International successions: taxation and coordination between States
A succession has an international dimension as soon as the deceased, an heir or an asset is outside France. France taxes under article 750 ter of the French Tax Code, subject to tax treaties, while the applicable civil law is set by the EU Succession Regulation.
The firm identifies the States entitled to tax, quantifies the duties in each, sets the credit for taxes paid abroad and coordinates the work of notaries and foreign advisers.
Which State taxes an international succession?
- Domicile of the deceased and the heirs, location of the assets: scope of French duties.
- Applicable inheritance tax treaty, or failing that the domestic tax credit.
- Applicable civil law, forced heirship and choice of law.
- Assets held abroad, trusts and foreign life insurance contracts.
- Planning through lifetime gifts, in the light of both legislations.
What are the figures and thresholds for 2026?
| Item | Value | Reference |
|---|---|---|
| Heir domiciled in France: worldwide assets taxed | Domiciled at least 6 of the previous 10 years | Art. 750 ter CGI |
| Direct-line allowance | €100,000 | Art. 779 CGI |
| Top direct-line rate | 45% | Art. 777 CGI |
In which cases has the question arisen?
Organising an international succession
A family whose wealth is spread across France and abroad: applicable law, inheritance tax in each country, double taxation and a roadmap for the heirs.
Passing French real estate on to your children when the family lives abroad
Gift of French property by a family resident abroad: shared gift (donation-partage), reserved usufruct, protection of the surviving spouse and French–Italian coordination.
Advising a US citizen settling in France
A US person settling in France on a long-term basis: France–US tax coordination (FBAR, FATCA, PFIC, CFC), review of investments, trusts, real estate and succession.
Frequently asked questions
When does France tax an international succession?
Under article 750 ter of the French Tax Code, on worldwide assets where the deceased was domiciled in France, or where the heir is domiciled there and has been for at least six of the previous ten years; otherwise, on assets located in France only.
Which civil law governs the succession?
For successions opened since 17 August 2015, Regulation (EU) No 650/2012 designates the law of the deceased’s habitual residence, unless they chose the law of their nationality.
How is double taxation avoided?
Through the inheritance tax treaty where there is one; failing that, article 784 A of the French Tax Code allows tax paid abroad to be credited against French duties on assets located outside France.
Answers current as at 9 October 2026
Publications and award
2026 OCCUR Prize, Interprofessional CollaborationLa Rencontre OCCUR Paris
Press contribution · 24 June 2026Entrepreneurs: structuring your wealth alongside your business (in French)
Expert view · 6 October 2026Pharmacy owner’s remuneration: three structures, three approaches (in French)- Interview · 28 September 2026Setting up and handing over a pharmacy: why and how to plan ahead (in French)
ArticlesThe firm’s articles on the National Bar Council’s platform
Joint publication · 26 July 2026BSPCE: no contributions, but a line in the DSN payroll returnwith Arnaud Albalat (Galadrim) and Laura Sinthe (Puncto)
AbracamoveJoint publicationInternational retirement: what the country of residence changeswith Delphine Bes (Abracamove)
Discussing your situation
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