French Inheritance Tax for UK Owners: Rates, Heirs and the UK Overlap

French inheritance tax, the droits de succession, applies to a French property whoever owns it, so a UK owner's holiday home or apartment is caught even though you have never lived in France. The tax is worked out on each person who inherits, based on their share and their relationship to you, and it can sit alongside a UK inheritance tax charge on the same property.

Does French inheritance tax apply to UK owners?

Yes. French inheritance tax applies to any property located in France, so a UK owner's French home is taxed in France regardless of where the owner lives or holds their nationality. France taxes the beneficiary on what they receive, not the estate as a whole, which is the opposite of the UK approach.

Location, or situs, is what pulls the asset into the French charge. A house, apartment or plot of land in France is French-situated, so it falls under French rules on succession and tax even for an owner who is resident and taxed only in the UK. French bank accounts linked to the property are usually caught in the same way.

Because the tax lands on each heir separately, two people inheriting equal shares can face very different bills. A surviving spouse or registered civil partner (a PACS partner) pays no French inheritance tax at all, while a friend or unmarried partner inheriting the same share pays 60% (service-public.fr, as at August 2026, subject to change).

How much is French inheritance tax?

French inheritance tax depends entirely on who inherits. Each heir first deducts a tax-free allowance set by their relationship to you, then pays a rate on the balance: a rising scale from 5% to 45% for children and grandchildren, or a flat 55% or 60% for more distant and unrelated heirs. Spouses and PACS partners are exempt.

Source: service-public.fr, French succession allowances and rates, as at August 2026, subject to change.

For a child or other direct descendant, the rate rises in bands: 5% up to €8,072, 10% to €12,109, 15% to €15,932, 20% to €552,324, 30% to €902,838, 40% to €1,805,677, and 45% above that, each band applying only to the slice of value inside it.

If your only child inherits a French home worth €400,000, they deduct the €100,000 allowance, leaving €300,000 taxable. Running that through the bands gives roughly €58,200 of French inheritance tax, an effective rate of about 14.5% on the €400,000. The same €400,000 passing to a niece, after her €7,967 allowance, would be taxed at 55%, a bill of around €215,600.

Can your English will override French forced heirship?

Not entirely. France applies forced heirship, the reserve hereditaire, which reserves a fixed share of the estate for your children whatever your will says. A UK owner can use an EU rule to choose English law for who inherits, but that choice does not remove French inheritance tax, and a recent French clawback right can still reach into a French property.

Source: service-public.fr, reserved heirs and disposable portion, as at August 2026, subject to change.

Under the EU Succession Regulation (often called Brussels IV), a British national can state in their will that the law of their nationality, such as the law of England and Wales, governs who inherits their estate. Done correctly, this can set aside French forced heirship so you can leave your French home as your English will directs. The UK did not adopt the Regulation, but the election can still apply to assets in France.

The election changes who inherits, not the tax. French inheritance tax at the rates above still applies to the French property, so choosing English law does not cut a 60% charge on an unmarried partner. Our guide to international and cross-border estate planning covers how a foreign asset also sits within your English will.

Do you pay UK inheritance tax on a French home as well?

Often, yes. If you are a long-term UK resident, your French property is inside your UK estate for inheritance tax at 40%, at the same time as French inheritance tax. A double taxation treaty between the two countries then prevents the property being taxed in full twice, usually by crediting the French tax against the UK bill on that asset.

Since 6 April 2025, UK inheritance tax on worldwide assets turns on residence, not domicile: being UK resident for at least 10 of the previous 20 tax years makes you a long-term resident, so your French home counts in your UK estate. It sits above the usual UK allowances, a £325,000 nil-rate band plus up to £175,000 of residence nil-rate band where a home passes to direct descendants, with 40% above them and all frozen until 5 April 2031 (gov.uk, Inheritance Tax rates and allowances, as at August 2026, subject to change).

The 1963 UK-France estate tax convention decides how the two charges meet. Immovable property, meaning land and buildings, is taxed first by the country where it sits, so France taxes your French house, and the UK then gives credit for the French tax paid against the UK inheritance tax on the same property (legislation.gov.uk, Double Taxation Relief (Estate Duty) (France) Order 1963, and gov.uk double taxation relief, as at August 2026, subject to change).

Relief is limited to the lower of the two taxes on the shared asset, so where French tax is high the UK charge can be reduced to nothing, but where it is low a UK top-up can remain. See our inheritance tax overview for how the UK bands are applied.

What UK owners get wrong about French inheritance tax

The common mistake is treating a Brussels IV election as a complete fix. Choosing English law can decide who inherits your French home, but it does not touch French inheritance tax, it does not switch off UK inheritance tax, and a 2021 French clawback right can still reach a French property. The full position has several parts that each need checking.

1. An English-law election changes who inherits, not the tax. French inheritance tax at up to 60% still applies to the French property, and UK inheritance tax may apply on top, so an election alone does not reduce a large bill for a distant or unrelated heir.
2. A French clawback right can undercut the election. Since a law of 24 August 2021 amended article 913 of the French Civil Code, a child left out by a foreign-law will can claim a compensating share (the droit de prelevement compensatoire) from assets in France where the foreign law gives children no protected share.
3. English wills may sit outside that clawback. French guidance issued in June 2026 indicated that English-law wills can be treated as offering equivalent child protection through family provision claims under the Inheritance (Provision for Family and Dependants) Act 1975, but this is recent and worth confirming for your own estate (Farrer & Co, June 2026).
4. A surviving unmarried partner is exposed. Without marriage or a PACS, a partner inheriting the French home pays 60% after a €1,594 allowance, and forced heirship may block the gift entirely, so partners often marry, enter a PACS, or restructure ownership.
5. Ownership structure is set when you buy, not at death. How the property is held, the wording used on purchase, and any marriage regime clause shape both who inherits and the tax, so the effective planning point is usually the purchase, not the will.

Because the outcome depends on your family, your marriage or PACS status, and how the property is held, French and UK advice usually need to be taken together. Our estate planning service can coordinate the UK side and work alongside a French notaire, and you can book a consultation to start.

Frequently asked questions

French inheritance tax applies to any French property owned by a UK resident, and is charged on each heir by relationship: 0% for a spouse or PACS partner, up to 60% for an unrelated one. The same home can also fall within UK inheritance tax, with a 1963 treaty crediting the French tax against the UK bill. These are the questions owners ask most often, answered for England and Wales as at August 2026.