How does getting a mortgage in France as a non tax-resident compare to a mortgage in Norway in 2026?

Spending a vacation in France to enjoy its mild climate, cuisine, or history is a common dream among Norwegians, but financing a second home requires navigating a different system. In Norway, banks can lend up to 90% of a property’s value, whereas French banks generally cap loans for non-resident borrowers at 70–80%, as specified in Regulation 2026 on residential mortgage lending issued by Finanstilsynet, the Norwegian Financial Supervisory Authority. This guide explains the 35% rule, the difference between fixed and variable rates, and the actual down payment amount you should expect.

 

Key Points to Remember

• Norway allows financing of up to 90% for residents, compared with the typical 70–80% for non-residents in France, which means a larger down payment is required.
• French mortgages are almost always fixed-rate, unlike the floating-rate loans common in Norway.
• Norwegian tax residents keep paying Norwegian wealth tax (formuesskatt) on a French property, even as a non-resident of France.

 

French vs Norwegian mortgages: what are the biggest differences?

Buying property abroad often involves a whole set of new rules and regulations that can differ quite significantly from the ones at home.

Norway's lending framework, run by Finanstilsynet, and France's mortgage market, shaped by the Banque de France and the High Council for Financial Stability (HCSF), solve different problems. A Norwegian applicant walks into a French bank with a profile that looks unfamiliar to the underwriter, income in kroner, no French credit history, and a lending culture used to floating rates and high loan-to-value (LTV) that France doesn't share.

Understanding both systems side by side sets realistic expectations before contacting a bank.

 

How much can Norwegian buyers borrow to purchase property in France?

In France, a 2021 decision from the HCSF puts a ceiling on borrowing capacity: total monthly loan payments across all debts (insurance included) cannot exceed 35% of net income. For a net monthly income equivalent to NOK 56,000 (roughly €5,000), the maximum monthly repayment in France is around €1,750.

Norway works differently. Under the 2026 residential lending regulations, total debt, including the new mortgage, cannot exceed five times gross annual income (a 500% ceiling). A Norwegian buyer earning NOK 800,000 a year before tax is capped at NOK 4,000,000 in total debt. France, by contrast, calculates borrowing capacity from monthly repayment capacity rather than an income multiple.

 

How much down payment is required in France compared with Norway?

In Norway, the maximum LTV ratio was raised from 85% to 90% for both primary and secondary homes, so a buyer might only need 10% in their own capital.

In France, non-resident buyers, Norwegians included, are generally asked for 30% down, sometimes more depending on the bank and the file. On a €300,000 property, that means €90,000 in cash, on top of fees; that's a lot of Kvikk Lunsj.

The good news is that buyers based in the EU or the EEA, which includes Norway, tend to land toward the lower end of that range, since French banks treat EEA affiliation as a lower administrative and legal risk than a non-EEA country.

 

French vs Norwegian mortgage rates: fixed or variable loans in 2026?

Beyond the headline numbers (Norway's policy rate at 4.25%, with average rates being 5-6% versus average French mortgage rates around 3.10 to 3.55% depending on the term, per the Pretto barometer for July 2026), the more important difference is structural.

French mortgages are overwhelmingly fixed-term rate, so the monthly payment is set at signing and never moves for the life of the loan. This can work in the borrowers' favor, since it offers predictability.

Norwegian mortgages are more commonly tied to a floating reference rate, which means Norwegian buyers are used to payments that adjust with Norges Bank's policy decisions. A Norwegian buyer financing in France should expect full predictability instead, since the rate is fixed at a specific point in the cycle rather than one that can fall if rates drop later.

Interest rates in France are also much lower than in Norway, sometimes even decreasing by half.

 

Does buying a home in France increase your Norwegian wealth tax?

In France, notary fees (mostly taxes and registration duties, not the notary's own income) run approximately 7-8% of the price for an existing property, and 2-3% for new construction, according to Notaires de France. On a €400,000 resale property, that adds €28,000-32,000 on top of the down payment. There are also other fees: agency fees, borrower insurance, property transfer taxes…

In Norway, the equivalent charge is the dokumentavgift (documentary duty), a flat 2.5% stamp tax on the property's market value, plus a fixed registration fee of around NOK 545, overall roughly NOK 100,545 on a NOK 4,000,000 home. There is no notary system in Norway: a licensed real estate agent (eiendomsmegler) handles the transaction, and Kartverket, the land registry authority, records the change of ownership.

 

Does buying a second home in France change what I owe on Norwegian wealth tax?

For a lot of Norwegian buyers, the French house becomes the new hytte, just with better weather. But buying outside of Norway will result in new tax implications.

Norway's formuesskatt taxes the worldwide net wealth of Norwegian tax residents, French property included. For the 2026 tax year, the first NOK 1.9 million of net wealth is tax-free, and anything above that is taxed at 1%, per the Norwegian Tax Administration.

