French Inheritance Taxes: Is It Worth Dying in France?

With all of the benefits of the US-France tax treaty, France, one of the highest-tax countries in the world, looks a lot like a tax haven for Americans.

With no French tax due on retirement income and pensions, plus credits eliminating tax on capital and received inheritances, is France really a tax utopia?

Nothing can be certain except death and taxes. And in France, those two go hand-in-hand, even for Americans.

Below, we’ll look at French estate and inheritance taxation, what your heirs can expect, and why the tax treaty doesn’t provide more protection.

Disclaimer: This article is for informational purposes only and does not constitute tax or legal advice. French and US tax laws can be complex and change over time. Consult a qualified professional before making decisions based on this information.

Estate vs Inheritance Tax in France

The difference between Estate and Inheritance taxes

For those unfamiliar, estate and inheritance taxes are not the same. Both are triggered by the transfer of wealth on death, but each taxes from a different perspective.

Estate taxes are levied on the whole of the assets of the deceased, before they are passed on. The US has a federal estate tax, although the exemption is $15M in 2026, so most estates will owe nothing. Some US states also impose an estate tax, but most do not.

Inheritance taxes are owed by the heir on the wealth they personally inherit from an estate. The US has no federal inheritance tax, but a few states do.

Does France have an Estate Tax?

France does not have an estate tax. Rather, each heir pays an inheritance tax with rates that depend on the amount inherited and the relationship to the deceased.

French Inheritance Taxes

France does tax inheritances, and the rates vary based on relationship to the deceased as well as the amount inherited.

For simplicity’s sake, we’ll focus on direct line heirs – parents to children or children to parents.

Inheritance Allowances

First, each parent/child has a €100,000 allowance. Inheritance taxes are only calculated on amounts above the allowance.

Note that the allowance is shared with the gift tax allowance (droits de donation), resetting every 15 years. The inheritance is treated like a gift would be, even sharing the same tax bands.

Inheritance Tax Rates

Below are the tax rates charged on inheritances (and gifts) received by a direct-line heir, parent to child or child to parent.

Taxable share after allowance	Scale of taxation
Up to €8,072	5%
From €8,073 to €12,109	10%
From €12,110 to €15,932	15%
From €15,933 to €552,324	20%
From €552,325 to €902,838	30%
From €902,839 to €1,805,677	40%
More than €1,805,677	45%

While the surviving spouse is fully exempt from inheritance taxes in France, it’s important to be aware of France’s forced heirship laws. The entire estate does not pass to the surviving spouse when there are children, which can trigger the above taxes much earlier than expected.

Applying the US-France Estate Tax Treaty

When a US citizen residing in France dies, their heirs must pay inheritance taxes to France, depending on the type of property being inherited. This is all governed by the US-France Estate Tax Treaty. The tax will be owed regardless of whether the heir resides in France or not.

What’s only taxed by the US

Immovable US property, such as real estate or a physical business, is sheltered by the treaty from French taxes.

Essentially, if it’s sitting in America, then it gets taxed in America.

What gets hit by French taxes

Almost everything else is subject to French inheritance taxes. Cash, brokerage accounts, retirement accounts; anything considered movable property will be taxed by France.

Forced Heirship in France

France uses the concept of forced heirship in their succession laws. Children are protected heirs and inherit a portion of the estate upon the death of a parent, even with a surviving spouse.

This differs significantly from US or UK norms, where the estate usually passes entirely to the surviving spouse upon the first death, and only to the children on the second death.

Succession laws in France are a very complicated and ever-evolving topic. But it’s an important one as the French tax authorities will be eager for a cut of the estate as part is forcibly passed to the children, even with a surviving spouse.

Minimizing Inheritance Taxes in France

Hoping to pass on your legacy to your children, rather than to French bureaucrats? With some planning ahead, there are ways to reduce the overall inheritance tax burden.

Don’t die in France

Both the easiest and hardest to plan for, simply leaving with enough time to establish tax residency somewhere else can be the most bulletproof way to dodge French inheritance taxes.

Start gifting now

Each parent can gift each child €100,000 plus €31,865 in cash every 15 years without owing French gift tax. This is one of the core ways the French use to avoid large inheritance tax bills, although it requires plenty of time and planning ahead.

Shift assets to the US

As seen in the treaty, immovable property located in the US is exempt from French inheritance taxes. While managing real estate from the other side of the Atlantic may not be every retiree’s dream, it can set up heirs to avoid dealing with French tax collectors on the properties.

Conclusion

As covered previously, the US-France Estate Tax Treaty protects US citizens residing in France from paying the high French inheritance taxes when receiving an inheritance from the US. Money flowing into France from the US is generally protected by the treaty.

But things shift drastically the other way around. When it’s the French resident who has died and the heirs are receiving an inheritance, the taxes generally do apply. Money coming out of France is taxed by France, even if it goes to US citizen heirs who’ve never set foot in France.

Planning ahead is essential for those expecting to settle in France permanently and hoping to leave a legacy to their heirs.

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