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Estate & Legacy

Inheritance Tax France 2026

Complete guide to French inheritance tax (droits de succession) in 2026 — spouse full exemption, children's €100.000 allowance, 15-year reset rule, rates up to 60% for unrelated heirs, and planning for French estates.

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CQ Score
Verified Data Source: Direction Générale des Finances Publiques (DGFiP) ↗ Updated Jan 2026
Full exemption — 0% on entire estate
Spouse / PACS Partner
Loi TEPA 2007 — total exemption for époux and partenaire PACS
€100.000 per child
Children Allowance
Resets every 15 years — most generous EU allowance per child
5% to 45%
Children Rates
Progressive: 5% on first €8.072, rising to 45% above €1.805.677
35% up to €24.430 / 45% above
Siblings Rate
After €15.932 exemption — very high for siblings
60% flat
Unrelated Persons Rate
After €1.594 exemption — highest in EU for unrelated heirs
Gifts reset every 15 years
15-Year Rule
Rappel fiscal — gifts within 15 years aggregated with inheritance
Data status: Current
Last updated: Jan 2026
Next review: Jan 2027
Update cycle: Annual (Loi de finances)
2026: no major structural changes. €100.000 child allowance unchanged since 2012. Spouse full exemption (loi TEPA 2007) unchanged. 15-year reset rule confirmed. Debate ongoing about wealth tax reform but droits de succession structure stable.
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France's full spouse exemption (since 2007) means the family estate passes between spouses completely tax-free — but divorce or PACS dissolution is catastrophic
The loi TEPA (August 2007) abolished droits de succession entirely for spouses and PACS partners — a reform under Sarkozy that remains in place across all subsequent governments. A spouse inheriting a €10m estate in France pays zero inheritance tax. This is far more generous than Germany (€500k exemption, then 7-30%) or the Netherlands (€795k exemption). However, the exemption requires legal marriage or registered PACS — unmarried cohabitation (concubinage) gets only the €1.594 unrelated allowance and faces 60% tax. Critically, the PACS must be registered — and PACS dissolution (which can be done unilaterally) removes the protection.
Source: CGI Article 796-0 bis — exonération époux et partenaires PACS
The 60% unrelated heir rate makes France prohibitive for estates going to friends, stepchildren without adoption, or distant relatives
France applies a flat 60% tax on inheritances to unrelated persons after a €1.594 allowance — the highest inheritance tax rate in the EU. A friend inheriting €500.000 pays approximately €299.000 in tax (60% of €498.406). Stepchildren who were not formally adopted face this rate unless the parent took specific steps. This has driven many wealthy French residents to structure their estates using assurance-vie (life insurance), which passes outside the succession entirely with more favourable tax treatment. The 60% rate is widely seen as confiscatory and creates strong planning incentives.
Source: CGI Article 777 — tarif des droits; Article 793 — cas particuliers
The 15-year rappel fiscal rule means gifts must be planned very far in advance to benefit from the full €100.000 reset
France's rappel fiscal (gift recall) aggregates all gifts made to the same beneficiary within the past 15 years with the current inheritance — preventing multiple uses of the €100.000 allowance. In practice: a parent gives €100.000 to a child in Year 1 (tax-free), then dies in Year 14 — the child has already used the allowance and the entire inheritance is taxable from the first euro. Compare with Germany's 10-year rule — France requires 15 years between gifts to maximise planning. The practical implication: inter vivos gift planning must start when parents are in their 50s to allow two full 15-year cycles before death.
Source: CGI Article 784 — rappel des donations antérieures
French Inheritance Tax — Progressive Rates (Children, Line Directe) CGI Article 777
Effective Inheritance Tax — Child Inheriting €500k — EU Comparison 2026 National tax authorities
📋 Reference Data
French Inheritance Tax — Rates and Allowances 2026 CGI Articles 779, 777 — DGFiP
BeneficiaryTax-Free AllowanceRatesNotes
Spouse / PACS partner FULL EXEMPTION 0% on all Loi TEPA 2007 — total exemption
Children / Parents €100.000 each 5%-45% progressive Rappel fiscal: 15-year aggregation with gifts
Grandchildren €31.865 each Rates vary Different schedule from children — line 2 below
Siblings €15.932 35% up to €24.430 / 45% above Very high — consider PACS or adoption strategies
Nieces / Nephews €7.967 55% flat After exemption
Disabled persons (all) Additional €159.325 Cumulative with other allowances Handicapé — additional allowance
Unrelated persons €1.594 60% flat Amis, concubins, step-children non-adopted
FRUP / Fondations Full or partial exemption 0% Recognised public utility foundations
ⓘ The children's €100.000 allowance applies individually to each parent-child relationship — so two parents dying can give €200.000 total to each child tax-free. The rappel fiscal looks back 15 years — gifts made more than 15 years before death do not reduce the allowance.
French Inheritance Tax Rate Bands — Children / Direct Line (In Force 2026) CGI Article 777 — Tableau I
Taxable Band (after allowance)RateCumulative Tax at Band CeilingNotes
Up to €8.072 5% €403 Very low entry rate
€8.072 to €12.109 10% €807
€12.109 to €15.932 15% €1.381
€15.932 to €552.324 20% €108.674 Main band — covers most estates after €100k allowance
€552.324 to €902.838 30% €213.849 Large estates — effective rate rising
€902.838 to €1.805.677 40% €574.982 High net worth
Above €1.805.677 45% 45% on excess Top rate — very large estates
ⓘ Rates apply to the net taxable share — estate value attributed to each heir after debts, funeral costs, and personal allowance. Abattements (allowances) are deducted before applying rates. For a child inheriting €500.000: taxable base = €400.000 (after €100k allowance). Tax = €403 + €404 + €573 + €76.874 = approximately €78.000 (19.5% effective rate on €400k taxable, or 15.6% on €500k total).
