How to Hold Financial Assets in the Context of International Mobility: France, Belgium, Switzerland, Italy

France – Belgium – Switzerland – Italy

Securities accounts · Life insurance · Holding companies

This comparison sets out, by holding vehicle, the tax consequences for a Belgian, Swiss and Italian resident, and places them alongside the position of a French tax resident.

I. Overview: each State's own logic

• France – High taxation of income flows on the securities account (flat tax raised to 31.4%), with no tax on holding financial assets. The logic is to place savings in wrappers: life insurance for transfers outside the estate, a holding company for qualifying shareholdings and reinvestment. A gift wipes out the latent capital gain.

• Belgium – End of the historic exemption: capital gains taxed at 10% since 1 January 2026, with acquisition costs set at their floor value as at 31 December 2025. Three further frictions apply: the tax on securities accounts, the stock exchange transaction tax, and foreign dividends taxed on a net-of-foreign-tax basis (no tax credit). No carry-forward of losses; no step-up on gift or death. Low inheritance tax (between 0 and 3%).

• Switzerland – The securities account is the natural vehicle: private capital gains are exempt, and inheritance tax is 0% in the direct line. The cost lies elsewhere: dividends at ordinary rates and wealth tax, which vary widely by canton. Life insurance and holding companies add nothing for a listed portfolio.

• Italy – 26% flat tax on dividends and capital gains, no wealth tax, gift and inheritance tax of 4% to 8% with a €1M allowance. Weak spots: net-of-foreign-tax treatment of foreign dividends and ring-fencing of losses. Life insurance is attractive on death but eligibility must be secured.

II. Direct holding: the securities account

	FRANCE	BELGIUM	SWITZERLAND	ITALY
Dividends	Flat tax (PFU) 31.4% since 2026 (12.8% income tax + 18.6% social contributions) or option for the progressive scale (40% allowance). Foreign withholding creditable (treaty tax credit). High-income surtax (CEHR) of 3-4% and minimum tax (CDHR) where applicable.	30% withholding tax (précompte mobilier), final. Foreign dividends taxed on the net-of-foreign-tax amount, with no credit for the foreign tax.	Ordinary progressive scale: up to ≈ 43% in Geneva, ≈ 25% in a canton such as Vaud. Base reduced to 70% (30% allowance) for shareholdings ≥ 10%. 35% withholding tax, refundable.	26% flat tax (imposta sostitutiva). Issue of the net-of-foreign-tax amount: no tax credit for foreign withholding. IRPEF progressive scale (max 43%) not applicable to this income.
Capital gains	Flat tax (PFU) 31.4%. Or holding-period allowances, only under the progressive-scale option, for shares acquired before 2018.	10 % Since 1 January 2026: (normal management of private assets) – Act of 3 April 2026. Floor acquisition cost: value as at 31.12.2025 (historic gains exempt). Annual allowance €10,000; substantial shareholding ≥ 20%	Private capital gains exempt, including private equity.	26 % (redditi diversi). 12.5% on government bonds and similar.
Capital losses	Set off against gains of the same kind in the year and the following 10 years.	Deductible from gains of the same year only: no carry-forward to later years.	Not deductible (corollary of the exemption).	Carried forward to the following 4 years
Funds	Distributing: flat tax. Accumulating: taxed on redemption only.	30% "Reynders" tax on the bond component; 10% capital gains tax on the remainder.	Distinguish between distributing and accumulating funds	Fund income = redditi di capitale at 26%, not offsettable against losses.
Tax on holding assets	None on securities, except for the real estate fraction of shares (IFI limited to real estate).	0.15% tax on securities accounts where the account's average value exceeds €1M: operates as a financial wealth tax.	Wealth tax: securities included at their value as at 31 December. ≈ 0.86% in Geneva; very low rates in some cantons (canton of Vaud around 0.01%).	No wealth tax. IVAFE 0.2% on financial assets held abroad (0.2% bollo in Italy); IVIE ≈ 1% on foreign real estate.
Transaction tax	0.4% FTT on purchases of French shares with market cap > €1bn.	Stock exchange transaction tax (TOB): 0.12% / 0.35% / 1.32% depending on the instrument.	Transfer stamp duty 0.15% (Swiss securities) / 0.30% (foreign).	Italian Tobin tax doubled in 2026: 0.2% on regulated markets, 0.4% off-market (shares of Italian companies); derivatives: fixed amount.
Reporting obligations	Annual tax statement (IFU) issued by the French bank. Foreign account: forms 3916 and 2047; €1,500 fine per undeclared account	The Belgian bank withholds (as in France), including the capital gains tax (withheld from 1 June 2026) Foreign account: declared by the taxpayer	Statement of securities and wealth as at 31 December. Individual taxation of couples approved on 8 March 2026, in force by 2032.	Regime amministrato: the Italian intermediary acts as withholding agent. Foreign account: quadro RW; an Italian fiduciary can act as paying agent.

