sets the time limit: to be admissible, claims relating to taxes other than local direct taxes must be presented at the latest on 31 December of the second year following, as the case may be, the year of collection of the roll or of notification of a collection notice, the year of payment where there was no roll or notice, or the year of the event that founds the claim. A late claim fails whatever its merits. Diary the 31 December of year N+2 from the assessment, and file earlier.<\/p>\n

The claim has to carry the computation, not a narrative of hardship. For a r\u00e9sidence principale<\/em> argument, the Lyon judgment is a checklist of what does not suffice: a statement that you only became French-resident after the sale; filings with the non-resident service in earlier years; post still arriving in the United Kingdom. What moved the court was letting, a French address on the returns, and notarial deeds that already described a French residence. If you genuinely still occupied the UK house as your main home on completion day, you need occupation evidence of that day: council-tax status, utility use, GP or hospital letters, the French lease or purchase date of the new home, boarding-pass patterns, and the absence of a letting. If the house was let, the exemption in article 150 U, II, 1\u00b0 is the wrong fight. Look instead at the holding-period allowance, at article 150 U, II, 1\u00b0 bis if you are buying a first French main home with the proceeds and you owned no main home in the previous four years, and at the credit for any UK tax actually paid.<\/p>\n

For the computation itself, rebuild it in euros as the Conseil d’\u00c9tat requires. Convert the acquisition price at the rate of the acquisition date, the sale price at the rate of the completion date, and keep the Bank of England or European Central Bank references. Add only those costs that French law allows as part of the acquisition price or as enhancement, with invoices. Do not add a divorce soulte if article 150 U, IV applies to the partition; the Lyon court was clear that the 2003 payment to the former spouse did not enter the 2014 gain. If the administration used a rounded rate, as it did in Lyon with \u00a31 to \u20ac1.24 at 10 January 1995, check the published rate for that day before you litigate a few cents. If the administration used a single rate for both prices, that is an error of law in the terms of decision n\u00b0 439987, and the claim should say so, with the two correct conversions attached.<\/p>\n

For the credit, attach the HMRC 60-day return, the payment record, and a reconciliation between the sterling gain and the euro gain. State that article 14, paragraph 1, of the 19 June 2008 treaty allows the United Kingdom to tax the immovable property, and that article 24, paragraph 3, a), (ii), as quoted by the Conseil d’\u00c9tat in n\u00b0 435907, gives a credit equal to the UK tax paid, capped at the corresponding French tax. If HMRC charged nothing because of principal private residence relief, do not invent a credit. Argue the French exemption if the facts support it, or the holding-period allowance, or a computational error. If HMRC charged 24 per cent and France has given no credit at all, the claim is that the credit was omitted. If France has given a credit computed on the wrong base, the claim is that the amount of UK tax paid or the corresponding French tax has been misstated. Quote the treaty lines. Do not quote a neighbour’s outcome.<\/p>\n

Penalties are a separate head. Article 1728<\/a> applies a 10 per cent surcharge where a return is not filed in time, rising to 40 per cent if the return is still missing thirty days after a formal notice, the mise en demeure<\/em>. Article 1729<\/a> applies 40 per cent “en cas de manquement d\u00e9lib\u00e9r\u00e9”, in the event of a deliberate failure, and 80 per cent in specified cases of abuse of law or fraudulent conduct. In the Lyon case the administration had applied the 40 per cent deliberate-failure surcharge to the London gain; the Grenoble tribunal discharged that surcharge and the court of appeal did not restore it. A seller who omitted the UK house because he thought the UK had dealt with it is not in the same position as a seller who hid the completion. The claim should ask for discharge of the surcharge on that ground, with the 60-day HMRC filing produced as evidence of disclosure on the UK side, while accepting that French disclosure still had to be made. Article L. 76 B remains available if the French office relied on HMRC papers you have never seen: ask for the copy before collection, then use what you receive.<\/p>\n

If the claim is rejected, or if the office lets the reply period die, the dispute moves to the administrative court of the place of taxation. The court will decide on the file you built: the completion statement, the two exchange rates, the occupation evidence, the HMRC calculation, the treaty clauses. Families who assembled that file at completion, rather than years later when the avis de mise en recouvrement<\/em> arrived, litigate from strength. The cheapest challenge is therefore the one you prepare before you complete: a written occupation timeline, a sterling-to-euro working, a decision on whether UK principal private residence relief is truly available, and a French return that reports the gain and claims the credit in the same movement. Brexit did not repeal article 4 A, article 150 U or article 24 of the 2008 treaty. It only made the two files easier to ignore until both offices write.<\/p>\n

