Technical article
Holding the Home Through a Company: When It Changes What the Heirs Pay
In several, the tax office looks through the company to the home.
Picture a couple with a villa worth EUR 600,000 in southern France. A friend tells them to put it in a company, so the children inherit shares and not a house. The amount is an example, not a forecast. They ask whether this makes the home easier to hand on, or more costly to keep.
The sources we read point both ways. In most of the countries below, the company brings a yearly charge unless its owners are named. In several, the tax office looks through the company to the home.
The charges, country by country
| Country | What the company pays or faces | Source tier |
|---|---|---|
| France | 3% of market value every year on an entity holding French property, unless exempt | Tax office (A) |
| Spain | 3% of cadastral value every year if the entity sits in a listed tax haven | Tax agency (A) |
| UK | Annual tax on enveloped dwellings from GBP 4,600 a year on a home over GBP 500,000 | Tax office (A), law firm (B) |
| Portugal | Transfer tax of 10% instead of 6.5%, and yearly property tax of 7.5% instead of 0.3% to 0.45%, for owners in listed places | Tax portal (A) |
| Greece | 15% of the objective value every year, unless the owners are disclosed | Accounting firm (B) |
| Costa Rica | 1.5% transfer tax also applies if control of the company changes hands | Accounting firm (B) |
France
The French tax office says the 3% applies to any entity, including a trust, that holds French property. Three groups are exempt without a form: states, entities with under 50% of French assets in real estate, and listed companies. Entities seated in France, the EU or a treaty country can be exempt by filing a form by 15 May. A non-resident also pays the French wealth tax on property over EUR 1.3 million, at 0.5% to 1.5%, and shares in a property company are looked through (PwC, tier B).
On inheritance, one legal-information site (tier U) says a French property company is see-through. It does not avoid French inheritance tax.
Spain
The 3% levy has exemptions, among them a company with a continuing business in Spain beyond holding or letting property. A second rule applies to shares. A non-resident who holds shares in a company with at least 50% of its assets in Spanish real estate is in Spanish wealth tax from 2022. A return is due if the wealth is over EUR 2 million, and the state allowance is EUR 700,000 where the region sets none (PwC, tier B).
The United Kingdom
A company that owns a UK home worth over GBP 500,000 pays a yearly tax on enveloped dwellings. The 2026-27 amounts run as follows.
| Home value | Yearly amount |
|---|---|
| GBP 500,000 to 1 million | GBP 4,600 |
| GBP 1 million to 2 million | GBP 9,450 |
| GBP 2 million to 5 million | GBP 32,200 |
| GBP 5 million to 10 million | GBP 75,450 |
A return is due even when a relief applies, such as for a home let to tenants. The tax office's manual says that since 2017 shares in a company, even a foreign one, fall inside UK inheritance tax to the extent their value comes from UK residential property. A holding under 5% is left out. A company that buys a UK home may also face a 17% stamp duty rate above GBP 500,000, and a 2% surcharge applies to non-residents. A foreign company holding UK land also joins the Register of Overseas Entities and names its owners.
Portugal and Greece
Portugal's transfer tax is 10% when the buyer is a company based in a listed place or controlled from one, and individuals are left out of that rule. One news report says the tax office read the 7.5% yearly rate to reach a person from a listed place who controls a company elsewhere, while an adviser disagreed. Treat that point as unsettled.
In Greece, the company is exempt from the 15% if it names its ultimate owners. A 2023 decision extended that to entities held by foreign trusts that meet conditions.
A fair objection
You might say: the charge only hits companies from tax havens, and ours is not one. In France, Greece and the UK, the sources show a charge that applies unless the owners are named or a relief is claimed. That means a filing each year. In Spain and Portugal, the sources link the higher rates to listed places.
You could ask the adviser four things. What does the company cost to run each year? What is filed, and by when? Does the heir pay on the shares or on the home? And what happens if the company is sold, not the villa?
The heirs, who may live in other countries, face the filing either way. If you hold a home abroad through a company, what did it cost you in the first year? Share it here, and someone weighing the same step may be glad to read it.
Figures are estimates for planning, based on public data. Date read: October 2026.
Sources
- French tax office impots.gouv.fr (A)
- Agencia Tributaria (A), gov.uk HMRC pages on ATED and inheritance tax manual (A)
- Portal das Financas, Portuguese tax portal (A)
- Companies House (A)
- PwC Worldwide Tax Summaries (B)
- Wedlake Bell (B), an accounting firm's Greece guide (B), wiki.private.law (U), idealista (U)



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