France has concluded with a number of countries conventions for the avoidance of double taxation with respect to inheritance.

The provisions for avoiding such double taxation are found either in a general convention alongside the provisions relating to income taxes (this is the case in particular for the older conventions concluded with African countries, which also cover other registration duties and stamp duties), or in specific conventions, some of which also deal with gift duties.

Like those relating to income taxes, inheritance conventions allocate taxing rights between States and contain provisions to eliminate double taxation where both States have concurrent taxing rights.

The State entitled to tax may be either the State where the property is located, for assets such as real estate or tangible movable property, or the State of residence for intangible movable property not attributable to a permanent establishment or a fixed base.
Double taxation is eliminated by means of the general techniques of exemption or credit.

French practice tends to favour the exemption method, possibly combined with the effective rate.
The same conventions generally specify the rules governing the allocation of debts between the States, drawing more or less closely on the 1982 OECD Model Convention on estate, inheritance and gift taxes (Art. 8).

Conventions concerning successions, gifts, registration duties and stamp duties are indicated in the table.

Conventions are often difficult to read; consult our tax law firm for their application to your specific situation.

This table lists the countries that have concluded with France a tax treaty for the avoidance of double taxation.

Our tax law firm can assist you.