Investment Structures for French Ski Property in 2026: Direct, LMNP, SCI, SARL Compared

Before you worry about which French ski resort to buy in, one decision quietly sets the frame for the next twenty years of your ownership: the legal structure through which you hold the property. Direct ownership in your own name, LMNP as a furnished-rental tax status, an SCI as a family holding company, or an SARL for fully commercial activity — each has distinct implications for income tax, social contributions, inheritance (succession), capital gains, and whether French lenders will mortgage you at all. Many first-time buyers default to the simplest route and only discover the trade-offs years later.

This guide walks through the four main structures used by Domosno clients to acquire French ski property, explains where each is appropriate, and highlights the 2026 rule changes that have modestly tilted the maths in favour of some routes over others. We’ll draw on the current Finance Bill provisions, the 2026 CSG update affecting LMNP landlords, the non-resident mortgage LTV caps, and real examples from Domosno buyers navigating this decision across resorts including Les Arcs property, Morzine property and Courchevel property.

Read this alongside our the buying process guide and French mortgage calculator tools. The structural decision is almost never reversible cleanly (changing structure after purchase usually triggers transfer costs), so it is worth getting right before reservation. For the large majority of Domosno clients, the answer is some version of direct ownership combined with LMNP tax status — but the decision genuinely is case-by-case, and the logic is worth understanding.

Direct personal ownership — simply buying the property in your own name, or jointly with your spouse or partner — is the default structure and the right choice for the large majority of buyers. It is the simplest to set up (no company formation, no annual filings, no French administrative overhead beyond the ordinary property tax return), and it is the structure that French mortgage lenders most readily finance. For a buyer intending to hold one property, rent occasionally, and use it themselves regularly, direct ownership is almost always the correct answer.

The main strengths of direct ownership are simplicity, mortgage access, and the relatively favourable French capital gains regime for individuals. Non-residents face a French capital gains tax headline rate of 19% plus 17.2% social contributions (or the 7.5% solidarity levy for those covered by an EU social security system), with taper relief reducing the income-tax element to zero after 22 years of ownership and the social contribution element to zero after 30 years. For a long-term hold, this is a friendly regime.

The main weakness is inheritance exposure. French forced-heirship rules apply to real estate held directly by individuals, meaning children have a reserved share (reserve héréditaire) regardless of the owner’s will, and inheritance tax scales apply to the French-situs property. For buyers with complex family situations — second marriages, stepchildren, a desire to leave the property to a non-reserved heir — direct ownership can become surprisingly restrictive. This is where the SCI becomes interesting.

The second weakness is that direct ownership offers limited scope for commercial-scale rental income if you want to scale beyond one or two properties. If you build a portfolio of three or four rental apartments, the LMNP thresholds become relevant and at some point a more structured approach — either LMP status or a company form — may be operationally more efficient.

LMNP — Loueur en Meublé Non Professionnel — is a tax status, not a separate company structure. It sits on top of direct personal ownership: you own the property in your own name, and you elect to treat the furnished rental income under the LMNP regime for French tax purposes. This is the route used by the overwhelming majority of Domosno new-build clients because it unlocks both the 20% VAT reclaim and favourable depreciation-based deductions against rental income.

Under LMNP, rental income is taxed in the BIC (Bénéfices Industriels et Commerciaux) category rather than the ordinary real-estate rental category. The practical effect is that you can deduct all operating expenses plus depreciation of the building and furniture against rental income, typically reducing the taxable rental profit to zero for the first 10–15 years of ownership. That is not a trivial saving — it is usually the difference between paying meaningful French income tax on rental income and paying nothing at all.

The 2026 Finance Bill introduced one headwind: social contributions on LMNP capital income rise from 17.2% to 18.6% from January 2026. For non-residents covered by the UK-France or Ireland-France treaties, the relevant rate is the 7.5% solidarity levy rather than the full 18.6%, so the change is modest. French residents feel it more directly. The change does not affect the underlying BIC taxation, the depreciation mechanism or the VAT reclaim eligibility — these all remain unchanged.

