Technical article

France: The 1.5% Levy, Form 2181 and the Fines

The French tax office has a form for this, called Form 2181.

By Neil Solomon · 3 min read

Imagine a family trust run by a trustee outside France. The settlor is an American who has moved to France. One of the children lives in Paris. The family wants to know what the trustee files each year and what happens when something is missed.

The French tax office has a form for this, called Form 2181. It comes in two parts, and the administrator of the trust files both.

The returns are due if the settlor or a beneficiary lived in France on 1 January, if a trust asset is in France, or if the administrator is French. Details go onto a register held under the finance ministers. Older guidance gave a non-resident settlor until 31 August, so the date has moved over time.

The 1.5% levy. A yearly levy of 1.5% applies to trust assets that were not declared for the French real-estate wealth tax or not reported on Form 2181. It does not apply to assets already inside the settlor's declared wealth. The administrator works it out and pays it. The settlor, and beneficiaries treated as settlors, are jointly liable. One guide calls it a levy of its own kind. The official guidance says its rate matches the top rate of the old wealth tax.

The base depends on residence. For a French resident, it covers assets wherever they are. For a non-resident, it covers only assets in France, leaving out financial placements. Values are taken at 1 January. The levy comes from a law firm's 2026 guide (tier C), and the base from the tax office's own guidance from 2015 (tier A).

The French real-estate wealth tax matters here too. The settlor is treated as the owner of French real estate held in the trust. The tax applies to real estate over EUR 1.3 million (approximately US$1.4 million), according to a law firm's 2023 guide (tier C).

The fines. Here the sources differ. A French tax office document from 2015 gives a fine of EUR 20,000 (approximately US$22,000), or 12.5% of the trust value if that is higher. A 2012 law-firm article gives EUR 10,000 or 5%. A 2026 guide gives EUR 20,000 fixed, with an 80% surcharge on tax that is later reassessed. The range, then, is EUR 10,000 to EUR 20,000 as a fixed sum. Percentage versions run from 5% to 12.5% of the trust. The most recent source in the set is the 2026 guide, which is a law firm's page.

You might say: "The trustee is abroad, so this is the trustee's problem." The sources show a different reading. Because the levy is shared between the administrator, the settlor and certain beneficiaries, a missed return may reach more people than the one who failed to file. And where the administrator sits in a state that does not cooperate on tax matters, the beneficiaries may be liable together.

You could keep a short list: who the administrator is and where, whether any party lived in France on 1 January, whether any asset is in France, when the trust deed last changed, and where the copy of each return sits. The list touches the trustee, the settlor, any adult child living in France, and the helper who keeps the papers.

When a trust crosses a border, who in your family keeps the file, and what do they wish they had started earlier? Share it here. Someone setting up their own paper trail may borrow it.

Figures are estimates for planning, based on public data. Date read: October 2026.