Proposed Law No. 276 in Monaco: What Changes for Foreign Corporate Owners
Publié par Paolo Petrini le 22/05/2026
Temps de lecture
20
min.
Taxation and Legislation
Proposed Law No. 276 marks a turning point for owners holding real estate in Monaco through a foreign company. Its objective is clear: to put an end to opaque structures and encourage more transparent property ownership in the Principality.
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In practical terms, a foreign entity owning property in Monaco will have to choose between three paths: demonstrating a sufficient level of transparency, transferring its structure to Monaco when conditions permit, or facing an annual tax of 1% calculated on the property's market value.
This reform directly impacts owners, investors, family offices, and buyers using or planning to use a foreign company to hold real estate assets in Monaco.
Proposed Law No. 276 was adopted in a public session on April 2, 2026, and received by the Prince's Government on April 3, 2026, according to Legimonaco.
Why Monaco is Strengthening Real Estate Transparency
In Monaco, real estate is not an ordinary market. It concentrates rare assets, high values, and an international clientele whose wealth structures can be complex. This uniqueness requires the Principality to maintain high standards of clarity, legal security, and international reputation.
Proposed Law No. 276 is part of this modernization movement. It comes at a time when financial and real estate jurisdictions are increasingly expected to identify the physical persons who truly control assets. For Monaco, the challenge is twofold: preserving the attractiveness of its real estate market while strengthening the credibility of its legal framework. This direction aligns with the objective stated by the National Council: to encourage foreign entities holding real estate in Monaco to transfer their domicile to the Principality, while retaining their legal personality.
The text thus reflects an evolution in philosophy. Real estate ownership via a foreign company is no longer seen merely as a private wealth management tool; it is becoming an ownership model that must be understandable, documented, and verifiable. In an international environment where compliance is increasingly important, clarity becomes a condition for sustainability.
This reform must also be read as a desire for alignment. When a real estate asset is located in Monaco, the Principality now encourages a legal organization that is more consistent with the property's location. The goal is not to exclude foreign investors, but to ensure that the structures used are compatible with contemporary standards of transparency.
For owners, the message is therefore broader than a simple reporting obligation. A structure that was once perceived as efficient may need to be re-examined in light of new criteria: its clarity, its wealth management justification, its compliance, and its ability to withstand future due diligence.
Are You Affected by Proposed Law No. 276?
You are potentially affected by Proposed Law No. 276 if a real estate property located in Monaco is held by a legal entity domiciled abroad. This can include a company, a foundation, a fiduciary, or any other foreign structure used to organize the ownership of a Monegasque real estate asset.
The central criterion is not just the identity of the final owner, but how the property is held. What needs to be analyzed is the legal structure owning the property, the nature of the real estate rights held, and the level of transparency regarding the physical persons who truly control or benefit from this structure.
In practice, the analysis begins with a simple question: is the property held directly, or through a foreign entity? If a foreign entity is involved in the ownership, the reform deserves careful attention.
To help you assess your level of exposure, you can use the self-assessment tool below.
Self-Assessment
Evaluate your level of exposure
Answer these few questions to identify whether your property's ownership structure requires special attention. This test does not replace legal or tax advice, but it can help you determine if a discussion with our team would be useful.
Criteria analyzed: ownership by a foreign entity, real estate rights in Monaco, ultimate beneficial owners, possibility of transferring to Monaco, and the current wealth management purpose of the structure.
Question 1 of 5
Is the property held by a foreign company?
This is the primary criterion for exposure to the reform. If the property is held directly by a physical person, the analysis will differ.
Important Note
Petrini Exclusive Real Estate Monaco is a real estate agency. This module is provided for informational purposes to help owners identify points of vigilance related to holding real estate in Monaco. It does not constitute legal, tax, notarial, or wealth management advice. Any decision concerning an ownership structure, a company transfer, a declaration of beneficial owners, or a tax reorganization must be validated by a qualified lawyer, notary, tax specialist, accountant, or wealth advisor.
Which Foreign Companies are Targeted?
