HELPLINE: 
How tax treatment differs depending on property location
When selling a former main residence after moving, tax treatment differs depending on the property’s location. These two real-life cases show how UK and French rules produce very different outcomes, even when the circumstances seem similar.
Case study 1 – Sale of a UK property by a French tax resident
The Situation. James*, a British national, lived and worked in London for many years. In 2021, he moved permanently to France and became a French tax resident. His former London home had been his main residence for a decade, but he retained it for a few years after leaving the UK and sold it in 2024.
The property was purchased for £300,000 and sold for £500,000, generating a total capital gain of £200,000. James owned it for 15 years, of which 10 were as his main residence.
Applicable tax rules. UK capital gains tax (CGT) applies regardless of James’s residence. Private Residence Relief (PRR) covers only periods of actual occupation. Since April 2020, non-UK residents must file a UK Property CGT Return within 60 days of completion.
Tax outcome. PRR applies to 10/15 of the gain, leaving £66,666 taxable. At 28% CGT, UK tax is around £18,666. James must also declare the gain in France, but the France-UK Double Tax Treaty allows a credit for UK tax paid, preventing double taxation.
Key takeaway. A former UK main residence is only partially exempt and relief is strictly governed by UK law.
Case study 2 – Sale of a French main residence with a bridging loan
The Situation. Marie and Laurent*, French tax residents, sold their home in Toulouse after buying a new main residence near Bordeaux in 2024, financed with a mortgage and bridging loan. For a few months, they temporarily owned two homes until the former residence sold.
Applicable tax rules. Under French law, the sale of a principal residence is fully exempt from capital gains tax, even if no longer occupied, provided the sale occurs within a normal timeframe. BOFiP guidance confirms the exemption applies when the former home is temporarily retained for sale, promptly listed, not rented or occupied, and sold within roughly 12 months.
Key takeaway. Transitional situations such as bridging loans or short-term dual ownership do not affect the main residence exemption in France. The decisive factor is the genuine intention to sell.
Final comparison and conclusion. These cases highlight a key distinction: in France, the main residence exemption is broad, flexible and practical, covering bridging loans and delayed sales. In the UK, relief is partial, time-based and does not depend on where the taxpayer lives. For capital gains purposes, the location of the property matters far more than the owner’s residence.
*Names have been changed for privacy.