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British expats relocating to France often assume UK testamentary freedom continues unchanged. Under UK principles, individuals can usually distribute their estate freely through a will.
French succession law operates differently. It includes forced heirship provisions that reserve part of the estate for protected heirs, typically children.
Even where UK law is elected under EU succession rules, this affects legal distribution—not necessarily taxation. French succession tax and UK inheritance tax (IHT) may both apply depending on residence history and asset location.
Cross-border estates require coordinated planning. Reviewing wills, ownership structures and residence exposure before relocation reduces the risk of unintended outcomes.
Under UK law, individuals generally enjoy testamentary freedom.
This means you can usually decide how your estate is distributed through your will.
French succession law operates differently.
In many cases, it includes forced heirship provisions requiring a defined portion of the estate to pass to certain heirs, typically children.
British expats relocating to France often assume their existing UK will continues to operate unchanged.
In practice, the interaction is more complex.
French law protects certain heirs through reserved portions of the estate.
For example:
These rules can override testamentary intentions unless structured carefully.
Forced heirship operates independently from tax.
It governs legal distribution.
Succession law determines who inherits. Succession tax determines how much tax applies.
Under UK principles, individuals can generally leave assets to:
This flexibility contrasts with French forced heirship.
Where a British expat becomes resident in France, or where assets are located in France, French succession rules may apply depending on circumstances.
Under EU succession regulations, individuals may in some cases elect for the law of their nationality to govern succession.
For British nationals residing in France, this may allow election of UK law to apply to the estate.
However:
Choice of law requires deliberate planning rather than assumption.
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Succession outcomes depend on multiple factors:
French property may trigger French succession rules.
UK property may remain subject to UK law.
Cross-border estates require coordinated analysis.
France imposes succession tax based on:
Rates can be progressive and differ from UK inheritance tax rates.
Unlike the UK, where spousal transfers are generally exempt, French rules operate differently depending on relationship and residence.
Tax exposure and legal distribution must be reviewed separately.
Short-term absence from the UK does not automatically remove UK IHT exposure.
Residence history and legislative thresholds may still bring worldwide assets into UK scope.
It is therefore possible for:
Coordination between systems is essential.
Cross-border estates can face overlapping legal and tax frameworks if not structured deliberately.
British expats often assume:
These assumptions can create structural conflict.
Succession law and tax must be analysed together.
Before or shortly after relocating to France, review should include:
Estate planning must reflect current and potential future residence.
Estate planning is often postponed during relocation because:
However, forced heirship rules apply automatically.
Planning while healthy and mobile is more effective than reacting later.
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Once death occurs:
Correcting misalignment after the event is impossible.
Sequencing before relocation preserves clarity.
French succession law differs materially from UK inheritance assumptions.
Forced heirship provisions may override testamentary freedom unless structured properly.
Residence and asset location influence which rules apply.
Succession law and succession tax are separate but overlapping frameworks.
British expats relocating to France should review:
Relocation changes not only tax exposure, but legal inheritance rights.
Early coordination protects family outcomes.
Shil Shah is Skybound Wealth’s Group Head of Tax Planning and a Private Wealth Adviser, based in London. He works with clients who live global lives, executives, entrepreneurs, families and professionals who want clear, confident guidance on their wealth, their tax position and the decisions that shape their future.
This article is provided for general informational purposes only and does not constitute legal, tax or financial advice. Succession outcomes depend on residence status, asset location, legislation in force and individual circumstances. Professional advice should be sought before acting.
A review can help you:
Relocation affects both legal inheritance rights and tax exposure. A structured review can help you:
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A structured review can align your will and estate structure with French succession rules.
In a focused session, we can:
Estate clarity reduces family uncertainty later.
