Protecting Your Wealth and Your Loved Ones

For many UK and US expatriates, France offers a dream lifestyle — world-class cuisine, stunning landscapes, a slower pace of life, and a strong sense of community. Yet beneath the charm of rural villages and the glamour of the Riviera lies a financial reality that every expatriate must face: France’s complex inheritance and estate planning laws.

If you live, own property, or hold financial assets in France, understanding the local rules around succession, inheritance tax, and estate structure is vital to ensuring that your wealth is passed on according to your wishes — not dictated by the law.

At Blacktower Financial Management, we’ve been advising expatriates on cross-border financial and estate planning for nearly 40 years. Here’s what you need to know about estate planning in France, and how expert advice can help protect your legacy.

1️⃣ Why Estate Planning in France Is Different

Estate planning in France is more complicated than in countries like the UK or the US because of its unique forced heirship rules and regional inheritance taxes.

Forced Heirship (La Réserve Héréditaire)

Under French law, a portion of your estate must be reserved for your direct descendants — your children. This portion is known as la réserve héréditaire, and it applies automatically if you are classed as a French resident or if you own French property.

• If you have one child, they are entitled to 50% of your estate.

• With two children, they share two-thirds equally.

• With three or more, they share three-quarters.

The remainder — the quotité disponible — can be left to a spouse, partner, or another beneficiary.

Why It Matters for Expats

This system can conflict with UK or US estate planning principles, where individuals are free to distribute assets as they choose. Many expatriates are unaware that even with a valid foreign will, French inheritance law may override it if their estate includes property or assets in France.

2️⃣ Inheritance Tax in France (Droits de Succession)

Inheritance tax in France is paid by the beneficiary, not the estate — and the amount depends on their relationship to the deceased and the value of the inheritance.

Tax-Free Allowances (2024)

Example

If you leave €500,000 to an only child, the first €100,000 is tax-free, and the remaining €400,000 is taxed progressively up to 45%.

This highlights why structured estate planning is crucial — the right arrangements can significantly reduce the inheritance tax burden for your heirs.

3️⃣ EU Succession Regulation (Brussels IV)

Since 2015, the EU Succession Regulation (Brussels IV) has allowed individuals residing in France to elect for the inheritance law of their nationality to apply to their estate instead of French law.

For example:

• A British citizen living in France can choose to have UK inheritance law govern their estate.

• A US citizen can opt for US succession law, providing greater testamentary freedom.

This can be done by making a clear statement in your will. However, this election does not exempt your estate from French inheritance tax, which still applies based on your residence and the location of assets.

4️⃣ Estate Planning Strategies for Expats in France

With careful planning, it’s possible to structure your assets to ensure your wishes are respected and your beneficiaries pay less tax.

✅ 1. Create a French Will (or Review Your Existing One)

Even if you already have a UK or US will, it’s highly advisable to create a French will for your French-based assets. This ensures your estate is distributed efficiently under local law and avoids legal disputes or delays during probate.

Blacktower can help you coordinate your will with legal professionals to ensure it aligns with both French and foreign laws.

✅ 2. Use Assurance Vie for Tax Efficiency

An Assurance Vie is one of the most powerful estate and tax planning tools available in France.

This life insurance-based investment structure allows you to:

• Grow your capital tax-efficiently.

• Name beneficiaries directly (bypassing forced heirship).

• Enjoy favourable inheritance tax treatment — beneficiaries can each receive up to €152,500 tax-free if contributions were made before age 70.

For many expatriates, the Assurance Vie forms the cornerstone of a French estate plan, providing flexibility, privacy, and efficiency.

✅ 3. Consider Joint Ownership Structures

If you own property with a spouse or partner, ownership type matters. The tontine clause (en tontine) can ensure that the surviving partner automatically inherits full ownership, but it must be written into the property deed at the time of purchase.

Alternatively, usufruct arrangements (usufruit and nue-propriété) can be used to balance inheritance rights between a surviving spouse and children.

✅ 4. Lifetime Gifting (Donations)

France allows tax-efficient lifetime gifts, with exemptions renewed every 15 years. For instance, you can gift up to €100,000 per child every 15 years without incurring inheritance tax.

Strategic gifting can help reduce the taxable value of your estate while ensuring wealth is passed to future generations during your lifetime.

✅ 5. Review Domicile and Residency

Your domicile and residency status can affect how your estate is taxed internationally. UK and US citizens may still be liable for Inheritance Tax (IHT) or Estate Tax in their home country, even while living in France.

A qualified financial adviser can help you assess your exposure and explore double taxation reliefs where applicable.

5️⃣ Common Estate Planning Mistakes to Avoid

❌ Assuming a UK or US will automatically applies in France.
Without an election under Brussels IV, French law will govern your estate.

❌ Failing to plan for inheritance tax.
Even modest estates can face significant tax bills if not structured efficiently.

❌ Overlooking Assurance Vie or other planning vehicles.
Many expats miss the opportunity to reduce tax and simplify wealth transfer through proper structuring.

❌ Not reviewing your plan regularly.
Changes in residence, marriage, property ownership, or legislation can all impact your estate plan.

6️⃣ How Blacktower Can Help

Estate planning in France can be complex — but it doesn’t have to be overwhelming.

At Blacktower Financial Management, we specialise in helping expatriates:

• Understand French inheritance laws and tax exposure.

• Coordinate wills and estate structures across jurisdictions.

• Use tax-efficient vehicles like Assurance Vie to protect assets.

• Plan intergenerational wealth transfers aligned with their wishes.

We collaborate with trusted French legal and tax professionals to ensure every aspect of your plan is compliant, efficient, and built around your goals.

Secure Your Legacy in France

You’ve worked hard for your wealth — and with the right estate plan, you can ensure it benefits the people and causes you care about most.

Whether you’re a retiree in Provence or a professional in Paris, Blacktower Financial Management can help you build a lasting legacy with clarity, control, and confidence.

📞 Book your complimentary consultation today
Speak to one of Blacktower’s expert financial advisers in France to discuss how we can help you protect your estate and secure your family’s financial future.

Disclaimer: The above information was correct at the time of preparation and does not constitute investment advice. You should seek advice from a professional regulated adviser before embarking on any financial planning activity.