Proposed Law No. 276 concerns legal entities domiciled abroad when they hold real estate or real estate rights in Monaco. Therefore, it does not solely address so-called "offshore" companies, but more broadly any foreign structures used to organize the ownership of a Monegasque real estate asset.
The determining factor is not just the form of the structure. What matters is its foreign domicile, the nature of the rights held in Monaco, and the level of transparency regarding the physical persons who truly control or benefit from it.
In practice, several types of entities fall within the scope of the reform: foreign civil companies, commercial companies, foundations, fiduciaries, or certain investment funds. According to the text available on Legimonaco, the concept of a "legal entity" notably covers companies, corporate bodies, foundations, fiduciaries, and investment funds, excluding trusts.
For an owner, the challenge is not to determine if their structure fits the classic image of an offshore company. Instead, four questions must be answered: where is the entity domiciled, what exactly does it hold in Monaco, who are the ultimate beneficial owners, and does the structure meet the transparency requirements set out by the reform?
This broad interpretation is essential. A foreign structure created for wealth, family, or succession reasons may now need to be documented, declared, or reorganized if it holds a real estate asset in Monaco. Conversely, trusts must be analyzed separately: they are excluded from this definition in Proposed Law No. 276, but this does not mean they are exempt from any obligations in the Principality.
Are Trusts Affected by Law 276?
Trusts must be analyzed separately. Proposed Law No. 276 excludes trusts from the definition of legal entities directly targeted by the text, but this exclusion does not mean that a structure involving a trust automatically escapes all obligations in Monaco.
The distinction is important. A foreign company, foundation, or fiduciary may fall under the scope of the reform when it holds real estate or a real estate right in Monaco. A trust, on the other hand, operates under a different legal logic, notably because it does not function like a traditional company endowed with comparable legal personality.
For owners using Anglo-Saxon, North American, or Middle Eastern structures, this nuance is critical. A Monegasque real estate property held within an architecture involving a trust must be reviewed with a Monegasque legal professional to identify the applicable regime, any potential transparency obligations, and the wealth management consequences of the structure.
The correct interpretation is therefore as follows: trusts should not be automatically equated with the foreign entities directly targeted by Proposed Law No. 276, nor should they be dismissed without analysis. Their treatment depends on the exact ownership architecture, the individuals involved, and the specific rules applicable in Monaco.
Which Properties are Affected and How Would the 1% Tax Be Calculated?
Proposed Law No. 276 does not only target the freehold ownership of an apartment, villa, or premises located in Monaco. It applies more broadly to real estate properties and certain real estate rights held by a foreign legal entity. In other words, the analysis focuses not only on the property itself, but on the exact nature of the right held by the structure.
The scope of the reform may include freehold ownership, usufruct, bare ownership, usage rights, as well as certain long-term rights such as those arising from a construction lease or an emphyteutic lease. Conversely, mortgages must be distinguished: they generally constitute a security interest for the benefit of a creditor, and not a right of use or ownership of the property.
The central mechanism is the 1% annual tax. It aims at foreign legal entities owning real estate or real estate rights in Monaco when they do not present a sufficient level of transparency. Its goal is dissuasive: it is not just about creating a tax burden, but encouraging owners to choose between transparency, transferring the structure to Monaco, or maintaining a potentially costly organization.
The most important point concerns the tax base. The tax would be calculated on the property's market value, and not on the company's net value. Debt does not reduce the tax base. A bank loan, a shareholder loan, or internal financing does not automatically protect against the 1% annual tax.
Let's take a simple example. If a foreign company holds a property valued at 20 million euros in Monaco, the 1% annual tax would represent 200,000 euros per year. Even if this property is financed by 15 million euros of debt, the calculation base remains the market value of the property, i.e., 20 million euros, and not the apparent net economic value of 5 million euros.
On high-value Monegasque real estate assets, inaction can therefore become significant. A property valued at 10 million euros would potentially represent 100,000 euros per year; a 50 million euro property, 500,000 euros per year; a 100 million euro property, 1 million euros per year. The reform thus transforms wealth transparency into a concrete financial issue.
