Inheritance Tax for UK Expats in France (2026)

France taxes inheritance very differently from the United Kingdom. The UK levies inheritance tax on the estate as a whole, while France taxes each beneficiary on what they receive, with the rate and allowance set by their relationship to the deceased. For a UK national who owns property in France, retires there or becomes French tax resident, both systems can come into play at once.

This guide sets out the French succession tax bands for 2026, the forced heirship rules that govern who must inherit, and how the long-standing UK-France treaty relieves double taxation. Figures below are confirmed against French government and HMRC sources.

• France taxes the beneficiary, not the estate, and the rate depends on the family relationship.
• Spouses and registered PACS partners pay no French succession tax at all.
• Each child has a €100,000 allowance from each parent; rates above that run from 5% to 45%.
• Distant relatives and unrelated heirs face allowances as low as €1,594 and rates up to 60%.
• French forced heirship reserves a fixed share of the estate for children.
• A 1963 UK-France treaty gives a credit so the same asset is not taxed twice.

How French succession tax works

French succession tax (droits de succession) is charged on each heir's share, not on the total estate. After deducting the allowance (abattement) attached to that heir's relationship, the remaining amount is taxed on a progressive scale. The allowance can generally be used once every fifteen years between the same two people, so lifetime gifts and inheritances interact.

Tax residence drives the scope of the charge. Where the deceased was tax resident in France, France can tax the worldwide assets passing to each heir. Where the deceased was resident elsewhere, France taxes only assets situated in France, such as a French property, although other connecting factors can extend that reach. French real estate is always within the French net regardless of where anyone lives.

Allowances and rates by relationship (2026)

The table shows the main allowance and the rate range for each category of heir. Spouses and PACS partners are fully exempt from succession tax on death, so no rate applies to them. The direct-line scale below applies to children and, in the other direction, to parents.

The direct-line scale rises in steps: 5% on the first €8,072 above the allowance, 10%, 15% and then 20% up to €552,324, 30% to €902,838, 40% to €1,805,677, and 45% beyond that. A disabled heir who meets the conditions receives an extra allowance of €159,325 on top of the relationship allowance.

Forced heirship: the reserve hereditaire

French law reserves part of an estate for children, who are protected heirs. The reserved portion (reserve hereditaire) depends on how many children there are: one child must receive at least half the estate, two children share two thirds between them, and three or more children share three quarters. Only the remaining free portion (quotite disponible) can be left freely to others, including a spouse.

Under the EU Succession Regulation, often called Brussels IV, a UK national can elect in their will for the law of their nationality to govern succession, which can displace French forced heirship for the disposition of assets. France added a counter-rule in 2021: where the deceased or a child is an EU national or EU resident, a disinherited child can claim a compensating payment (droit de prelevement) out of French assets. The interaction is contested, so a French will or notaire input is usually needed to make a nationality-law election work in practice.

The UK-France position and double taxation

UK inheritance tax can still apply alongside the French charge. Following the 2025 reform, UK inheritance tax is based on long-term residence rather than domicile: a person who has been UK resident for at least ten of the previous twenty tax years is generally a long-term resident whose worldwide estate is within UK inheritance tax. Someone who has left the UK can remain within scope for several years under the new "tail" provisions, and UK-situated assets stay taxable regardless.

Relief from double taxation comes through the Double Taxation Relief (Estate Duty) (France) Order 1963, which still applies to UK inheritance tax. Where the deceased is treated as domiciled in one state, that state taxes the whole estate and gives a credit for tax paid in the other state on assets located there, applied asset by asset. The credit must be claimed, with proof of the foreign tax paid, generally within five years of death. From April 2027, unused UK pension funds are also due to fall within UK inheritance tax, which adds a further cross-border layer for expats holding UK pensions.

This article is for general information only and does not constitute financial, tax or regulatory advice. Kaeltripton.com is not authorised or regulated by the FCA. Pension and tax rules differ by country of residence and change over time. Verify any figure with official sources such as GOV.UK, HMRC or the FCA, and take advice from a suitably authorised adviser in your country of residence before acting.

FAQ

Do spouses pay French inheritance tax?

No. A surviving spouse or registered PACS partner is fully exempt from French succession tax on death, so no rate applies to their inheritance.

What allowance do children get in France?

Each child has an allowance of €100,000 from each parent. Amounts above that are taxed on a progressive scale running from 5% up to 45%.

What is forced heirship in France?

French law reserves part of an estate for children. One child is reserved half the estate, two children two thirds between them, and three or more children three quarters, leaving only the free portion to distribute.

Can UK inheritance tax still apply if I live in France?

Yes. UK inheritance tax now follows long-term UK residence and also covers UK-situated assets. The same estate can face both charges, with treaty relief available.

How is double taxation between the UK and France relieved?

The 1963 UK-France estate duty convention gives a credit for tax paid in the other state on assets located there, applied asset by asset. It must be claimed with proof of foreign tax paid, generally within five years of death.