Are you a Brit who’s moved abroad? Got a cottage in Dordogne? Maybe just a modest share account that never left a French bank? You’ll want to know what happens and what to do when life moves on and the will comes out of the drawer before a notaire asks for papers.
Before we go any further, it’s worth noting that France does not copy the UK model. It taxes what each person receives rather than a single bill on the entire estate, and it cares about where assets sit and where people actually live. Let’s get into it:
How Does Inheritance Tax Work for UK Citizens in France?
When people talk about “Inheritance tax France”, they usually just mean a charge on what a beneficiary receives – not a tax on a central pot. That is the French inheritance tax system in a nutshell.
The calculation depends on the heir’s relationship to the deceased person. A surviving spouse is usually exempt, but the rules differ for children, parents, or any other relatives.
Each person has a personal tax-free allowance and then checks the inheritance tax rates that apply to whatever remains. And if nothing remains after allowances, there is no inheritance tax owed! If something does remain, you’ve got to pay inheritance tax on that slice, and you do it according to a timetable that the French authorities enforce.
Does French Inheritance Tax Depend on Residency or Location?
You might live in London and keep a house in Bordeaux. Or, you might be a long-term French resident who still owns a flat in Manchester – it’s those facts that determine which country has the primary right to tax.
France will then ask you:
- Are you, or was the deceased person, a tax resident of France at the relevant time?
- Are the assets located in France?
If the answer to either is yes, French inheritance tax applies in some form. Say no to both, and your exposure gets a bit smaller (though it rarely disappears completely).
If you own property in France or live there for tax purposes, France can tax everything you inherit worldwide (though certain reliefs may apply). And if you live in the UK but inherit a house in France, you’ll still pay French tax on that property simply because it’s in France.
The tax office won’t just take your word for it – they’ll look at things like your:
- Utility bills
- Health cover
- Your kids’ school records
- Where you actually spend your days
So don’t assume that a quick flight and a change of address will switch your status overnight!
Fortunately, this is where treaties between these countries help. The UK and France have a double taxation treaty for inheritance. It’s a tax treaty with its own logic, so it’s not just a clone of the income tax network. It sets out who taxes first for particular items and how the other side should give credit.
Which Assets are Subject to Inheritance Tax in France?
French inheritance law looks at everything from relationships and allowances to what sits on the table. So things like cash and homes count as taxable assets. Some life insurance policies have their own thresholds and timing rules, so you might want to check the details before you bank on a specific outcome.
The French inheritance tax applies per recipient, with the bill calculated after allowances tied to the family link. That often means a practical plan revolves around who takes which asset rather than who acts as executor or signs which form.
How Do Other French Taxes Interact with Inheritance?
Don’t mix up inheritance with other French taxes that can arrive later. For example, you might inherit a house this year and incur capital gains tax if you sell after a rise in value next year. You might incur income tax on rent if you let the place while you decide what to do. But neither of those replaces the French succession tax, and none of them cancels out the others.
Also, if your property wealth crosses a threshold, a separate wealth tax liability can crop up on French real estate values. But that charge is about property, not shares or cash, and it works slightly differently.
Do Gifts Made Before Death Count Toward the Tax Bill?
Furthermore, when you give away assets before you die, France can count those gifts alongside what you leave at death. They check back over a set period to see if earlier gifts push you into a higher tax band or eat into your allowance.
That means the date and proof of any gift are really important here. Make sure you keep clear records – signed documents, dates, amounts – so your generosity doesn’t cost your heirs more, just because a file went missing or a scan was unreadable!
How Do French Succession Laws Affect Inheritance for UK Citizens?
So you have two paths with inheritance: the tax rules on one side, and the legal rules about who gets what on the other. In France, the law protects certain heirs (which tends to be children), so you can’t just entirely cut them out by writing a will that follows another country’s rules.
Now, you do have the option to pick English law for your estate under European succession regulations, but if a French court steps in, it will still check that your plan feels fair and follows form.
Needless to say, this can end up getting a bit tricky for families based all over the place, where you want to look after a spouse but also honour children’s guaranteed shares. So oftentimes, people use tools like life-interest arrangements or a mix of assets so everyone gets something meaningful.
What Role Does the Notaire Play in the Process?
When you own property or other assets in France, a notaire handles everything. They:
- Confirm who the heirs are based on your chosen rules
- Work out each heir’s tax bill
- File all the French paperwork (forms that might look odd if you’re used to UK documents)
And if your will names an executor back home, that person can help gather documents and liaise with the notaire. Just bear in mind the French process moves in its own order, so having clear translations and keeping originals where they’ll be found makes the whole thing a lot smoother.
How Upscore Can Help
If you want a simple way to keep documents and contacts in one place while you’re moving between different countries, check out Upscore’s Finance Passport! It’s a completely free tool, and it’s ideal for helping you organise figures and presenting a clean snapshot whenever a bank or notaire asks for proof.