Norway also gives primary residences a break that a French secondary home won't get. Only 25% of a primary home's value (up to NOK 10 million) counts toward taxable wealth, 70% when above that threshold. When buying a secondary home, it will be counted at its full market value instead, with no discount.

On the French side, the wealth tax on real estate (IFI) only applies once French property owned by a non-resident exceeds €1.3 million, with a progressive scale starting at 0.5%. Below that threshold, no IFI is due. A buyer's overall wealth tax exposure depends mainly on the Norwegian side of the equation, as long as they remain a non-resident of France.

 

What happens if you become a French tax resident? 

Relocating does not remove Norwegian wealth tax obligations overnight. Norway only ends tax liability once "tax emigration" is formally approved, and the timeline depends on how long the person lived in Norway.

Someone who lived there for less than 10 years can end Norwegian tax liability once they have moved abroad permanently, spent no more than 61 days a year in Norway, and no longer have housing available there, according to the Norwegian Tax Administration. Formuesskatt doesn't let you pull a quiet Norwegian exit, Skatteetaten wants a proper goodbye before it lets you go: someone who lived in Norway 10 years or more stays liable for at least three additional years after the move, even if the same conditions are met.

In France, once someone becomes a tax resident, the IFI normally applies to real estate held anywhere in the world, not just in France. A transitional rule softens this, though, as a new resident who was domiciled outside France for the previous five years is taxed only on French property for up to five years after the move, as shown in impots.gouv.fr. After that period, any property still held in Norway would also count toward French IFI.

In practice, a Norwegian family relocating permanently may keep paying Norwegian wealth tax on worldwide assets for several years after the move, while France taxes only their French property during that same window. The France-Norway tax treaty prevents the same asset from being taxed twice. It is a gradual handover between two systems, not an exemption from either, and worth planning with a tax advisor on both sides before the move.

Heads up! - this article is aimed at non tax residents, if you're a French tax resident and looking to buy in France, go here: How do mortgages work in France in 2026? The complete guide

 

Does France have competitive property bidding like Norway?

No, both systems are quite different. Most Norwegian sales run through a budrunde, a formal bidding round managed by the real estate agent: once a property is shown, interested buyers submit written bids, each with a deadline set at least 30 minutes after the previous one, and a bid becomes binding the moment it is submitted.

Since 1 July 2025, so-called secret bids, offers an agent could show only to the seller, have been banned by law, so every bidder now sees the same information as everyone else, according to Norway's Ministry of Finance.

France works the other way around. A property is listed at an asking price, and a buyer submits a written offre d'achat, often below that price, which the buyer can limit to a set validity period. There is no legal deadline for the seller to reply: without one stated, the seller has a “reasonable” amount of time, and if they never respond, the buyer is free to walk away, according to the Chambre des Notaires de Paris.

For a Norwegian used to deciding within minutes during a budrunde, this slower, negotiation-based process can feel unfamiliar, but it also leaves more room to bring the price down instead of bidding it up. The main difference is that the asking price in Norway will be negotiated upwards, while in France it will be negotiated downwards.

 

How long does the French property buying process take?

A French purchase runs through a preliminary sales agreement, a financing period of around 45 to 60 days, a loan offer subject to a mandatory 10-day cooling-off period, and a final signature before a notary, a mandatory public official in every French property sale.

A Norwegian buyer does not need to travel for any of it, since the entire process, from the initial offer to the notarial signing, can be handled remotely through a power of attorney (procuration), something we cover in detail in our guide on how a mortgage works in France.

In Norway, there is no notary requirement: the eiendomsmegler manages the transaction directly between buyer and seller, and Kartverket records the change of ownership. For a Norwegian buyer, the French process can feel slower and more formal, but it exists to protect both parties at every stage.

 

How can Norwegian buyers finance a property purchase in France?

Comparing France and Norway makes one thing clear: neither system is better or worse, but they are different enough that a Norwegian income, savings structure, and tax residency need to be translated into terms a French bank recognizes.

At Opeongo Finance, we help Norwegian and other Scandinavian buyers, as non-residents and expatriates, translate their projects into terms that the banks understand, and explain how the French rules interact with what you already know from home.

Whether you are just starting to research your options or already have a property in mind, let's discuss your project, with no obligation.

Updated on July 6, 2026, by Paul Desjardins, mortgage broker specializing in international clients (ORIAS No. 25 010 121).

Paul Desjardins assists expatriate buyers, non-residents, and international investors with their real estate financing projects in France. More than 60% of his clients live abroad: he advises them in French and English, from the initial review of their application through to the signing at the notary’s office. He writes practical guides for Opeongo Finance aimed at international clients who want to understand the rules of French mortgage lending and secure financing from abroad.