Inheritance Tax in France for Non-Residents: 2026 Guide

GME Audit l Votre expert-comptable

Sep 24

5 min read

Inheritance tax in France for non residents is not a rumour: when assets pass on a death and France has taxing rights, it applies droits de succession, the French inheritance tax, wherever the beneficiaries live. What changes with residence is the scope. A death outside France brings only French assets into the net. A death in France can bring the whole estate. The 2026 Budget Act left the scales unchanged, so the figures below are those in force as of September 2026 (impots.gouv.fr).

Does a Non-Resident Pay Inheritance Tax in France?

Yes, in two situations, and the distinction drives everything else:

The deceased lived outside France. France taxes only the assets located on its territory (French-situs assets): typically real estate in France and shares in French property companies such as an SCI. Situs means the location the law attaches to an asset for tax purposes. Bank accounts and most securities held by a non-resident deceased sit outside the French net.
The deceased was French resident. The worldwide estate falls under French inheritance tax, even if every heir lives abroad.

One rule extends the second case. If any heir was French tax resident for at least 6 of the 10 years before the death, the deceased's worldwide assets are treated as French-situs for that transfer. The test looks at residence history, not just the address on the day of death.

Who Is Actually Non-Resident Here? The Two Scenarios That Decide

Scenario A: the heir lives abroad, the deceased lived in France. French inheritance tax applies to the worldwide estate, subject to the tax treaty between France and the deceased's country. A child living in London who inherits a flat in Lyon and a Swiss bank account from a French-resident parent declares both in France.

Scenario B: the deceased lived abroad, the heir lives anywhere. Only French-situs assets are taxable in France. A US resident inheriting a house in Provence from a US-resident parent owes French inheritance tax on that house. Without a closer family link or a treaty rule, the 60% rate for non-relatives can apply, with no allowance.

The 6-of-10-years trap. An heir who has left France keeps worldwide-scope exposure for years. If you were French resident for 6 of the last 10 years, the estate is taxed as if the deceased had stayed resident. Returning expats and their families should check this rule first.

Allowances and Rates: What a Non-Resident Beneficiary Pays

French inheritance tax is computed per beneficiary. Each heir deducts a personal allowance from their share, then the balance is taxed on the scale for their relationship to the deceased. The 2026 figures, unchanged by the 2026 Budget Act (service-public.gouv.fr):

Relationship to the deceased	Allowance per beneficiary	Rate above the allowance
Spouse or PACS partner (civil union)	Fully exempt	0%
Child, parent (direct line)	100,000 euros	5% to 45%, progressive
Grandchild	31,865 euros	5% to 45%, progressive
Brother or sister	15,932 euros	35% up to 24,430 euros, then 45%
Disabled beneficiary	159,325 euros	Then the family scale
Relative up to the 4th degree	No allowance	55% flat
Beyond the 4th degree, non-relatives	No allowance	60% flat

Source for allowances and the 55%/60% bands: service-public.gouv.fr, duties by relationship.

The direct-line scale applies to each taxable share:

Taxable share (after allowance)	Rate
Up to 8,072 euros	5%
8,073 to 12,109 euros	10%
12,110 to 15,932 euros	15%
15,933 to 552,324 euros	20%
552,325 to 902,838 euros	30%
902,839 to 1,805,677 euros	40%
Above 1,805,677 euros	45%

A worked example. A non-resident child inherits 150,000 euros from a French-resident parent. Allowance: 100,000 euros. Taxable: 50,000 euros. Tax: 403.60 + 403.70 + 573.45 + 6,813.60, which is 8,194.35 euros, following the service-public computation method. The same 150,000 to a non-relative: 90,000 euros, at 60% with no allowance.

The non-resident allowance cut. Under article 779 II of the French Tax Code, a beneficiary who is not resident in the EU or EEA, in a state without an administrative assistance convention with France, has allowances halved. Before counting on the full 100,000 euros, check your country's convention status.

How and When to Declare: The Non-Resident Filing Rules

The declaration goes to the Service des impôts des non-résidents (SIP), the Non-Residents Collection Office, with payment attached (impots.gouv.fr).

Deadline: 6 months from the death if it occurred in France, 12 months if it occurred abroad.
No declaration at all when gross estate assets stay below 50,000 euros for direct heirs, a surviving spouse or PACS partner (with no prior undeclared gift), or below 3,000 euros for other beneficiaries (thresholds, impots.gouv.fr).
Real estate: a French notary must handle the transfer, and files the return (form 2705) for you.
After payment: you can request an attestation de paiement, a certificate of payment, sometimes called a quitus. Keep it: buyers and the land registry will ask for it when the property is resold or transferred.

What Tax Treaties Actually Change

Without a treaty, two countries can tax the same transfer. Treaties allocate the right to tax, and most follow the same pattern: the country where the deceased was resident taxes the estate, but France keeps exclusive or shared rights over French immovable property.

UK and France: the 1963 convention leaves French real estate to France. A UK-domiciled heir pays French inheritance tax on a French house first; how the UK then treats that tax depends on the deceased's domicile.
US and France: the older-generation treaty also preserves French taxing rights over French real estate.
Brussels IV: an EU regulation lets a foreign national elect the law of their nationality for the succession itself. That election changes the civil law, who inherits what. It does not switch the tax: French inheritance tax still applies to French assets.

Treaty mechanics differ case by case. Reading the convention before filing is the cheap part; discovering it after payment is not.

If You Inherit French Property, What Follows

Becoming an owner changes your own tax position. A non-resident owner of French property owes annual taxes, may have rental income to declare if the property is let, and faces capital gains tax on a later sale. We cover those obligations in detail in the annual taxes non-resident owners pay. If this is your first holding in France, it also helps to know what a French expert-comptable actually is, because accounting and tax filings in France run through specific professionals and forms.

FAQ: Inheritance Tax in France for Non-Residents

Do non-residents pay inheritance tax in France?

Yes, when the assets are French-situs, or when the deceased was French resident, or when an heir was French resident for 6 of the last 10 years.

What is the deadline to declare from abroad?

12 months after a death abroad, 6 months after a death in France, filed with the Non-Residents Collection Office.

Is a spouse exempt from French inheritance tax?

Yes, fully, and so is a PACS partner. Siblings get a 15,932 euros allowance; children 100,000 euros.

Does a tax treaty stop France taxing the house?

Usually not. Most treaties, including the UK and US ones, preserve France's right to tax French immovable property.

Check Your Scenario, Then Your Deadline

Identify which of the two scenarios applies, check the treaty between France and the deceased's country, and diarise the 6 or 12 month deadline. This article is general information, not personal advice: the right answer depends on the treaty, the family situation and the assets involved. GME Audit, a firm led by Steeve Elharrar, expert-comptable and commissaire aux comptes, ex-KPMG and Deloitte, advises non-resident owners and heirs in English and French. If you want your case sized precisely, request a quote on our real estate tax advisory in France page. You may also find it useful to read our guidance on choosing an English-speaking tax adviser in France.