LMNP is the correct answer for the investor-buyer who wants to run the property as a classified tourist residence, reclaim 20% VAT on a new-build VEFA purchase, and enjoy depreciation-shielded rental income for the first decade of ownership. It is almost always combined with direct personal ownership in the title deeds, and it works seamlessly alongside a non-resident French mortgage. See our VAT reclaim guide for the interaction with the 20% rebate.

The Société Civile Immobilière (SCI) is a family-oriented civil company that exists specifically to hold real estate. Two or more people (typically family members) create an SCI, subscribe to shares, and the SCI then owns the property. The legal ownership sits with the company, but the individuals own shares in the company that are much more flexible than a direct property deed. The primary reason buyers use an SCI is inheritance flexibility — shares are easier to gift incrementally, bypass the French forced-heirship rules more cleanly, and allow the family to choose which members receive which share over time.

An SCI is not itself a tax-optimising structure. It is fiscally transparent by default (income and capital gains flow through to the shareholders at their personal tax rates), which means an SCI holding a furnished-rental property cannot elect LMNP status — LMNP is available only to individual owners. This is a critical limitation: if the property is a new-build VEFA that you want to use for the 20% VAT reclaim, and you want depreciation-based deductions, the SCI is the wrong structure. Use direct ownership plus LMNP instead.

Where the SCI shines is for families buying a chalet or apartment for multi-generational personal use with limited or no rental activity, especially when the family consists of multiple adult members who want clear ownership shares and a clean inheritance path. A classic example is a couple in their 50s who buy a chalet in Megève with the explicit intention of passing it to their three children over time; an SCI makes this planning dramatically easier than direct ownership would.

The second consideration: French mortgage lenders are generally less willing to lend to SCIs than to individuals, especially at the highest LTVs. A non-resident borrower who could get 80% LTV in their own name might get only 70% through an SCI. If financing is a core component of the purchase, the SCI typically costs you 5–10% of maximum LTV — a meaningful consideration for marginal buyers. We walk through this in detail with Domosno clients considering the SCI route.

LMP (Loueur en Meublé Professionnel) is LMNP’s larger sibling. It applies when furnished rental income exceeds €23,000 per year AND represents more than 50% of total household income — in other words, when furnished rentals become your primary business. LMP offers some advantages over LMNP (notably the ability to offset losses against overall income and to claim full exoneration from wealth tax), but the thresholds make it irrelevant for the large majority of non-resident ski-property buyers, who typically own one or two properties and have a primary income from employment or investments elsewhere.

The SARL — Société à Responsabilité Limitée — is a full commercial limited-liability company. A variant, the SARL de Famille, allows family members to run the business under a pass-through taxation model that resembles LMNP. This is the structure most serious portfolio investors use when they scale beyond 3–4 properties and want the administrative and liability protections of a proper company form. It is a significantly more complex structure than direct ownership, with annual statutory accounts, a French commercial registration, and an ongoing accountancy overhead of €1,500–€3,000 per year.

The practical question for most Domosno buyers is: ‘do I need an SARL?’ For almost all of them, the answer is no. If you are buying one or two ski apartments as part of a diversified investment portfolio alongside other assets, direct ownership plus LMNP is vastly simpler and loses nothing material in terms of tax optimisation. The SARL becomes interesting when you cross 4+ properties or when you have a specific structuring reason (co-investors from multiple countries, limited liability concerns from a specific professional context, etc.).

A final consideration: mortgage financing for SARL-held property is harder than for individually-held property. Non-resident lenders will typically require either a personal guarantee from the SARL shareholders or additional collateral, which erodes some of the limited-liability benefit of the company form. For buyers who need to finance the purchase, this tends to push the decision back toward direct ownership even when the portfolio is larger.

French inheritance law is one of the most distinctive features of the French legal system and one of the most important considerations for foreign buyers. The forced heirship (reserve héréditaire) rules give children a reserved share of the estate that cannot be overridden by the deceased’s will: one child gets 50%, two children share 66%, three or more share 75%. This applies to French-situs property regardless of the owner’s nationality or residence, and it can produce unexpected results for buyers whose home jurisdictions (including England and Wales) do not have forced heirship.