III. Life insurance

	FRANCE	BELGIUM	SWITZERLAND	ITALY
Subscription	No tax on premiums.	2% tax on premiums.	2.5% stamp duty on single-premium surrenderable insurance.	No entry tax; 0.2% annual bollo / IVAFE on unit-linked contracts.
During the contract	Tax-free accumulation; switches are tax-neutral. Social contributions remain at 17,2 % (life insurance excluded from the 2026 CSG increase). Outside the IFI except for real estate units.	Internal switches (branch 23) outside the capital gains tax. Branch 23 affected indirectly by the 0.15% securities account tax: payable by the insurer on its accounts > €1M, then passed on to policyholders.	Surrender value included in taxable wealth.	Tax deferred until surrender; internal offsetting of gains and losses.
Surrender	Only the income portion is taxed. 30% flat tax.	10% on the gain since 2026. Branch 21: 30% withholding on a notional yield if surrendered within 8 years.	Periodic premiums: benefit exempt. Single premium: yield taxable at ordinary rates, unless pension conditions are met (payout after age 60, contract ≥ 5 years, taken out before age 66).	Taxation of the policyholder or beneficiary: 26% on the yield (12.5% on the government bond portion).
Death	Outside the estate. Premiums paid before age 70 – Art. 990 I: €152,500 allowance per beneficiary, then 20% and 31.25% above €700,000. Premiums paid after age 70 – Art. 757 B: inheritance tax above €30,500, gains exempt. Spouse / civil partner exempt.	No capital gains tax on death. But inheritance tax applies to the capital transferred (regional scales).	Cantonal inheritance tax: 0% in the direct line and between spouses in most cantons.	Outside the estate: no inheritance tax on the death benefit. But since 2015 the financial yield remains taxed at 26% (12.5% government bonds); only the portion covering demographic risk is exempt from IRPEF.
Rationale	Core wrapper: transfer outside the estate.	A tool for estate planning (beneficiary clause, gift of the contract) rather than income optimisation: entry cost 2% + securities account tax.	Not used: the securities account is already more favourable (gains exempt). Life insurance is characterised as an insurance contract and treated as such.	Attractive (deferral + death outside scope) but a delicate issue on a transfer of residence

