UK Inheritance Tax V French Succession Tax
By Lorraine Chekir
This article is published on: 19th May 2016
This is an area that many expats find very confusing: what and where to declare, what and where to pay, where to even start!
It doesn’t help that UK and France have completely different rules. In the UK the estate pays the tax and the net proceeds are paid to the beneficiaries. In France, the proceeds are paid to the beneficiaries. The beneficiary will then complete a Succession tax form and pay the inheritance tax, the amount of which is based on their relationship to the deceased.
What many expats do not realise is that if you are a French resident and inherit from someone who was a UK resident you need to complete and submit a French Succession tax form to URSAAF within 12 months of their death. No actual tax is payable in France as there is a tax treaty in place between the two countries.
Let’s look at a couple of different scenarios:
You are a UK resident and own a property in France. When you pass away your estate will be taxed in the UK on your worldwide moveable assets. However, your property in France will be subject to French inheritance tax.
If you are a French resident, when you pass away French inheritance tax will apply to your worldwide assets. If you still have UK assets, it may be that you will also pay some inheritance tax in the UK, however there is a tax treaty in place to ensure that you do not pay tax twice on the same assets.
Inheritance Rules:
In the UK the law says you can make a will naming whoever you wish as your beneficiaries. If you have not made a will, then the rules of intestacy apply and the distribution of your estate is based on these. If you have no living relatives, even long lost and distant, then everything you have will go to the Crown. Anyone born in Scotland would have some restrictions on who they could leave their estate to.
In France you cannot freely dispose of “la réserve” which must be held for your children. You are only free to dispose of as you wish the “quotité disponible”. A spouse is not a protected heir in France, however unless you specifically disinherit them, they are entitled to a quarter of your estate. The amount freely disposable from your estate will depend on the number of children you have.
- If you have one child they are entitled to half of your estate with half freely disposable
- Two children are entitled to two thirds with one third freely disposable
- Three children are entitled to three quarters with one quarter freely available
Since August 2015 it has been possible, in your French will, to adopt the inheritance rules of your country of nationality. This means if you are from the UK then you can adopt UK inheritance rules and leave your estate to whoever you wish. However, it is important to note this applies to inheritance rules not tax, French inheritance tax will still apply. I think this change in legislation will be of particular importance to people in second marriages with children from previous relationships and maybe from the current relationship also. For some reason, the UK and Ireland have chosen not to sign up to this change, which means if you are from the EU and living in the UK your estate will be subject to UK inheritance rules and tax.
Inheritance Tax Rates:
In the UK, the first 325,000 GBP of a person’s estate is free of inheritance tax. From the tax year 2017/18 if you have a family home that will pass directly to your children, then an additional allowance of 100,000 GBP will apply, rising to 175,000 GBP by 2020. This means that by 2020, married couples and those in civil partnerships with a family home to pass to children, could pass a total of 1m GBP free of inheritance tax. Inheritance tax in the UK is 40% of everything above your allowance.
In France, each person can leave 100,000 Euro to each of their children free of inheritance tax. Above this there is a sliding scale starting at 5% and rising to 45%. However as a guide, between 15,932 Euro and 552,324 Euro, the rate payable by the beneficiary is 20%.
For siblings, the first 15,932 Euro of what you leave them is free of inheritance tax, then they pay 35% on the next 24,430 Euro and 45% on everything else
Nieces and nephews can have just 7,967 Euro free of tax then pay a whopping 55% on the rest.
Everyone else (including non-married partners) can inherit a measly 1,594 Euro free of tax and will pay a massive 60% on amounts above this.
An important tax planning tool is the Assurance Vie. Providing it is set up before age 70, you can name beneficiaries and each beneficiary can inherit 152,500 Euro free of inheritance tax, amounts between 152,500 Euro and 852,500 Euro will be taxed at 20% and anything over this at 31.5%. As you can imagine, this could make a huge tax saving, especially for non-married partners, nieces, nephews and beneficiaries not related to you, with potential tax savings of up to 60%. The great thing is, it remains your money until you die which means you have full access if you need it, unlike when you put money in a trust in the UK to try and reduce your inheritance tax liability. In addition, it is the nearest thing the French have to an ISA as your money grows tax free.
If you want any more information or would like some advice, please contact me on the number or email below.
I also hold a free financial surgery in Café de la Tour in Les Arcs on the last Friday morning of each month where you can discuss your own situation in confidence over a cup of coffee.