The correct interpretation is therefore as follows: it is not only the foreign structure that must be examined, but also the real estate right held, the market value of the property, the level of debt, and the company's ability to demonstrate its transparency. For an owner, this analysis must be completed before the constraint becomes a recurring cost.
How to Avoid the 1% Tax?
To avoid the 1% annual tax, a foreign entity owning real estate in Monaco will have to embrace a logic of transparency or consider transferring its structure to the Principality. Maintaining a foreign company remains possible, but it will need to be clearly documented and justified.
The first path involves declaring the ultimate beneficial owners. In other words, the foreign company retains its existence, but it discloses the identity of the physical persons who truly own, control, or benefit from it. This option can be relevant when the structure retains a genuine wealth management, family, or international purpose.
The second path is to transfer the company to Monaco when legal conditions allow. This transfer may be particularly suitable when the Monegasque real estate asset is the company's main asset. The objective is to align the legal structure with the property's location, while benefiting, under certain conditions, from the temporary regime provided by the reform.
The third option, in reality, is inaction. It is also the riskiest. A foreign company that does not demonstrate sufficient transparency and fails to reorganize could be exposed to the 1% annual tax on the property's market value.
For an owner, the choice should not be reduced to a simple tax question. It is necessary to analyze the actual utility of the foreign company, the transparency already in place, the possibility of transfer under the law of the country of origin, the wealth management consequences, and the long-term objectives: conservation, transmission, renting, management, or sale of the property.
The right decision therefore depends on the owner's exact situation. A foreign structure may remain relevant if it is transparent and useful. It may also need to be transferred, simplified, or reorganized if its main interest was anonymity or if it is no longer coherent with holding a real estate asset in Monaco.
The Three-Year Window: Why Act Quickly?
Proposed Law No. 276 does not only create a constraint for foreign companies owning real estate in Monaco. It also opens a transitional period that may allow some owners to review their ownership structure under more favorable conditions.
Several analyses by Monegasque law firms, including CMS Monaco and 99 Avocats, present this three-year window as an incentive mechanism for the relocation or restructuring of foreign entities owning real estate in Monaco. This period may allow, under certain conditions, to benefit from temporary exemptions on certain duties normally payable during the transfer of domicile or the contribution of a real estate asset to a Monegasque entity.
For an affected owner, this period should not be understood as a simple administrative deadline. It must be used as a period for analysis, decision-making, and execution. Company transfers, compliance checks, analyzing the law of the country of origin, and potential tax consequences cannot be handled in a rush.
The challenge is therefore twofold. On one hand, inaction can expose a foreign structure to the 1% annual tax if its level of transparency is insufficient. On the other hand, waiting too long can result in losing the opportunity for a restructuring carried out within a temporarily more favorable framework.
The right approach is to use this period to map out the structure, verify the ultimate beneficial owners, estimate the market value of the property, analyze the possibility of a transfer to Monaco, and decide whether the foreign company should be retained, transferred, or reorganized.
In practice, the three-year window is not a comfortable delay: it is a working timetable. For affected owners, the risk is not just paying later, but having to decide too quickly, with a poorly documented structure and professionals mobilized in an emergency.
What Decision Should You Make if Your Property is Held Through a Foreign Company?
When a real estate property in Monaco is held by a foreign company, the right decision depends on several elements: the actual role of the structure, its country of origin, the identity of its ultimate beneficial owners, the value of the property, and the owner's objective. There is no universal answer, as a company that is still useful for a family or international organization is not treated like an old structure whose primary interest was confidentiality.
Three paths generally need to be studied. If the foreign company retains genuine wealth management utility, transparency may be the first option: this involves clearly declaring the ultimate beneficial owners and documenting the structure over time. If the Monegasque property constitutes the company's main asset, transferring the structure to Monaco may become more coherent, provided that the law of the country of origin permits it. Finally, if the company is opaque, old, or hard to justify, a deeper reorganization may be necessary.
Inaction is rarely a comfortable strategy. It can expose the owner to an annual tax of 1% on the market value of the property when the level of transparency is insufficient. It can also complicate a future sale, slow down due diligence, make a family transmission more difficult, or raise questions during a bank refinancing.