IV. Holding company

	FRANCE	BELGIUM	SWITZERLAND	ITALY
Corporate tax rate	25 % (15% up to €42,500 for SMEs).	25 %. The 20% SME rate (first €100,000) is in practice closed to holding companies: companies whose shareholdings exceed 50% of paid-up capital and reserves are excluded (other than shareholdings > 75%).	≈ 14% in Geneva (effective federal + cantonal/communal rate).	IRES 24% + IRAP ≈ 4% (regional).
Dividends received	Parent-subsidiary regime (≥ 5%, 2 years): exemption except for a 5% add-back → ≈ 1.25%.	Dividends-received deduction (RDT): 100% deduction (≥ 10% or €2.5M, 1 year, subject-to-tax condition).	Participation reduction (≥ 10% or market value ≥ CHF 1M): near-exemption.	95% exemption → ≈ 1.2%, with no shareholding threshold: the 5% or €500,000 thresholds of the 2026 Budget Law were repealed retroactively to 1 January 2026 by Decree-Law 38/2026, converted into law on 20 May 2026.
Capital gains on shares	Participating interests held ≥ 2 years: 12% add-back → ≈ 3%. Portfolio securities: full corporate tax; non-equity funds taxed annually on net asset value.	Exempt if the RDT conditions are met; otherwise 25%.	Exemption through the participation reduction if ≥ 10% held for 1 year.	PEX: 95% exemption if shares held for more than 12 months (+ booked as a fixed financial asset, operating company, not in a privileged-tax State). 5% / €500,000 thresholds repealed (Decree-Law 38/2026).
Capital losses	Long-term losses on participating interests not deductible.	Not deductible (except on liquidation, up to the paid-up capital).	In principle deductible (value adjustments), with subsequent recapture.	Not deductible where the PEX applies.
Distribution to the shareholder	Flat tax 31.4% (+ CEHR / CDHR).	Withholding tax 30%	⚠ Dividend at ordinary rates for the individual, with a 30% allowance for shareholdings ≥ 10%. Sale of the holding company's shares: private gain exempt	26 %.
Listed portfolio held in a holding company	Positions < 5%: no parent-subsidiary regime, full corporate tax then flat tax on exit.	Loss of the 10% individual rate in favour of 25% corporate tax on non-qualifying positions.	Counter-productive: an exempt gain is swapped for 14% corporate tax + dividends at ordinary rates.	Outside the PEX: 24% + 26% on exit.
Reinvestment of sale proceeds	Contribution-then-sale (Art. 150-0 B ter): tax deferral subject to reinvestment, with stricter parameters under the 2026 Finance Act (notably 70% to be reinvested)
Other	20% tax on passive holding companies (Art. 235 ter C CGI, 2026 Finance Act) on luxury assets.	Classic reinvestment holding company (RDT + capital gains exemption).	Holding company relevant for shareholdings ≥ 10% and accumulation at 14%.	—

V. Transfers and mobility

	FRANCE	BELGIUM	SWITZERLAND	ITALY
Gift	Scale up to 45% in the direct line; €100,000 allowance per child; 15-year look-back.	Registered gift of movables, flat rate: 3% in the direct line (Flanders, Brussels), 3.3% (Wallonia); 7% / 5.5% for others. Unregistered manual or bank gift: 0%, but added back to the estate if death occurs within 5 years (all three Regions since 2026). Foreign notarial deed: registration mandatory.	Cantonal: 0% in the direct line and between spouses in most cantons (Geneva exception for lump-sum taxpayers).	4% to 8%; allowance of €1M per beneficiary in the direct line / spouse; no look-back.
Inheritance	Same scale; spouse exempt.	Regional jurisdiction, based on the deceased's domicile. Direct line and spouse: Flanders 3 / 9 / 27% (27% above €250,000); Brussels and Wallonia 3 to 30% (30% above €500,000). Wallonia: 15% cap voted for 2028, retention uncertain.	0% direct line / spouse.	4% to 8%, same allowances.
Treatment of the latent gain	Step-up on gift and on death alike: the acquisition cost becomes the transferred value.	Neither gift nor inheritance gives a step-up: the acquisition cost remains the donor's (floor 31.12.2025).	Not applicable (private gain exempt).	Gift: no step-up (donor's acquisition cost). Inheritance: step-up ("true" succession).
Benefit of gifting early	Two benefits: step-up of the gain (give before selling) and €100,000 allowance every 15 years. Bare ownership: usufruct extinguished with no tax on death.	Benefit on the duties, not on the gain: 3 to 3.3% versus 27-30% on death; 5-year suspect period, so give early or register. €10,000 annual allowance multiplied by the number of donees. Trap: the 20% threshold is assessed per person.	Limited in the direct line: 0% on gift and on death, gain exempt. Real issues: other beneficiaries, lump-sum taxation in Geneva, French shares or a French-resident donee (Art. 750 ter).	Limited benefit: same rates and same €1M allowance as on death. A gift gives no step-up whereas inheritance does: for shares with large gains, waiting may be preferable. Residual benefit: locking in the current regime.
Usufruct / bare ownership	Joint sale with price split: gain shared between usufructuary and bare owner. Reinvestment in split ownership: bare owner alone liable. Quasi-usufruct: usufructuary.	Liable for the capital gains tax: the bare owner.	Not applicable	—
French shares	—	Inheritance: 1959 treaty, Art. 8 – securities are taxable only in the State of the deceased's domicile: no French tax for a deceased domiciled in Belgium. Gift: no treaty, Art. 750 ter applies – French shares taxable in France.	Taxable in France (Art. 750 ter); no inheritance tax treaty since 2015. Art. 784 A does not apply to French shares: no double taxation in the direct line (0% in Switzerland), but cumulative taxation for other heirs. Likewise if the heir is French-resident (6 years out of 10).	⚠ French shares taxable in France on gift and on death alike: 1990 treaty, Art. 8 (securities located in the State of the issuer's seat). Italy credits the French tax (Art. 11).
Transfer of residence	Exit tax (Art. 167 bis): shares > €800,000 or ≥ 50%; automatic deferral within the EU, on option with guarantees for Switzerland; relief after 2 years (5 years above €2.57M).	Exit tax under the new capital gains tax: taxed if sold within 2 years of departure (automatic deferral EU / EEA / treaty State).	No exit tax for individuals.	No exit tax for individuals; ordinary or lump-sum regime on arrival.

