French Inheritance Tax 2025: What UK Residents Need to Know

For UK residents who own assets in France or have relocated there, understanding “inheritance tax in France” (often referred to as “French succession tax”) is very important. The French tax system differs significantly from “UK inheritance tax (IHT)”, making estate planning more complex. Below, we explain how “French inheritance tax rates” work, how they interact with UK tax laws, and why you may need expert advice.

Understanding French Inheritance Tax

Scope of “Inheritance Tax in France”

• Residents: If you are fiscally domiciled in France at the time of your death, your worldwide assets are subject to “French inheritance tax”.
• Non-Residents: If you own assets in France (e.g. property), those assets are taxed under “France inheritance tax rules”, even if you live elsewhere.

Note: UK nationals living in France do not automatically acquire French domicile. A tax specialist can clarify your domicile status.

French Forced Heirship & Napoleonic Law

France follows “Napoleonic succession law”, which enforces a system of forced heirship:

• One child: Must inherit at least 50% of your estate.
• Two children: Must share 66%.
• Three or more children: Must share 75%.

A surviving spouse benefits from a 0% inheritance tax rate but is not automatically entitled to a large share of the estate unless specific legal steps are taken. However, UK nationals can elect to use English succession law under “EU Succession Regulation 650/2012 (“Brussels IV”)”—but this does not exempt assets from “French inheritance tax”.

1. Spouses/Civil Partners:

• Tax Rate: 0% (full exemption)

2. Direct Descendants (Children, Grandchildren, Great-Grandchildren):

• Tax-Free Allowance: €100,000 per child (this allowance has not changed since 2012).
• Progressive Rates:

3. Siblings

• €15,932 tax-free allowance, then 35–45%

4. Nephews/Nieces:

• €7,967 tax-free allowance, then 55%

5. Unrelated Beneficiaries (or “Concubins”)

• €1,594 tax-free allowance, then 60%

6. Beneficiaries with Disabilities:

• An additional €159,325 allowance can apply, potentially giving them a total allowance of €259,325+ (depending on relationship).

“UK Inheritance Tax” vs. “France Inheritance Tax”

The “UK inheritance tax system” is based on domicile, while “French inheritance tax” is based on residency and asset location.

• UK Domiciled Individuals: Taxed at 40% on worldwide assets above £325,000.
• French Residents: Taxed in France on all worldwide assets.
• Non-Residents with Assets in France: Taxed under “French inheritance tax rates” only on French-sited assets.

A “UK-France double tax treaty” prevents being taxed twice but does not eliminate liability in both countries.

The “UK-France Double Taxation Treaty” & Tax Planning

The “UK-France Double Taxation Treaty” helps mitigate double taxation. If you have assets in both countries:

• French assets are taxed in France first.
• UK assets are taxed under “UK IHT rules”.
• Tax credits ensure you do not pay full inheritance tax twice.

However, different thresholds, allowances, and tax bands may still result in some dual tax exposure.

Lifetime Gifts & Gifting Strategies

• “UK IHT”: Gifts made seven years before death can be tax-free.
• “French IHT”: Gift tax applies immediately. However, gift allowances reset every 15 years:
  • €100,000 per child every 15 years.
  • €31,865 for grandchildren.

Strategic gifting can reduce “inheritance tax in France” if planned properly.

Cameron James & Inheritance Tax Planning

At Cameron James, we specialise in:

• UK pension transfers (Defined Benefit/Final Salary, Defined Contribution).
• SIPP & QROPS for UK expats in France.
• Assurance Vie advice (for clients already set up in France).
• General investment advice for UK nationals with French assets.

What We Do Not Do:

• We do not provide French tax advice or file French tax returns.
• We do not offer one-off 20-minute consultations for complex inheritance tax matters.

If you require legal or tax-specific advice, we can introduce you to our network of French tax specialists.

Minimum Advice Fee: £3,000 for comprehensive financial planning.

Next Steps for UK Expats in France

• Determine your domicile status (UK or French?)
• Review your estate and tax exposure under both “UK inheritance tax” and “French succession tax” rules.
• Update your will and consider using “EU Succession Regulation 650/2012”.
• Seek specialist advice from bilingual tax experts for “France inheritance tax planning”.

Book a consultation with Cameron James to optimise your UK pension and investment strategy for life in France.

Secure Your Financial Future with Expert Advice

Understanding the complexities of “French inheritance tax” and “UK IHT” is very important for expats in France. At Cameron James, we provide expert UK pension transfer and financial planning services to help you navigate these tax rules effectively.

📞 Book your free consultation today to discuss your financial planning needs.