For an owner, the first step is therefore to map out the situation: which entity holds the property, where is it domiciled, who truly controls it, what real estate right is held, what is the market value of the property, is there any debt, and what is the medium-term wealth management objective — to keep, rent, pass on, sell, or entrust the property for management.
This analysis is not solely about taxation. It also touches on the daily management of the property, its valuation, its future liquidity, and the owner's ability to present a clear structure to the right stakeholders. In a market as demanding as Monaco, wealth management clarity is becoming an element of security.
Petrini Exclusive Real Estate Monaco is not a law firm, a notary, or a tax advisor. Our role is to assist owners in the management, oversight, and valuation of their properties in Monaco, while helping them identify real estate vigilance points and connecting them with competent professionals when the situation requires it.
Entrusting your property for management is not just delegating an administrative or rental task. It means relying on a local team that tracks the market, monitors important changes, coordinates the right stakeholders, and helps the owner preserve the value of their asset over the long term.
Anticipate Rather Than Endure the Reform
Proposed Law No. 276 marks a new stage in the evolution of the Monegasque real estate market. It does not challenge the ownership of a property via a foreign company, but it imposes a new requirement: this structure must now be understandable, justifiable, and documented.
For the affected owners, the challenge is not just fiscal. The 1% annual tax on the market value of the property, the non-deductibility of debt, the declaration of ultimate beneficial owners, and the possibility of transfer to Monaco transform the ownership structure into a true wealth management subject.
The right approach is therefore to anticipate. It is necessary to verify the entity that holds the property, understand the real estate rights involved, evaluate the market value, identify the beneficial owners, and study, with the right professionals, whether it is better to keep, transfer, or reorganize the existing structure.
For future buyers, this reform also changes reflexes. Buying a property in Monaco via a foreign company should no longer be an automatic decision. The chosen structure must be consistent with the wealth management objective, the expected transparency, and the future management of the property.
Petrini Exclusive Real Estate Monaco assists owners in the management, oversight, and valuation of their real estate properties in the Principality. We are not lawyers, notaries, or tax specialists, but we help our clients identify real estate vigilance points, track market developments, and connect with competent professionals when their situation demands it.
Do you own or plan to acquire real estate in Monaco through a foreign company? Entrusting your property to Petrini means benefiting from a local, attentive, and informed partner, capable of supporting you over the long term and coordinating the right experts around your project.
FAQ
Law 276 Monaco
Frequently Asked Questions
- What is Law 276 in Monaco?
Proposed Law 276 aims to strengthen real estate transparency in the Principality. It requires foreign entities owning property in Monaco to declare their beneficial owners or face a dissuasive new tax. - Who must pay the 1% real estate tax?
This tax targets foreign legal entities, such as civil or commercial companies, that hold real estate in Monaco and choose not to disclose the identity of their ultimate beneficial owners. - Do company debts reduce the 1% tax?
No, the 1% tax is calculated exclusively on the market value of the real estate. Bank loans or company debts are not deducted from this calculation base, which can represent a significant cost. - How can you avoid this annual tax on Monegasque properties?
You must demonstrate full transparency or transfer the company's registered office. Paolo Petrini, expert in Monegasque real estate, assists owners in monitoring their assets to identify these challenges and directs them to the right legal advisors. - Is it mandatory to declare the company's beneficial owners?
The declaration is not strictly mandatory, but it is the primary way for a foreign company to avoid paying the 1% annual tax. Inaction automatically leads to the application of this new fiscal constraint. - Are trusts also targeted by this new tax?
Trusts are explicitly excluded from the definition of legal entities targeted by this specific text. However, each structure involving a trust must be individually analyzed to verify its actual obligations in the Principality.
This article is provided for informational and educational purposes only. It does not constitute legal, tax, or wealth management advice. Proposed Law No. 276 must be analyzed based on its adoption status, its entry into force, any potential implementing texts, and each owner's specific situation. Any decision must be validated by a competent lawyer, notary, accountant, or tax advisor in Monaco.
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