A foreign corporate investor may invest in French property directly or through a local (e.g. a société à responsabilité limitée [SARL], a société anonyme (SA) or a société par actions simplifée [SAS]) or non-resident company, or through a partnership such as a société civile immobilière (SCI).
Foreign investors frequently invest in French real estate assets through a two-tier structure in which a French company owns the real estate asset, with the shares of the French entity being held by a foreign holding company (Luxembourg or Belgian holding company). This type of structure is frequently used for the acquisition/holding of French property since the sale of the shares in such a foreign holding company (or even the shares in the French company) may fall outside the scope of French capital gains taxation.
Source : PWC