Conclusion<\/h2>\n

A British resident in France who sells a UK house is not choosing between HMRC and the French fisc. He or she is dealing with both. France taxes the gain because article 4 A reaches worldwide income and article 150 U reaches private real-estate gains without a French-situs limit, as the Conseil d’\u00c9tat and the Lyon court have applied those texts to buildings in the United States and in London. The United Kingdom taxes, or relieves, the same land under its own Capital Gains Tax, with a 60-day report on residential property and, from 6 April 2026, rates of 18 per cent and 24 per cent around a \u00a33,000 annual allowance. The 2008 treaty then gives France a credit equal to the UK tax actually paid on an article 14, paragraph 1, gain, capped at the corresponding French tax. It does not give a free pass where the United Kingdom has charged nothing because the house was a former main residence. The French r\u00e9sidence principale<\/em> exemption looks at occupation on the day of sale. Letting, a French address on the returns, and French notarial deeds were enough, in Lyon, to destroy that claim on a London house.<\/p>\n

The working papers are therefore the case. Convert each sterling price at its own date. Do not assume a divorce soulte reduces the French gain. Keep the HMRC return, even a nil one. File the French return. If the assessment ignores the credit, inflates the euro gain, or refuses an exemption the facts support, claim under articles L. 190 and R* 196-1 before 31 December of the second following year, and ask under article L. 76 B for any British papers the office used. The sale of the UK house is often the last large UK transaction of a life now lived in France. Treated as a single file, with both statutes and the treaty on the same sheet, it is manageable. Treated as two separate surprises, it is how a tax-free UK completion becomes a French bill at 19 per cent plus social charges, with a 10 per cent or 40 per cent surcharge on top.<\/p>\n

Need a quick opinion on your case<\/h2>\n

Would you like a French lawyer to check the UK completion, the French gain and the treaty credit before you file or before you answer a reassessment? Our firm offers a telephone consultation within 48 hours with an avocat of the cabinet, to review your HMRC return, your euro computation and your occupation evidence. Call Ma\u00eetre Reda Kohen on +33 6 46 60 58 22<\/a>, or write to us through our contact page<\/a>, and we will tell you quickly whether the French bill is due, whether a credit is missing, and how to challenge it.<\/p>\n","protected":false},"excerpt":{"rendered":"

