Inheritance and Estate Tax in France

How does France structure inheritance tax?

France's droits de succession (inheritance tax) is a beneficiary-side levy: each heir calculates and pays tax on their own net share of the estate, after deducting debts and personal allowances. There is no single estate-level charge. The Direction Generale des Finances Publiques (DGFiP) administers the tax under Articles 777-790 of the Code General des Impots (CGI). A notaire (civil-law notary) typically handles the estate declaration and computes the liability for each beneficiary. The Declaration de Succession (Form 2705) must be filed with DGFiP within six months of death when the deceased was resident in France, or within twelve months when the death occurred abroad [1].

If the deceased was a French tax resident, all worldwide assets are within the scope of French inheritance tax. If neither the deceased nor the heir was French-resident, only French-situated property is taxable. Where the heir has been a French tax resident for at least six of the ten years preceding the inheritance, worldwide assets are also drawn in (Article 750 ter CGI) [2].

Are spouses and PACS partners exempt from inheritance tax?

Yes. Since the Loi TEPA (Loi en faveur du Travail, de l'Emploi et du Pouvoir d'Achat) enacted in August 2007, surviving spouses and registered PACS (Pacte civil de solidarite) partners are fully exempt from droits de succession, regardless of the amount inherited [1]. This exemption is unconditional and does not require any minimum period of marriage or civil partnership. It covers all assets, whether French-situated or worldwide.

Note that the TEPA exemption applies to inheritance only. Lifetime gifts (donations) between spouses are not fully exempt: they carry a separate allowance of EUR 80,724 per 15-year window, followed by the same progressive rate scale that applies to direct-line gifts. A registered PACS partner does not enjoy the same gift allowance as a spouse for lifetime transfers, so the distinction between inheritance and gift treatment is material for partners considering inter-vivos arrangements. A qualified notaire can clarify the difference in a specific situation.

Brothers or sisters may qualify for a separate full exemption under Article 796-0 ter CGI if, at the time of death, the sibling was unmarried (or widowed or divorced), was over 50 years old or disabled, and had been living continuously with the deceased for at least five years. All three conditions must be met simultaneously.

What allowances and rate scales apply by relationship?

Once a qualifying allowance is subtracted from a beneficiary's net share, the remaining taxable amount is subject to a progressive rate scale specific to that relationship class. The table below shows the current figures under Articles 779 and 777 CGI (unchanged since 2014; confirmed by DGFiP for 2026) [1]:

The seven progressive bands for direct-line heirs (children, parents) are: 5% on the first EUR 8,072; 10% on EUR 8,073-12,109; 15% on EUR 12,110-15,932; 20% on EUR 15,933-552,324; 30% on EUR 552,325-902,838; 40% on EUR 902,839-1,805,677; and 45% above EUR 1,805,677 [1].

As an illustration: a child inheriting EUR 300,000 from one parent (allowance fully available) pays tax on EUR 200,000 of taxable share. Applying the bands, the liability is approximately EUR 35,194 -- an effective rate of around 11.7% on the EUR 300,000 received. An unrelated heir receiving the same EUR 300,000 pays tax on EUR 298,406 at a flat 60%, yielding approximately EUR 179,044 -- around 59.7% effective.

How does the 15-year gift window interact with inheritance allowances?

The same allowances that apply on death also govern lifetime gifts (donations) between the same donor-beneficiary pair. Crucially, allowances are shared across a rolling 15-year window: any gift made within 15 years before death is aggregated with the inheritance for the purpose of computing available allowances and progressive rate bands. This is the rappel fiscal (fiscal recall) rule under Articles 779 and 784 CGI [1].

If a parent gave a child EUR 60,000 eight years before death, and leaves the same child EUR 150,000 on death, the child's EUR 100,000 direct-line allowance is reduced by the EUR 60,000 already used: only EUR 40,000 remains available against the EUR 150,000 inheritance. The child pays tax on EUR 110,000 instead of EUR 50,000.

Conversely, gifts made more than 15 years before death fall entirely outside the recall window. A child who received EUR 100,000 more than 15 years ago inherits a fresh EUR 100,000 allowance at death. This reset mechanism makes early lifetime giving one of the principal levers for multi-generational wealth transfer in France. Over two consecutive 15-year cycles, a two-parent family can transfer EUR 400,000 per child entirely within the direct-line allowance (2 parents x EUR 100,000 x 2 cycles).

The same 15-year reset applies to gifts between siblings (EUR 15,932 allowance) and between any other relationship class. A notaire can use a donation-partage (anticipated succession arrangement) to formalise multi-beneficiary gifts and fix the valuation date -- which can be material when assets appreciate between the gift and the death.

What is the assurance-vie inheritance regime?

Life insurance contracts (assurance-vie) held under French law follow a separate fiscal framework that sits outside the standard droits de succession calculation. The rules depend on the age at which premiums were paid [3].

Premiums paid before age 70 (Article 990 I CGI): Each named beneficiary receives a personal allowance of EUR 152,500 on the death benefit. On amounts above EUR 152,500 and up to EUR 852,500 (i.e., the next EUR 700,000), a withholding levy of 20% applies. On amounts above EUR 852,500, the rate rises to 31.25%. These rates are not the standard droits de succession scale -- they are flat levies collected directly by the insurer. Surviving spouses and PACS partners are exempt from these levies even for premiums paid before 70 [3].

Premiums paid after age 70 (Article 757 B CGI): The EUR 152,500 per-beneficiary treatment does not apply. Instead, a single collective allowance of EUR 30,500 is shared across all beneficiaries for all contracts combined. Amounts above EUR 30,500 are subject to standard droits de succession rates according to each beneficiary's relationship. Investment gains (interest and appreciation) credited after age 70 remain exempt under this track.

The practical implication is that assurance-vie funded before age 70 can shelter material sums from standard succession rates. A parent who names two adult children as beneficiaries on a EUR 400,000 contract (all premiums before 70) passes EUR 305,000 (EUR 152,500 x 2) entirely free of levy, with the remaining EUR 95,000 subject to 20% -- a total levy of EUR 19,000 versus potentially EUR 50,000-plus under the standard direct-line scale on the same amount.

For estate structuring involving assurance-vie, a qualified notaire or certified financial planner (Conseiller en Gestion de Patrimoine, CGP) should be consulted, as beneficiary-designation clauses have significant legal and tax consequences. See the France country overview for the broader French personal tax context.