A French mortgage according to your country of residence

Two buyers present the same property, the same down payment and the same salary, and one gets their loan in six weeks while the other collects three refusals. The difference lies neither in the passport nor in the amount: it lies in the country where each pays their taxes and in the currency their income lands in. This guide reviews the situations we meet most often, with the down payment banks ask for in practice and the deciding point in each case.

It complements our reference page on mortgages for non-residents; the figures are observed orders of magnitude, not rules, and each institution has its own.

What the bank really looks at

Three data points classify a file before it is even read: tax residence, the currency of income and, for US persons, status under the FATCA regulations. Nationality only comes afterwards, and it weighs almost nothing. A French national employed in Dubai is a UAE resident; a Brazilian employed in Luxembourg is a euro-area resident.

The mechanism common to every country outside the euro area is the discount applied to income after conversion, detailed in our guide on borrowing capacity. What varies from one country to another is its size, the number of open institutions and the documents expected.

United Kingdom

The most frequent file on the market, and for that reason the most well-oiled. Since 2021 a UK resident is treated as outside the European Union: usual down payment of 25 to 30 %, discount on income in pounds, guarantee usually refused in favour of a mortgage charge. Open banks remain numerous. Documents expected are payslips, annual tax statements and three months of bank statements, accepted in English without translation.

United States

The most particular case. Since the 2014 FATCA agreement, French banks must report their American clients’ accounts to the United States tax authorities; a share of them chose to stop opening any. Accessible institutions remain, which know these files well, ask in practice for a 30 to 35 % down payment and have the American tax form signed when the account is opened. Documents expected: the last two federal returns, annual wage statements and recent payslips. The deciding point is to present the file only to open banks: elsewhere, lost time is certain.

Switzerland

The most sought-after profile after the euro area. Income in Swiss francs is read with a small discount, and a few border institutions even agree to lend in francs, which the law only allows if your income is mainly in that currency. Usual down payment of 20 to 25 %. The annual salary certificate and cantonal tax statements are generally enough.

Belgium, Luxembourg, Germany, Netherlands

The euro area removes the currency question, hence the discount. The file resembles a resident’s, with a usual down payment of 20 to 25 % and a guarantee sometimes accepted. The point to watch lies elsewhere: the tax on holding property and the applicable treaty, which our country guides set out.

Canada and Australia

Stable currencies, legible income, but two concrete constraints. The time zone lengthens every exchange by a day, which weighs on a short condition precedent, and documents often have to be certified. Usual down payment of 30 to 35 %. Negotiating sixty days of condition precedent rather than the legal minimum of one month is a necessity here, not a precaution.

UAE, Qatar, Saudi Arabia

Salaries are not taxed there, and that is what complicates the reading: the French bank cannot rely on a tax return and reconstructs a net income itself from detailed employer certificates, the employment contract and bank statements. Usual down payment of 30 to 40 %. Files go through well when the employer is a known group; they bog down when income arrives in cash or from several sources.

Brazil

The real is the currency on which banks apply the heaviest discount, and some institutions simply refuse income denominated in it. In practice, most Brazilian files that succeed rely on assets or income already in euros or dollars, or on a pledge rather than income, as our guide on the security for the loan explains. Usual down payment of 35 to 40 %, often more. Documents must be translated by a sworn translator.

Singapore and Hong Kong

High income, known employers, impeccable documents: these files are good, but the number of institutions that handle them is small, and the source of funds is examined closely. Usual down payment of 30 to 35 %. Preparing the proof of source of funds before the first meeting saves several weeks.

What does not change

Whatever the country, French rules apply identically: 35 % debt-service ratio including insurance, 25 years at most, ten-day reflection period on the offer, condition precedent of at least one month. And whatever the country, the file is built with a partner broker registered with ORIAS who knows which bank reads which passport, while French Realty frames the project and coordinates the bank account, the currency exchange, the insurance and the notary.

To know where your file stands before looking for a property, the complimentary personal study is the starting point.