The EU Succession Regulation (Brussels IV), in force since August 2015, allows a person to elect the law of their nationality to govern their entire estate rather than the law of their habitual residence. For a British or Irish buyer who prefers the English/Welsh or Irish free-disposal regime over the French forced-heirship regime, a simple election clause in your will can meaningfully change the inheritance picture. This is cheaper, simpler and more flexible than structuring around the issue with an SCI in many cases, and it is worth discussing with a cross-border estate lawyer.

The French-UK inheritance tax treaty prevents double taxation on French-situs property between the two jurisdictions. UK domicile buyers inheriting French property will pay French inheritance tax according to French scales, with credit given against any UK inheritance tax liability. For most UK buyers, the practical effect is that the French inheritance tax regime — which has generous spousal exemptions and reasonable child allowances — is the binding constraint, not the UK regime.

For a typical British or Irish family buying a ski apartment, the inheritance question usually resolves cleanly as: own directly plus LMNP, elect home-jurisdiction succession law under Brussels IV in your will, and rely on the UK-France treaty to avoid double taxation. The SCI route is reserved for genuinely complex family situations where this simpler structure doesn’t provide the flexibility required. Our the Domosno team can introduce you to cross-border lawyers who specialise in this exact question.

French non-resident mortgage lenders have clear preferences, and those preferences materially affect which structure is economically optimal for a leveraged buyer. Direct personal ownership receives the best terms: non-residents can typically access 70–80% LTV on prime ski properties, with the most competitive profiles reaching 85% LTV. Current fixed rates for non-residents in April 2026 run 3.4–4.25%, with EU residents generally pricing a touch below non-EU borrowers.

SCI-held properties receive marginally less favourable terms. Lenders will still finance, but typically at 65–75% LTV and with slightly wider pricing (often +15–30 basis points over the direct equivalent). This reflects the additional legal complexity of enforcing against SCI shares rather than individual deeds. For buyers who need maximum leverage, the SCI trade-off is real and should be quantified before reservation.

SARL and other commercial company forms are the hardest to finance. Non-resident lenders will often require a personal guarantee from the SARL shareholders, and the LTV cap is typically 60–70%. Rates are generally 25–50 basis points wider than direct equivalents. For a portfolio investor scaling to multiple properties, this tightening is manageable — but it should be budgeted for, not discovered at offer stage.

The practical sequence for a leveraged buyer is: (1) speak to a French mortgage broker about your maximum borrowing capacity under each structure, (2) decide whether the marginal LTV loss from an SCI or SARL is worth the legal benefits, (3) finalise the structure before reservation, and (4) apply for the mortgage under the agreed structure. Our French mortgage calculator models the difference between structures for non-resident buyers.

For the vast majority of Domosno buyers, the correct structure is direct personal ownership combined with LMNP tax status. This unlocks the 20% VAT reclaim, gives access to the best French mortgage terms, keeps administrative burden low, and works cleanly alongside a home-jurisdiction succession election under Brussels IV. Unless a specific circumstance points elsewhere, this is the default.

Move toward an SCI if: the property is primarily for multi-generational family personal use with limited rental activity, you anticipate gifting shares incrementally to adult children, the family includes stepchildren or other non-traditional heirs where forced-heirship creates real problems, and financing is either not needed or the marginal LTV loss is acceptable. The SCI is not a tax-saving structure — its value is purely in family inheritance flexibility.

Move toward LMP or SARL if: rental income meaningfully exceeds €23,000 per year, you are building a portfolio of four or more rental properties, your personal circumstances create a liability-protection need that an individual title cannot satisfy, or you have co-investors from multiple jurisdictions who need a clean equity structure. The threshold for ‘time to incorporate’ is usually the portfolio crossing 4–5 rental properties.

Whatever structure you choose, commit to it before reservation. Changing structure after purchase is expensive (transfer costs, potential CGT realisation, administrative overhead) and often destroys the very tax benefits you were trying to capture. The correct move is a 30-minute conversation with a French chartered accountant or cross-border lawyer at the shortlist stage — before a single contract is signed. Our the Domosno team makes these introductions as part of the standard Domosno buying process.