Non-residents with French assets over a value of € 1.3 Million are required to file a Form  2725, with the appropriate annexes  by 2nd September, 2013 with the Service des impôts des particuliers non residents, at Noisy le Grand.

Those trustees having French situs assets should check their position and ensure that they are only holding financial investments at 1st January, 2013. They too have to file a specific Trustee Prélèvement declaration by 2nd September, or face severe penalties: €10.000 or 5% of the trust assets.

I stress that there has been no indication given yet that any such penalties will be limited to  French assets alone, but to penalise the entire fund would be disproportionate.

That only applies to Trustees with no French resident beneficiaries or deemed settlors.

Those who have, and who have not filed or confirmed that they are outside the scope of the declaratory requirements are already in default. Their prélèvement declaration should have been earlier this year. Please contact Peter for assistance if that is the case.

See generally Resources Page:  Summary of French Wealth Tax (ISF), rates and filing dates for 2013

Those individual non-residents who have French assets over that value, and also French source income should already have filed their returns: See Resources Page /media/15859/introduction%20isf%202013.pdf

Whilst it is possible to argue that no declaration is required where the net value of French assets and liabilities is less than €1.3 million, but the gross value is higher, that is rarely accepted by the French administration as an excuse for not filing, and will inevitably lead to a query, a requirement for declarations for undeclared years, and expense.  The tendency is to require a full asset and liability declaration to ensure that only French situs liabilities are deducted. In the current budgetary situation, there will be increase compliance pressure.