Frenchie51

As we are soon to move to France will my UK will be valid there.We are a married couple with no children,but various assets. Thanks

EuroTrash

As French residents you will be subject to French succession laws and taxes. You should ask your notaire to explain the options and implications. A good notaire will raise these issues at the time of purchase, and will ensure that the purchase contract and your marriage regime are appropriate to your particular personal circumstances and will protect both of you. It's possible that the option of bequeathing your estate under the rules of your country of nationality will become available in the next few years - but French taxes will still apply; so for instance, anything that you leave to non relatives may be subject to 60 per cent inheritance tax.

dmu

Hi, Property and Inheritance Laws are different in France. From your other threads you already own your property and I'm quite surprised that the Notaire didn't advise you to make a French Will to cover that part of your assets at least, whatever your matrimonial régime and even if you weren't resident here at the time.
AFAIK your respective siblings (or their children) would inherit your French property equally between them if you haven't stated otherwise in a French Will. Bear in mind that if you name heirs who are unrelated to you, they will have to pay 60% of the value of the succession (they have the option to refuse the inheritance).
Consult the Notaire, who is best placed to advise!
P.S. Didn't see ET's post!

cyrian

Hi
You are a married couple with no children but are asking about a Will.
You must have other people that you want to leave your assets to.
These are the current rates of Inheritance Tax:
Order of succession and inheritance tax | Notaires de France
Forget what you understand about IHT in the UK, it is totally different in France.
In my experience, a French notaire will be able to advise you about French taxes but will have no experience of the interaction between the French system and the UK system.
Good luck

TheGrocer

The EU are about to change ALL the legislation in respect of wills and inheritance. This will mean UK wills will be legal and honoured in France. Of course if you are resident in France you will still (or your inheritors) have to honour tax obligations.

cyrian

Do you think that the French will pay any attention to EU legislation?
If they do then that would be a first.
The problem would arise if you had something set up under UK legislation which doesn't exist in your country of residence. e.g. France.
The advice I have been given is to have a French Will that refers to my UK Will stating that UK assets will be distributed according to the UK Will.
It will be interesting to see what transpires.

EuroTrash

One thing that will certainly transpire, if you're leaving things to non-relatives, is a lorra lorra tax.
I don't expect France will have any objection at all.

dmu

My former neighbour returned to the UK a few months ago and passed away last week. I can confirm what Cyrian says. Being the logical intermediary between the Notaire and her family in the UK, I learned that the Notaire deals with the French Property and assets in an "international" Succession, i.e. her children will pay French Inheritance Tax on her property and bank balances here, and an English solicitor will deal with any assets in the UK. She made life easier for all by writing an identical will in French and English, depositing the French version with her Notaire.
As advised, the OP's Notaire can draft a Will concerning their French Property, in everyone's best interests. Whatever future European Legislation rules, French taxes will be paid on French property and assets.