Rates at a Glance
Scope: Which Dwellings Are Caught
The TLV under CGI Art. 232 applies to dwellings meeting all three of the following conditions simultaneously.
- Located in a qualifying commune: an agglomeration of >50,000 inhabitants with a marked supply/demand imbalance (list per Décret 2013-392 du 10 mai 2013); or — following Loi 2022-1726 Art. 73 — any commune with a marked supply/demand imbalance evidenced by high rents and acquisition prices or a high proportion of non-primary-residence dwellings (list by separate decree).
- Habitable and unoccupied for at least one year at 1 January of the tax year. A dwelling undergoing significant renovation works that render it uninhabitable is not within scope. Seasonal residences unoccupied on 1 January may qualify.
- Vacancy results from the owner’s volition. Involuntary vacancy — where the property cannot be let or sold despite genuine efforts at market conditions — is excluded. The owner bears the burden of proof of involuntary vacancy.
Vacancy is treated as involuntary where the property cannot be let or sold at market price and is actively offered for letting or sale without finding a tenant or buyer. The mere fact that a property is in poor condition does not automatically constitute involuntary vacancy if the owner has not made genuine efforts to let it. Conversely, a property offered at above-market asking price is typically treated as voluntarily vacant.
Who Is Subject to the Tax
The TLV is due by the following persons where they have the qualifying status at the start of the vacancy period:
- Owners (propriétaires), whether individuals or legal persons;
- Usufructuaries (usufruitiers);
- Holders of a bail à construction, a bail à réhabilitation, or an emphytéotique lease.
Where there are multiple redevables (e.g. co-owners), the tax is established in the name of the person who actually controls the decision to keep the dwelling vacant.
The Tax Base
The TLV is assessed on the valeur locative foncière brute of the dwelling and its dependencies as at 1 January of the tax year. This is the same valeur locative as used for the taxe foncière on built property: it represents the theoretical annual rent the property could generate as determined by the cadastral authorities. The State retains 9% of the TLV as management fees — higher than the 3% frais de gestion charged on the taxe foncière.
How the Tax Is Calculated
The tax amount equals valeur locative foncière brute × applicable rate (17% or 34%). The first year of taxation is the year in which the dwelling has been vacant for at least twelve consecutive months at 1 January. The 34% rate applies from the following January if the dwelling remains vacant. There is no partial-year proration: the full annual rate applies regardless of when during the year the dwelling is brought back into use (though return to use will prevent the tax from arising in the following year).
The TLV and the taxe d’habitation sur les logements vacants (THLV) are mutually exclusive. The THLV applies only in communes where the TLV is not applicable. In TLV communes, only the TLV is levied on vacant dwellings. In non-TLV communes that have voted the THLV, it is the THLV that applies instead. The two taxes are never cumulated on the same property.
Administration: Assessment, Declarations, and Claims
No Declaration Obligation for Owners
Unlike many French property taxes, the TLV imposes no declaration obligation on owners. The tax is assessed by the authorities from existing cadastral and declaratory information. In practice, the annual CGI Art. 1418 declaration of residential premises (filed by all property owners before 1 July via “Gérer mes biens immobiliers”) also serves as the information base for establishing and auditing the TLV.
Assessment and Recovery
The TLV is assessed annually in the commune where the property is situated and recovered by tax roll (par voie de rôle) in the same way as the taxe foncière on built property. The owner receives a tax notice showing the base, the applicable rate, and the amount due.
Claims and Disputes
The procedural rules follow the same regime as the taxe foncière on built property:
- Claims may be filed up to 31 December of the year following the year in which the tax roll is enforced, addressed to the tax service for the property;
- The administration’s right of recovery runs until 31 December of the year following the tax year;
- Disputes fall within the jurisdiction of the administrative courts.
The most effective way to challenge a TLV assessment is to file a réclamation contentieuse supported by evidence of active marketing: advertisements, estate agent mandates, letting platform listings, correspondence with prospective tenants or buyers, and records of viewings. The claim must be filed within the deadline. Where vacancy results from poor condition, evidence of a building permit or works contracts preparing the property for letting can support the temporary and involuntary nature of the vacancy.
Our French law practice advises on TLV scope and qualification, involuntary vacancy defence strategies, interaction with the THLV and the annual CGI Art. 1418 declaration obligation, and contentious claims against TLV assessments.
Book a ConsultationLegal Notice. This article is provided for general information and educational purposes only. It does not constitute legal or tax advice. The list of qualifying communes under the >50,000 inhabitants category is set by Décret 2013-392 du 10 mai 2013 as amended; the list of communes qualifying under the Loi 2022-1726 extension should be verified at the time of any assessment. Procedural rules follow those of the taxe foncière sur les propriétés bâties. Always consult a qualified French tax adviser before any decision based on TLV rules.
Key Legal References
Taxe sur les logements vacants: scope (habitable dwelling vacant ≥12 months in qualifying commune; vacancy results from owner’s volition); taxable persons (owner, usufructuary, bail à construction/réhabilitation/emphytéotique holder); base (valeur locative foncière brute); rates (17% year 1; 34% from year 2); no declaration obligation; recovered by tax roll; procedural rules follow taxe foncière TFPB
Extension of TLV scope to additional communes with marked supply/demand imbalance evidenced by high rents/prices or high proportion of non-primary-residence dwellings; list by separate decree
TLV rates doubled: year 1 rate increased to 17%; from year 2 onwards rate increased to 34%
List of qualifying agglomerations of more than 50,000 inhabitants with marked supply/demand imbalance for TLV purposes
Electronic payment required for local taxes (including TLV) where amount exceeds €300