This article is for information only and should not be considered as advice and is based on current legislation. 04/05/2016.
Stay invested and don’t try to second guess the market – Discipline is rewarded
By Derek Winsland
This article is published on: 6th May 2016

Individual investors may face many “known unknowns”—that is to say, things that they know they don’t know. The UK’s referendum on EU membership is one of them, confronting people with a large degree of uncertainty. But as we’re witnessing, it’s not just the investor that’s afflicted by this Known Unknown condition – the markets are really uncomfortable as evidenced by the fall in the value of the pound.
We have though been here before; perhaps not having to make decisions that could affect our financial stability for years to come, but as the chart below shows, major global events that have impacted on our lives to a greater or lesser effect. Through all of them, the markets have shown a remarkable resilience over the longer term and that is one of the most important lessons the individual investor can learn.
You see, it’s not necessary to “make the right call” on the referendum or its consequences to be a successful investor. Our approach is to trust the market to price securities fairly; to take account of broad expectations of future returns.
In arguing for the status quo, the “remain” campaign is able to point out familiar characteristics of membership.
The “out” campaign, however, is based on intangibles that can only be resolved after the result of the referendum is known. It is impossible for any individual to predict the implications of these unknowns with certainty.
But this is no cause for concern. While the referendum is imminent and its implications are potentially vast and unpredictable, it is not necessary for individual investors to make any judgement calls on the outcome. We have faced many uncertainties in the past—general elections, market crises, recessions, wars—and throughout all of them, the market has done its job of aggregating participants’ views about expected returns and priced assets accordingly.
And while these events have caused uncertainty, volatility and short-term losses and gains, none of them has altered the expectation that stocks provide a good long-term return in real terms.
We have a global view of investing, and we know that the market is very good at processing information that is relevant to future returns. Because of this view, we don’t attempt to second-guess the market. We manage well-diversified portfolios that do not rely on the outcome of individual events or decisions to target the expected long-term return.
These events are not offered to explain market returns. Instead, they serve as a reminder that investors should view daily events from a long-term perspective and avoid making investment decisions based solely on the news. Past performance is no guarantee of future results. MSCI data © MSCI 2016, all rights reserved.
Research has demonstrated time and again that the best returns are achieved through ‘Time in the Market’ and not by trying to ‘Time the Market’; in other words, stay invested rather than guess the best time to invest and disinvest.
If you would like more information on our investment philosophy, please ring for an appointment or take advantage of our Friday Morning Drop-in Clinic here at our office in Limoux. And don’t forget, there is no charge for these meetings.
French Tax Return dates 2016
By Spectrum IFA
This article is published on: 11th April 2016
The time is approaching for French residents to make their 2016 income tax declarations and there is an important change in procedure.
If your revenue fiscal de reference (taxable income) was at least €40,000 in 2014 (i.e. as declared in 2015), then you are now obliged to make an on-line declaration. The only exception to this is if your principal residence does not have an internet connection, in which case, you can still submit a paper declaration. By 2019, only on-line declarations will be possible and between now and then, the ceiling of the income limit for paper declarations will reduce each year.
On-line declarations can be made from 13th April 2016 up to the following deadlines:
• 24th May 2016 for departments 01 to 19;
• 31st May 2016 for departments 20 to 49; and
• 7th June 2016 for all other departments and non-residents.
Paper declarations, where permitted, must be submitted by 18th May 2016.
For those of you who came to live in France during 2015, then you will need to make your first French tax declaration and declare all your worldwide income and gains, but only for the period since becoming resident in 2015. To do this, you will need to collect the necessary forms from your local tax office.
Income and gains that might be tax-free in another country, for example, UK ISAs, premium bond winnings and Pension Commencement Lump Sums, must be declared, as all are taxable in France. Even for income that is taxable in another country, for example a UK government type of pension (i.e. civil service, military, police and teachers pensions, but not State pensions) and/or UK property rental income, the amount must still be reported in France and it will be taken into account in calculating your French income tax. You will then be given a tax reduction to take into account the fact that the income is taxable elsewhere.
If you have been living in France for less than 183 days in 2015, you may be thinking that you do not need to register in the French tax system. This is a myth because the time that you spend in France is not the only factor that is taken into account in determining whether or not you are resident in France. For more on this, please see my article at:
If you do not register in the French tax system and you should have done, you risk a financial penalty. Never mind what that nice lady in the tax office says about you not needing to register if you have been here for less than a year – you will be liable for the fine, not her!
