France taxes an inheritance on everything the deceased owned worldwide if they lived in France, and only on French assets if they lived abroad. One major exception: an heir who has lived in France for at least 6 of the last 10 years can be taxed on foreign assets too. Children get a €100,000 allowance per parent, then pay 5% to 45%. A surviving spouse or PACS partner pays nothing. Tax treaties, including the US-France estate treaty, can change all of this.
Key facts
| Heir | Allowance | Rate |
|---|---|---|
| Child, parent | €100,000 | 5% to 45% (most estates stay in the 20% band) |
| Spouse, PACS partner | Fully exempt | 0% |
| Brother, sister | €15,932 | 35% / 45% |
| Nephew, niece | €7,967 | 55% |
| Unmarried partner, unrelated person | €1,594 | 60% |
Tax is computed per heir, on their share, after their allowance. Gifts made by the deceased in the 15 years before death use up the allowance. A child inheriting €1,000,000 from one parent pays about €213,000.
When France taxes an inheritance
- The deceased lived in France (tax residence): worldwide assets are taxable in France, wherever the heirs live.
- The deceased lived abroad: only French assets are taxable, including French property held through a company.
- The deceased lived abroad, but the heir has lived in France for at least 6 of the past 10 years: foreign assets received by that heir are taxable in France as well.
The third case surprises many families. A parent in New York, Dubai or Moscow leaves an apartment and a bank account in their country to a child who has lived in France for 7 years: without a treaty, France can tax that inheritance at French rates, even though nothing was ever in France.
Foreign inheritance tax paid on foreign assets is credited against the French tax, up to the French tax on those assets. If the other country has no inheritance tax, there is nothing to credit.
The US-France treaty and the UK position
The US-France treaty of 1978 covers both estates and gifts. In broad terms, real estate is taxed where it is located, and shares, bank accounts and other financial assets only by the country where the deceased was domiciled or a citizen.
- Americans recently in France. A US citizen (not also French) who has lived in France for less than 5 of the last 7 years can, under conditions set by the treaty, be treated as domiciled only in the US. France then taxes mainly French real estate, not the US portfolio.
- After that, France taxes the worldwide estate, with a credit for US estate tax on assets the treaty lets the US tax. A US citizen in France stays within the US estate tax net, so both systems need to be looked at together.
The France-UK convention of 1963 covers inheritance only, not lifetime gifts.
Many countries have no inheritance tax treaty with France at all: Russia, China, Japan, India, Israel, Switzerland, the Netherlands, Luxembourg and Singapore, among others. For those, French rules apply in full.
Forced heirship: can you choose your own law?
French law reserves part of the estate to children: half for one child, two-thirds for two, three-quarters for three or more. Under the EU Succession Regulation, the law of the country where you last lived applies, unless you chose the law of your nationality in a will.
An American or a Briton living in France can therefore choose their national law for who inherits what. This choice does not change French inheritance tax. And in some cases, children can still claim their reserved share from assets located in France.
Spouses: the marriage regime comes first
Before the estate is taxed, the couple's property is split under their marriage regime. Under a community regime, half of the common assets already belongs to the survivor and is not taxed.
Many international couples are not under the regime they think they have: depending on when and where they married, moving to France can change it. On the US side, the unlimited spouse exemption does not apply to a spouse who is not a US citizen, unless specific structures or the treaty apply.
Trusts and assurance-vie
Trusts follow specific French rules, with annual reporting duties and high rates when beneficiaries are not clearly identified. A revocable US living trust does not avoid French inheritance tax for a French resident. Even a trust drafted as irrevocable can be pulled back into the estate if the settlor kept control in practice.
Assurance-vie, the French life insurance wrapper, is taxed separately and more favourably: €152,500 tax-free per beneficiary for premiums paid before age 70. For US persons, the US income tax treatment of a French contract needs a separate review. The 2027 French budget bill, still under debate, would remove this advantage for some contracts (for example premiums paid in securities rather than cash) for deaths from 1 July 2027. The text may still change.
What to put in place before moving
- Check where you will be tax-resident, and from when, under French law and the treaty.
- Review your marriage regime.
- Write or update a will, with an express choice of law if you want your national law to apply.
- Decide how French property will be held: in your name, via a company, or split between usufruct and bare ownership.
- Consider gifts while the timing is favourable: allowances renew every 15 years.
When it gets complicated
- Tax residence is unclear: life split between two countries, or a recent move. If France treats the deceased as resident, the whole worldwide estate is taxable.
- The inheritance comes from a country with no treaty, to an heir who has lived in France for more than 6 years.
- A trust or a US living trust is part of the estate.
- A foreign account or gift was never declared. Tax authorities now receive information on foreign accounts automatically.
In these situations, the stakes often run to tens or hundreds of thousands of euros, and most solutions only exist before death.
Assets or heirs in more than one country? A short consultation is enough to see which country taxes what.
Frequently asked questions
Do children inherit tax-free in France?
Only up to €100,000 per child and per parent. Above that, 5% to 45%.
Can an American choose US law for a French estate?
Yes for who inherits what, by an express choice in a will. It does not change French inheritance tax, and children may still claim a reserved share from French assets in some cases.
Is the surviving spouse exempt from French inheritance tax?
Yes, for a married spouse or PACS partner, with no limit. The US position depends on the spouse's citizenship.
Does France tax US assets?
If the deceased was domiciled in France under the treaty, yes, with a credit for US estate tax on assets the US may tax. If the deceased was domiciled in the US, France taxes mainly French real estate.
Related reading
- Gifting to your children in France: allowances and lifetime gifts
- French life insurance (assurance-vie) and inheritance
- France's 20% tax on homes, yachts and cars held through companies
- The French impatriate regime
Two ways to move forward
You are planning ahead. You live in France or are about to move, with assets or children in several countries, and want to know what your heirs will pay and what can be organised now. Book a consultation.
You are dealing with an estate now. Someone has died with assets in France and abroad, and you need to know where to file and how not to pay twice. Describe your situation and you will receive a proposal for full assistance.
General information under French law as at 31 October 2026. It is not legal advice for your situation.