Completed on a UK house after moving to France? HMRC wants Capital Gains Tax within 60 days; France taxes the same gain at 19 per cent plus social charges. How the 2008 treaty credit works, why a UK tax-free former home can still leave a full French bill, and how to challenge a reassessment.<\/p>\n","protected":false},"author":251031309,"featured_media":16310,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_kj_source_type":"","_kj_official_id":"","_kj_official_url":"","_kj_judilibre_id":"","_kj_jur":"","_kj_lieu":"","_kj_chambre":"","_kj_rg":"","_kj_date":"","activitypub_content_warning":"","activitypub_content_visibility":"","activitypub_max_image_attachments":4,"activitypub_interaction_policy_quote":"anyone","activitypub_status":"federated","footnotes":""},"categories":[80312,80314],"tags":[],"class_list":["post-2119001","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-british-desk","category-decryptage"],"yoast_head":"\nBritish Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax - Ma\u00eetre Reda Kohen, Real Estate and Business Law Attorney in Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax\" \/>\n<meta property=\"og:description\" content=\"Completed on a UK house after moving to France? HMRC wants Capital Gains Tax within 60 days; France taxes the same gain at 19 per cent plus social charges. How the 2008 treaty credit works, why a UK tax-free former home can still leave a full French bill, and how to challenge a reassessment.\" \/>\n<meta property=\"og:url\" content=\"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/\" \/>\n<meta property=\"og:site_name\" content=\"Ma\u00eetre Reda Kohen, Real Estate and Business Law Attorney in Paris\" \/>\n<meta property=\"article:published_time\" content=\"2026-09-10T22:14:40+00:00\" \/>\n<meta name=\"author\" content=\"Kohen\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Kohen\" \/>\n\t<meta name=\"twitter:label2\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"29 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"Article\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/#article\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/\"},\"author\":{\"name\":\"Kohen\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#\\\/schema\\\/person\\\/6254a643e6239d803134a01c800381bd\"},\"headline\":\"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax\",\"datePublished\":\"2026-09-10T22:14:40+00:00\",\"mainEntityOfPage\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/\"},\"wordCount\":5833,\"publisher\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#organization\"},\"image\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/#primaryimage\"},\"thumbnailUrl\":\"https:\\\/\\\/kohenavocats.fr\\\/wp-content\\\/uploads\\\/2024\\\/11\\\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp\",\"articleSection\":[\"British Desk\",\"D\u00e9cryptage\"],\"inLanguage\":\"en-US\",\"citation\":\"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax\",\"about\":[{\"@type\":\"Thing\",\"name\":\"British Desk\"},{\"@type\":\"Thing\",\"name\":\"D\u00e9cryptage\"}],\"dateModified\":\"2026-09-10T22:14:40+00:00\",\"speakable\":{\"@type\":\"SpeakableSpecification\",\"cssSelector\":[\".article-content > p:first-of-type\"]}},{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/\",\"name\":\"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax - Ma\u00eetre Reda Kohen, Real Estate and Business Law Attorney in Paris\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#website\"},\"primaryImageOfPage\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/#primaryimage\"},\"image\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/#primaryimage\"},\"thumbnailUrl\":\"https:\\\/\\\/kohenavocats.fr\\\/wp-content\\\/uploads\\\/2024\\\/11\\\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp\",\"datePublished\":\"2026-09-10T22:14:40+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/\"]}]},{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/#primaryimage\",\"url\":\"https:\\\/\\\/kohenavocats.fr\\\/wp-content\\\/uploads\\\/2024\\\/11\\\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp\",\"contentUrl\":\"https:\\\/\\\/kohenavocats.fr\\\/wp-content\\\/uploads\\\/2024\\\/11\\\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp\",\"width\":3840,\"height\":2160},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/2026\\\/09\\\/11\\\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\\\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#website\",\"url\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/\",\"name\":\"Kohen Avocats\",\"description\":\"Ma\u00eetre Reda Kohen, attorney specialized in real estate and business law in Paris, advises and assists companies and individuals in their real estate, commercial and contractual transactions. He also handles real estate litigation and the resolution of complex commercial disputes.\",\"publisher\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#organization\"},\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Organization\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#organization\",\"name\":\"Kohen Avocats\",\"url\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#\\\/schema\\\/logo\\\/image\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.fr\\\/wp-content\\\/uploads\\\/2024\\\/05\\\/Logo-2-1.webp\",\"contentUrl\":\"https:\\\/\\\/kohenavocats.fr\\\/wp-content\\\/uploads\\\/2024\\\/05\\\/Logo-2-1.webp\",\"width\":2114,\"height\":1253,\"caption\":\"Kohen Avocats\"},\"image\":{\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#\\\/schema\\\/logo\\\/image\\\/\"}},{\"@type\":\"Person\",\"@id\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/#\\\/schema\\\/person\\\/6254a643e6239d803134a01c800381bd\",\"name\":\"Kohen\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/1c5e76ef76bbbfdd2b4da984e2bf2fa4056fd51a27d25ce2c332047f1dfd6e00?s=96&d=identicon&r=g\",\"url\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/1c5e76ef76bbbfdd2b4da984e2bf2fa4056fd51a27d25ce2c332047f1dfd6e00?s=96&d=identicon&r=g\",\"contentUrl\":\"https:\\\/\\\/secure.gravatar.com\\\/avatar\\\/1c5e76ef76bbbfdd2b4da984e2bf2fa4056fd51a27d25ce2c332047f1dfd6e00?s=96&d=identicon&r=g\",\"caption\":\"Kohen\"},\"url\":\"https:\\\/\\\/kohenavocats.fr\\\/en\\\/author\\\/kohenmlk\\\/\"}]}<\/script>\n<!