VI. Lessons

Key takeaways

• Giving before selling only pays off in France. In Belgium and Italy, a gift passes the latent gain on to the donee; in Italy only inheritance provides a step-up. In Switzerland, no tax at all.

• The securities account is king in Switzerland, acceptable in Belgium (10% after the allowance, but annual frictions), costly in France and Italy.

• Life insurance is first and foremost a French tool. Its portability must be tested before any transfer of residence.

• A holding company is only justified for qualifying shareholdings (≥ 5% in France, ≥ 10% in Belgium and Switzerland, PEX in Italy) and an accumulation logic. For a diversified listed portfolio, it worsens the outcome everywhere.

• Foreign dividends: residual double taxation for Belgian and Italian residents; favour accumulation or wrappers.

Frequently asked questions

Are stock market gains taxed in Switzerland?

No, for an individual managing private assets: private capital gains are exempt. In return, dividends are taxed at ordinary rates and securities are included in the wealth tax base at their value as at 31 December.

What is the tax rate on share capital gains in Belgium since 2026?

10% since 1 January 2026, within the normal management of private assets, with an annual allowance of €10,000. Only the gain arising after 31 December 2025 is taxed: the value of the shares on that date serves as the floor acquisition cost.

Does gifting shares before selling them wipe out the gain, as in France?

Only in France. In Belgium, neither gift nor inheritance gives a step-up: the recipient takes over the donor's acquisition cost. In Italy, only inheritance gives a step-up, not a gift. In Switzerland, the question does not arise since private gains are exempt.

Does my French life insurance remain advantageous if I leave France?

Not automatically. Each State applies its own rules: 2% tax on premiums and 10% on the gain at surrender in Belgium, surrender value subject to wealth tax in Switzerland, yield taxed at 26% in Italy, including on death. The contract's portability must be checked before the transfer of residence.

Should I set up a holding company to hold a listed share portfolio?

Generally not. A holding company is effective for qualifying shareholdings (at least 5% in France, 10% in Belgium and Switzerland, PEX regime in Italy) and in an accumulation logic. For a diversified listed portfolio, it adds corporate tax and then tax on distribution.

Do my shares in French companies remain taxable in France after I leave?

On gift or death, often yes. This is the case for a Swiss resident, in the absence of an inheritance tax treaty since 2015, and for an Italian resident, under the 1990 treaty. For a Belgian resident, the 1959 treaty excludes French tax on death, but it does not cover gifts.

Eve d'ONORIO di MEO

Lawyer, Certified Specialist in Tax Law

Marseille and Geneva Bars (EU/EFTA Lawyer)

ed@donorio.com