Assurance-Vie vs Succession — French Estate Planning Tool Comparison CGI Articles 990-I and 757-B; DGFiP
FeatureStandard SuccessionAssurance-Vie (life insurance)Notes
Regime Droits de succession Specific tax regime — outside succession Key advantage — hors succession
Spouse/PACS beneficiary Full exemption Full exemption Same result
Child beneficiary (premiums pre-70) €100k allowance + 5-45% €152.500 per beneficiary + 20% up to €700k, 31.25% above More generous than succession for larger amounts
Child beneficiary (premiums post-70) €100k allowance €30.500 shared allowance + succession rates on gains Less favourable for post-70 premiums
Unrelated beneficiary (pre-70) 1.594 + 60% €152.500 + 20-31.25% FAR more favourable — key use case
Rappel fiscal 15-year rule applies Does NOT apply — outside succession Critical advantage for tax planning
Planning horizon 15 years between gifts No time constraint on premium payments More flexible
ⓘ Assurance-vie is the most widely used French estate planning tool — approximately 54% of French household financial wealth is held in assurance-vie contracts. The €152.500 per-beneficiary allowance for contracts funded before age 70 is completely independent of succession allowances — a client can give €100.000 succession gift AND place €152.500 in assurance-vie for the same child, effectively doubling the tax-free transfer.
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🔬 Methodology & Sources
French Inheritance Tax Data
Droits de succession governed by Code Général des Impôts (CGI) Articles 750 ter to 798 A. Administered by DGFiP through the recettes des impôts (tax offices). French notaires are legally required to handle most successions and collect tax due. The spouse exemption (loi TEPA, August 2007) was a landmark reform. The €100.000 child allowance has been unchanged since August 2012 (raised from €159.325 — actually reduced). The rappel fiscal was extended from 10 to 15 years in 2012. Assurance-vie regulation under CGI Article 990-I (pre-70 premiums) and 757-B (post-70 premiums).
Formula
Tax_due = Progressive_rate(Net_taxable_share) | Net_taxable_share = (Estate_value / N_heirs_line) − Allowance − Debts | Rappel: current_taxable += gifts_within_15_years
CitationCode Général des Impôts Articles 777-798; Réponse ministérielle Dumont 2019 (rappel fiscal); Feuillet rapide Lefebvre Sarrut Succession 2025.
❓ Frequently Asked Questions
No — spouses and registered PACS partners are completely exempt from French inheritance tax (droits de succession) since the loi TEPA of August 2007. A spouse can inherit an estate of any size — €1m, €10m, €100m — and pay zero French inheritance tax. This full exemption applies to both marriage and PACS (civil partnership). Unmarried cohabitants (concubins) are not covered — they receive only a €1.594 allowance and face the 60% unrelated person rate. PACS partners must register their partnership at the tribunal judiciaire or notaire.
Each child receives a €100.000 personal allowance per parent. For a child inheriting €400.000 from one parent: taxable base = €300.000. Tax = 5% on €8.072 (€403) + 10% on €4.037 (€404) + 15% on €3.823 (€573) + 20% on €283.069 (€56.614) = approximately €58.000 total, or 14.5% effective rate on the full €400.000. For two parents dying with the same estate, the child gets €100.000 exemption from each parent — so €200.000 total tax-free across both inheritances.
France's rappel fiscal aggregates all taxable gifts received from the same person within the 15 years before their death with the current inheritance — for tax calculation purposes. The effect: if a parent gives a child €100.000 in Year 1 (using up the full allowance tax-free), and dies in Year 14, the child has zero allowance remaining — the entire inheritance is taxable from the first euro. If the parent dies in Year 16, the gift has dropped out of the 15-year window and the full €100.000 allowance is available again. Planning implication: gifts must be made at least 15 years before death to fully benefit from the allowance reset.
Assurance-vie (life insurance/investment wrapper) is France's primary estate planning tool — holding approximately 54% of French household financial wealth. Money invested in assurance-vie passes outside the standard succession to named beneficiaries, under a specific tax regime. For premiums paid before age 70: each beneficiary receives a €152.500 allowance (versus €100.000 in succession), taxed at 20% up to €700.000 and 31.25% above. This allowance is completely separate from the succession €100.000 — so a parent can give a child €100.000 through succession AND €152.500 through assurance-vie tax-free. For unrelated beneficiaries (e.g., a partner or friend), assurance-vie at 20-31.25% vs succession at 60% is dramatically more favourable.
Yes — French inheritance tax applies in two situations for non-residents: (1) If the deceased was domiciled in France — worldwide assets are taxable (Article 750 ter CGI); (2) If the deceased was not France-domiciled but owned French situs assets (real estate, French company shares, French bank accounts) — only those assets are taxable. If the heir is domiciled in France but the deceased was not, French assets are taxable from the French side. France has inheritance tax treaties with: USA, UK, Germany, Switzerland, Austria, Sweden, and several others — which may provide relief. The France-USA treaty is particularly important for US citizens with French real estate.
Sources & References
DGFiP — Droits de succession 2026 Retrieved 2026-01-01
BOFIP — Succession et libéralités Retrieved 2026-01-01

Data sourced from official institutional publications. Results are for informational purposes only. Last reviewed Jan 2026.

Data Disclaimer
French inheritance tax sourced from Code Général des Impôts (CGI) and BOFIP (Bulletin Officiel des Finances Publiques). French tax law is complex — always consult a notaire and expert-comptable for specific situations. This is informational only.