Are you convinced now to register in the system? If you’re still not sure, call me and with just a few questions, I will be able to tell you.
It is also obligatory to declare the existence of bank accounts and life assurance policies held outside of France, regardless of whether these accounts pay interest or if there is a zero balance in the account. The penalties for not doing so are €1,500 per account or contract, which increases to €10,000 if this is held in an uncooperative State that has not concluded an agreement with France to provide administrative assistance to exchange tax information. Furthermore, if the total value of the accounts and contracts not declared is at least €50,000, then the fine is increased to 5% of the value of the account/contract as at 31st December, if this is greater than €1,500 (€10,000 if in an uncooperative State).
No-one should ever try to second guess the Fisc or think that they can out-manoeuvre this government department. I hear some interesting stories of people being contacted and questioned about why they are not registered in the French tax system. You would be amazed at what is used to check – telephone bills, utility bills, etc., etc. How long will it be before our use of cash machines and our bank and credit card transactions in shops might be used to verify how much time we spend in France? Scary thought and actually they probably don’t need to go that far, as we can be tracked through our mobile phones and probably also our internet use.
On a final note, if anyone finds that they need to complete the pink 2047 form, this means that you have foreign income and/or gains to declare. If this is for any reason other than pension income and earnings, then perhaps you may benefit from a brief discussion to see if your financial situation can be improved by investing in something that is more tax-efficient for French residency.
If you would like to have a confidential discussion with one of our financial advisers, you can contact us by e-mail at limoux@spectrum-ifa.com or by telephone on 04 68 31 14 10. Alternatively, drop-by to our Friday morning clinic at our office at 2 Place du Général Leclerc, 11300 Limoux, for an initial discussion.
The Spectrum IFA Group advisers do not charge any fees directly to clients for their time or for advice given, as can be seen from our Client Charter at
https://spectrum-ifa.com/spectrum-ifa-client-charter/.
Le Tour de Finance
By Spectrum IFA
This article is published on: 21st March 2016
The first spring leg of Le Tour de Finance has finished in France, with three events being held in Limoges, Poitiers and Mouzeil.
The events were a resounding success with attendance up on last year and an extended pool of international guest speakers present for the three events. The organisers work hard to bring representatives from large international financial institutions to these events, giving attendees unrivaled personal access to these experts and asksome of those ‘need to know’ questions in a small and informal group. Each event ends with a complimentary buffet and offers attendees even more personal access to the experts.
Le Tour de Finance will return to France in May with events in Toulouse, Bergerac and Brantome with further events in June.
Le Tour de Finance – Italy
Le Tour de Finance continues in April with events in La Spezia on the 13th April and in Milano on the 14th April. More information and booking information can be found here.
Le Tour de Finance – London
We are also pleased to announce that Le Tour de Finance will be running an event in London. This is the perfect opportunity for those of you who are thinking of making the move to France and will allow you to ask these experts direct questions about becoming an expat.
For more information about Le Tour de Finance in London please click here
Le Tour de Finance – Spring Seminars
By Spectrum IFA
This article is published on: 23rd February 2016

The spring run of Le Tour de Finance seminars in France is kicking off this week on the 8th March in Limoges and then moves on to Poitiers on the 9th March and Mouzil on the 10th March.
Le Tour de Finance in 2015 proved to be the most popular series of events ever and we celebrated the 100th event in November. The seminars offer English speaking expats a chance to meet various experts from fields including; specialist expat independent financial advice, mutli-asset wealth management, currency exchange, QROPS/pensions and expat tax advice. The experts represent a range of international institutions giving attendees unprecedented access to ask those nagging questions about living as an expat in France.
The events commence at 10am with a welcome coffee followed by a series of short and informative presentations. The seminars are wrapped up with a free buffet lunch and the chance to personally meet these experts and mingle with other like minded expats.
The next events are:
8th March 2016 | Haute-Vienn Limoges | Register Now | |
9th March 2016 | Poitou-Charentes Poitiers | Register Now | |
10th March 2016 | Pays de la Loire Mouzeil | Register Now |
If you would like further information or would like to book a place, please contact us
The objective of Le Tour de Finance is to provide expatriates with useful information relating to their financial lives. We try and cover frequently asked questions that we receive from our clients. It would be helpful for us to know what your particular areas of interest might be.
For further details and to book your place at a future event please register here or complete the form below.