-- \/ Yoast SEO Premium plugin. -->","yoast_head_json":{"title":"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax - Ma\u00eetre Reda Kohen, Real Estate and Business Law Attorney in Paris","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/","og_locale":"en_US","og_type":"article","og_title":"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax","og_description":"Completed on a UK house after moving to France? HMRC wants Capital Gains Tax within 60 days; France taxes the same gain at 19 per cent plus social charges. How the 2008 treaty credit works, why a UK tax-free former home can still leave a full French bill, and how to challenge a reassessment.","og_url":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/","og_site_name":"Ma\u00eetre Reda Kohen, Real Estate and Business Law Attorney in Paris","article_published_time":"2026-09-10T22:14:40+00:00","author":"Kohen","twitter_card":"summary_large_image","twitter_misc":{"Written by":"Kohen","Est. reading time":"29 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"Article","@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/#article","isPartOf":{"@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/"},"author":{"name":"Kohen","@id":"https:\/\/kohenavocats.fr\/en\/#\/schema\/person\/6254a643e6239d803134a01c800381bd"},"headline":"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax","datePublished":"2026-09-10T22:14:40+00:00","mainEntityOfPage":{"@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/"},"wordCount":5833,"publisher":{"@id":"https:\/\/kohenavocats.fr\/en\/#organization"},"image":{"@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/#primaryimage"},"thumbnailUrl":"https:\/\/kohenavocats.fr\/wp-content\/uploads\/2024\/11\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp","articleSection":["British Desk","D\u00e9cryptage"],"inLanguage":"en-US","citation":"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax","about":[{"@type":"Thing","name":"British Desk"},{"@type":"Thing","name":"D\u00e9cryptage"}],"dateModified":"2026-09-10T22:14:40+00:00","speakable":{"@type":"SpeakableSpecification","cssSelector":[".article-content > p:first-of-type"]}},{"@type":"WebPage","@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/","url":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/","name":"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax - Ma\u00eetre Reda Kohen, Real Estate and Business Law Attorney in Paris","isPartOf":{"@id":"https:\/\/kohenavocats.fr\/en\/#website"},"primaryImageOfPage":{"@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/#primaryimage"},"image":{"@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/#primaryimage"},"thumbnailUrl":"https:\/\/kohenavocats.fr\/wp-content\/uploads\/2024\/11\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp","datePublished":"2026-09-10T22:14:40+00:00","breadcrumb":{"@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/#breadcrumb"},"inLanguage":"en-US","potentialAction":[{"@type":"ReadAction","target":["https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/"]}]},{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/#primaryimage","url":"https:\/\/kohenavocats.fr\/wp-content\/uploads\/2024\/11\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp","contentUrl":"https:\/\/kohenavocats.fr\/wp-content\/uploads\/2024\/11\/zyanya-citlalli-gy0ATtkEcZs-unsplash.webp","width":3840,"height":2160},{"@type":"BreadcrumbList","@id":"https:\/\/kohenavocats.fr\/en\/2026\/09\/11\/british-resident-france-selling-uk-house-cgt-treaty-credit-challenge-brexit\/#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/kohenavocats.fr\/en\/"},{"@type":"ListItem","position":2,"name":"British Resident in France Selling Your UK House After Brexit: UK CGT, French Plus-Value, the Treaty Credit and How to Challenge Double Tax"}]},{"@type":"WebSite","@id":"https:\/\/kohenavocats.fr\/en\/#website","url":"https:\/\/kohenavocats.fr\/en\/","name":"Kohen Avocats","description":"Ma\u00eetre Reda Kohen, attorney specialized in real estate and business law in Paris, advises and assists companies and individuals in their real estate, commercial and contractual transactions. He also handles real estate litigation and the resolution of complex commercial disputes.","publisher":{"@id":"https:\/\/kohenavocats.fr\/en\/#organization"},"potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/kohenavocats.fr\/en\/?s={search_term_string}"},"query-input":{"@type":"PropertyValueSpecification","valueRequired":true,"valueName":"search_term_string"}}],"inLanguage":"en-US"},{"@type":"Organization","@id":"https:\/\/kohenavocats.fr\/en\/#organization","name":"Kohen Avocats","url":"https:\/\/kohenavocats.fr\/en\/","logo":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/kohenavocats.fr\/en\/#\/schema\/logo\/image\/","url":"https:\/\/kohenavocats.fr\/wp-content\/uploads\/2024\/05\/Logo-2-1.webp","contentUrl":"https:\/\/kohenavocats.fr\/wp-content\/uploads\/2024\/05\/Logo-2-1.webp","width":2114,"height":1253,"caption":"Kohen Avocats"},"image":{"@id":"https:\/\/kohenavocats.fr\/en\/#\/schema\/logo\/image\/"}},{"@type":"Person","@id":"https:\/\/kohenavocats.fr\/en\/#\/schema\/person\/6254a643e6239d803134a01c800381bd","name":"Kohen","image":{"@type":"ImageObject","inLanguage":"en-US","@id":"https:\/\/secure.gravatar.com\/avatar\/1c5e76ef76bbbfdd2b4da984e2bf2fa4056fd51a27d25ce2c332047f1dfd6e00?s=96&d=identicon&r=g","url":"https:\/\/secure.gravatar.com\/avatar\/1c5e76ef76bbbfdd2b4da984e2bf2fa4056fd51a27d25ce2c332047f1dfd6e00?s=96&d=identicon&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/1c5e76ef76bbbfdd2b4da984e2bf2fa4056fd51a27d25ce2c332047f1dfd6e00?s=96&d=identicon&r=g","caption":"Kohen"},"url":"https:\/\/kohenavocats.fr\/en\/author\/kohenmlk\/"}]}},"_links":{"self":[{"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/posts\/2119001","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/users\/251031309"}],"replies":[{"embeddable":true,"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/comments?post=2119001"}],"version-history":[{"count":0,"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/posts\/2119001\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/media\/16310"}],"wp:attachment":[{"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/media?parent=2119001"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/categories?post=2119001"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/kohenavocats.fr\/en\/wp-json\/wp\/v2\/tags?post=2119001"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}