A large share of prime acquisitions in Paris, on the Côte d'Azur and in Monaco are made by buyers who do not live there. Cross-border ownership is not the exception in these markets; it is the norm. But financing a prime asset as a non-resident is rarely just a question of finding a lender. The holding structure comes first, and it shapes the leverage, the lender pool and the eventual exit. Getting it right at the outset avoids expensive restructuring later.

The Holding Structure Comes First

For a non-resident buyer, the ownership vehicle is not an administrative afterthought. It affects how the asset is financed, how income and gains are treated, how the asset passes on, and which lenders are willing to engage.

Lenders are entirely comfortable with cross-border structures, provided they are clean, properly documented and transparent as to ultimate beneficial ownership. The structures that cause difficulty are not the international ones; they are the opaque ones.

France: The SCI and Its Variants

In France, prime residential property is very commonly held through an SCI (société civile immobilière), a civil property-holding company widely used by non-residents.

The SCI can be structured in different ways, including an SCI à l'IS (subject to corporate tax) depending on the objectives. The choice has consequences for financing and for the treatment of income and gains, and it should be settled with the borrower's notaire and tax counsel from the term-sheet stage rather than retrofitted afterwards.

For a lender, a well-constituted SCI with clear ownership is a familiar and financeable structure. The key is that the vehicle, its members and the flow of funds are documented and consistent.

Layered Ownership: SOPARFI and Offshore Vehicles

Many non-resident acquisitions involve more than one layer. A common pattern is a French SCI holding the asset, sitting beneath a Luxembourg holding company (a SOPARFI), or beneath a Jersey or BVI vehicle, depending on the buyer's circumstances and advisers.

These multi-layered structures are routine in prime markets. What a lender needs is a clear map: who sits where, who controls the cash, and who the ultimate beneficial owner is. When that map is supplied up front, the structure is a non-issue. When it has to be assembled during due diligence, it becomes the main cause of delay.

Monaco: Ultra-Prime and the Lender Pool

Monaco occupies a distinct position. The market is ultra-prime and trophy in nature, and the pool of lenders genuinely active in it is narrower than in London or Paris. Private banks and specialist lenders dominate, and relationships matter.

For a non-resident borrower, the practical implication is that lender selection is everything. The right counterparty for a Monaco asset is rarely the same as for a London one, and approaching the wrong pool produces either no offer or poor terms.

What Lenders Need From a Non-Resident Borrower

Across all of these markets, the recurring requirements are consistent. A lender will want the asset details and the requested facility, the borrower vehicle and the full ownership chain through to ultimate beneficial ownership, any existing debt, and a clear exit.

Source of wealth and identity documentation will be more involved for a non-resident than for a domestic borrower, and preparing this in advance is one of the simplest ways to keep a transaction moving.

Coordinating With Your Notaire and Advisers

Cross-border financing works best when the financing structure and the legal and tax structure are designed together. The notaire, the tax adviser and the arranger should be working from the same plan from the start.

Decisions made for tax or succession reasons can constrain financing options, and decisions made for financing reasons can have tax consequences. Coordinating them early avoids the situation where a structure optimised on one axis quietly closes off the others.

Our Perspective

Passy Partners arranges bridge and development finance across France, Monaco, Switzerland, Luxembourg and the United Kingdom, and cross-border ownership is the norm rather than the exception on our mandates. We bring the lender's perspective into the structuring conversation early, alongside your notaire and tax advisers, so that the holding structure supports the financing rather than constraining it.

If you are a non-resident planning a prime acquisition in France or Monaco, we would welcome the conversation before the structure is fixed.