Personal Financial Planning in France – if I knew then what I know now…
By Jonathan Cooper
This article is published on: 9th February 2016

A British National, I came to France in 1996 for what was meant to be a 3-year local contract. But here I am, still living in France 20 years later. Sound familiar?
This year, at the age of 57, I stopped full-time employment, though I expect to stay in France for some years to come. Here are a just few of the useful things I’ve learned over the years, as an expat in France, focusing on tips for those of you who are still relatively new to France.
Tax efficient investment vehicles
The ISA doesn’t exist in France, but the Plan d’Epargne en Actions (PEA) and the Assurance Vie (AV) do. One can invest 150k euros in a PEA, and after 5 years the gains are free from Capital Gains Tax (CGT). There is no limit to the number or amount invested for AV’s, and after 8 years, any gains on withdrawal attract only 7.5% tax (over 9200 euros/yr). Both PEA’s and AV’s attract Social Charges on investment gains. With present interest rates low, an AV older than eight years is a much better option than a savings account (Compte Epargne). Your employer might also offer you a Plan d’Epargne d’Enterprise (PEE) where investment gains are free from CGT after 5 years.
My advice to anyone becoming tax resident in France is to open a PEA and an AV as soon as you arrive, with just a small initial investment, just to get the clock ticking. You can always close them if your short term contract turns out to be just that!
Pensions, QROPS & PERPs
Years worked in the UK can be transferred to the French system, and additional years purchased at little cost, which can greatly increase the value of your French Pension.
With the 15-year Gilt Rate presently so low, UK pension pot valuations are very high. If you are thinking of staying overseas, it is a good time to consider the Pro’s and Con’s of transferring your pot to a Qualifying Recognised Overseas Pension Scheme (QROPS).
Each year you can invest up to 10% of your salary free of income tax (within the maximum of 8 times the Social Security ceiling) in a Plan d’Epargne de Retraite (PERP), and you can accumulate up to 3 years if you do not use this 10% annual allowance. If you have been made redundant, at the end of the 3-year period of unemployment benefit, you can withdraw all the funds from a PERP free of CGT, so avoiding taking an annuity. Investments in a PERP are not subject to Wealth Tax (ISF).
Getting good, in-depth financial advice
I have always worked with one of the big French Banks and whilst they offer a range of products, their understanding of the needs of Anglo-Saxons is not always high. They recommend mainly in-house products and could be a lot more pro-active.
My employers were kind enough to offer me big consultancy companies to help fill out my annual French tax forms. The introductory meetings with senior directors always went well, but it was clear the forms were filled out by very junior staff, and their aim was to fulfil a service to the employer as much as to me – they are not at all there to offer advice and optimise tax.
Whilst it’s taken me a while to realise, it’s best to seek the assistance of specialist independent financial advisers, people who really understand both the UK and French financial space. I like to have more than one, in addition to the bank, to ensure several points of view/proposals on which to base decisions.
From experience, I can certainly recommend Jon Cooper (The Spectrum IFA Group) and Thierry Mandengue (VIP Partner) – they have undoubtedly saved me tens of thousands of euros.
In my next article, I will share my knowledge of Stock Options, PEE’s and Inheritance planning. I’d be happy to discuss expat finance further if anyone is interested (mspowell58@gmail.com).
*This article has been written by Dr. Martin Powell, a retired, British, Senior Corporate Executive living in France and a client of Jonathan Cooper
Le Tour de Finance – 100th event in Dinard
By Spectrum IFA
This article is published on: 15th November 2015
Our 100th financial seminar was quite rightly our biggest yet with approximately 90 attendees out of the 106 who had RSVP’d.
Guest speakers from Rathbones, SEB, Tilney Best Invest, Prudential International and Standard Bank all flew in specially for this event alongside the organisers and founders, Pippa Maile from Currencies Direct and Michael Lodhi from The Spectrum IFA Group.
The venue, Le Grand Hotel Dinard, was a fabulous location with first-class service and an excellent buffet lunch to finish.
There were plenty of prized to mark the event – five lucky attendees went home with 100euros in cash each, everyone received a goodie bag plus there was a prize draw for other prizes including champagne, signed British rugby shirts and autographed books.
Thank you to everyone who came along and made this such a great success. If you are one of the people who unfortunately had to cancel at the last minute, please feel free to drop us a line at seminars@ltdf.eu if you would like copies of the presentations or have a specific topic that you would like advice on.
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