What is Démembrement (Structured Ownership)?

In France, full property ownership (pleine propriété) is split into two separate legal rights that can be held by different parties.

Bare Ownership

Bare Ownership — The Walls

  • You own the asset / the walls
  • No personal use during the term
  • No rental income received
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Usage Rights

Usufruct — Usage Rights

  • Can use or rent the property
  • Receives all rental income
  • Does not own the structure
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Full Ownership

Full Ownership at the End

  • Bare Ownership + Usage Rights combined
  • Automatic at end of term
  • No extra tax to recombine

How It Works In Practice

A property worth €500,000 is split between two parties for a fixed term of 12–20 years.

01

Year 0 — Purchase at Discount

You (the investor) buy the nue-propriété (bare ownership) at 50–70% of the full market value — e.g. €250,000 for a €500,000 property.

02

Years 1–12 — Sit Back

The usufruit holder (social landlord, hospitality operator or institution) manages the property throughout the term.

Read more…

The usufruit holder:

  • Rents the property
  • Collects income
  • Maintains it

The nue-propriétaire (you):

  • Has no operational involvement
  • Pays no tax on rental income
  • Often no IFI (wealth tax) on the asset

This is a capital growth strategy, not an income strategy. Early resale of nue-propriété is possible but may be subject to market conditions and pricing adjustments.

03

Year 12+ — Full Ownership

The usufruit expires automatically. You become the 100% owner (pleine propriété) with no extra tax to recombine ownership. You can then sell or rent the property.

What Happens at the End?

After the agreed term (typically 12–20 years), ownership automatically consolidates — completely tax-free.

  • The usufruit / usage rights expire automatically
  • The nue-propriétaire becomes 100% owner (pleine propriété)
  • No extra tax to "recombine" ownership

You now own a €500k+ property that you originally bought at 50% of its value.

Split ownership to full ownership

Do Purchasers Need to Buy Under a Company?

Most Common

Personal Name

This is how most démembrement deals are done.

  • You're a private investor
  • You want simplicity
  • You're targeting long-term capital growth
  • Simple purchase process
  • Lower admin / accounting costs
  • Clean tax treatment (no income = no income tax)
  • No corporate complexity

For most clients, this is the default route.

Specific Cases

French Company (SCI / SARL / etc.)

You can use a company, typically:

  • SCI (Société Civile Immobilière) — most common
  • SARL de famille — most common for property above €1.5m in value
When it makes sense:

A. Family structuring / inheritance

  • Parents + children hold shares
  • Easier to transfer wealth progressively
  • Combines nicely with démembrement of shares as well

B. Portfolio building

  • If someone plans to hold multiple properties
  • Cleaner to manage under one structure

C. Cross-border / tax planning

  • Sometimes useful for non-French residents
  • Needs proper advice (this can get complex)

For classic démembrement investments (12–20 years, no income): a company often adds more friction than value.

Investment Variables

The Structured Ownership scheme can be applied to other French property tax-advantageous schemes:

  • Short-term rental management with VAT Reclaim
  • Long-term rental management
  • Senior Residences via commercial lease with VAT Reclaim
  • Student Residences via commercial lease with VAT Reclaim
  • Resort and/or Hotelier Residences via commercial lease with VAT Reclaim

At the end of the structured ownership term, the full property owner retains a VAT liability until the 20-year period is finalised.

View VAT Reclaim Explanation: Click here

*This means that in some cases in particular the Resort and/or Hotelier Residences, they need to abide the obligation to rent the property out on a short term basis until the term set by the local town hall has expired (usually 30 years) – Bonus is that after 30 years of ownership the property is capital gains tax free in France.

Financial Example

Based on a €500,000 property purchased at 50% (€250,000), with 3% estimated annual capital appreciation.

  • Year 0 → Purchase at discount
  • Years 1–12 → No income / no use
  • Year 12 → Full ownership
  • Year 12+ → Income or resale
Asset Class
Residential Property
Country
France
Areas
Alpine / French Riviera
Structured Ownership
Est. Capital gains /Pa
3%
InvestmentProperty ValueRunning CostsIncomeNet Income
Year 1250,000.00500,000.000.000.000.00
Year 20.00515,000.000.000.000.00
Year 30.00530,450.000.000.000.00
Year 40.00546,363.500.000.000.00
Year 50.00562,754.410.000.000.00
Year 60.00579,637.040.000.000.00
Year 70.00597,026.150.000.000.00
Year 80.00614,936.930.000.000.00
Year 90.00633,385.040.000.000.00
Year 100.00652,386.590.000.000.00
Year 110.00671,958.190.000.000.00
Year 120.00692,116.940.000.000.00
Year 130.00712,880.445,523.0015,886.0010,363.00
Year 140.00734,266.865,523.0015,886.0010,363.00
Year 150.00756,294.865,523.0015,886.0010,363.00
etc.0.00778,983.715,523.0015,886.0010,363.00
Structured Ownership period (Years 1–12)
Full Ownership (Year 13+)

Risks & Considerations

No income during usufruit period (12–15 years)
Illiquidity — resale during the usufruit term is much harder
Market risk — capital appreciation is not guaranteed
Dependence on the quality of the usufruit operator
No personal usage during the usufruit period
Timing mismatch between life events and term end
Tax treatment on exit depends on your country of tax residence

Who Is This For?

Suitable For

  • Long-term investors (10–20+ years)
  • High-income individuals seeking tax efficiency
  • Hands-off investors
  • Investors seeking a complement to their pension fund

Not Suitable For

  • Yield-focused investors
  • Short-term buyers
  • Buyers wanting personal usage

Frequently Asked Questions

Explore answers to the most common questions about structured ownership in France.

Ready to Explore Structured Ownership?

Speak with our expert team to find out how Démembrement could work for your investment goals.

This page is provided for information purposes only and does not constitute financial, tax, or investment advice. Investors should seek independent professional advice before making any investment decision.

Structured Ownership | 100% Ownership with 50% Investment | Greenstone