“Alexis, we've been living in Melbourne for two years and we're thinking of staying. My parents are getting older in France. What will happen, tax-wise, on the day I inherit from Australia?”
Australia is home to 27,614 French nationals on the consular register as of 31 December 2025, a rise of +7.63% in one year : the strongest growth in our panel after the Emirates. Sydney, Melbourne, Brisbane and Perth account for most of this community.
It is a destination where the treaty framework is both modern and incomplete. The income tax treaty, signed on 20 June 2006, is recent and well constructed. But there is neither an estate tax treaty nor a bilateral social security agreement between France and Australia — a rare combination of gaps, with heavy practical consequences.
At Balmont Conseil, we treat Australia as a long-distance file: trips back and forth are costly, lead times long, and wealth decisions must hold for several years without adjustment.
1. Why seek expert wealth management in Australia?
Four issues, two of which stem from gaps.
- No estate tax treaty. Nothing allocates taxing rights on death between France and Australia, and nothing provides a treaty credit.
- No social security agreement. France has concluded such agreements with around forty countries; Australia is not among them. This has consequences for your pension rights as well as your social security contributions.
- A recent and favourable income tax treaty. The treaty of 20 June 2006 notably provides for an exemption from withholding tax on certain dividends and a rate capped at 10% on interest, with several exemptions.
- An Australian death tax in all but name. Australia does not levy inheritance tax, but its capital gains tax includes mechanisms specific to transfers on death, some of which are triggered specifically when the beneficiary is not resident. This point should be checked with a licensed adviser in Australia.
2. The France ↔ Australia framework in five verified points
Here is the applicable framework, checked against official sources as of 15 September 2026. It is one of the rare destinations where three lines out of five are unfavourable.
| French nationals on the register | 27,614 as of 31 December 2025 (+7.63% in one year), one of the strongest increases in the panel. |
| Income tax treaty | Yes — treaty of 20 June 2006 (Official Journal of 21 June 2009). Pensions and annuities taxable in the state of residence (Article 17), with reciprocal exemption for war and veterans' pensions. Interest capped at 10% (Article 11), with exemptions for public loans and certain financial institutions. |
| Estate tax treaty | None. In the list of treaties concluded by France, Australia appears only for income tax. |
| Exit tax — deferral of payment | Automatic deferral of payment. This is the good news in this file: Australia has exchange-of-information and collection-assistance clauses with France covering all the taxes concerned. |
| CSG and CRDS on property income and capital gains | 17.2%. The CSG and CRDS exemption applies to members of a scheme in the European Economic Area, Switzerland or the United Kingdom. Furthermore, there is none — no bilateral social security agreement between France and Australia. |
The absence of a social security agreement is a verified fact, not a supposition. The official list of bilateral social security agreements in force, published by the Centre for European and International Social Security Liaison, includes around forty countries. Australia is not on this list. This affects the coordination of your pension rights as well as your contributions.
The absence of an estate tax treaty makes Article 750 ter of the French Tax Code directly applicable. Its paragraph 3 makes taxable in France all assets received by an heir domiciled in France for at least six of the last ten years. Conversely, if you inherit from Australia from parents domiciled in France, France taxes the deceased's worldwide estate under paragraph 1 of the same article.
The automatic exit tax deferral is the favourable element. Unlike Canada, Israel or Andorra, a move to Australia requires neither guarantees nor a tax representative. This is an important cash-flow point for a significant securities portfolio.
3. Our services: 360° support for expatriates and investors
Three workstreams, calibrated for distance.
Modelling the estate transfer in both directions
A Franco-Australian file raises the question of transfer in both directions: what you will pass on from Australia, and what you will receive from France. Article 750 ter of the French Tax Code deals with both cases, in different paragraphs.
We model both scenarios, with and without the offset under Article 784 A of the French Tax Code, to arrive at the real net cost. It is the only way to know whether the situation calls for corrective steps.
- Scenario “I pass on assets from Australia”: effect of paragraph 3 of Article 750 ter on each heir.
- Scenario “I inherit from Australia”: effect of paragraph 1 on the deceased's worldwide estate.
- Limits of the offset provided for by Article 784 A of the French Tax Code.
Coordination of pension rights
In the absence of a bilateral social security agreement, your periods of work in France and Australia are not automatically aggregated. This does not mean your French rights are lost, but that they are paid out separately, under their own rules.
We establish the status of your rights accrued in France, how they will be paid out from abroad, and any choices to be made — buying back quarters, choosing the date of retirement, tax effects of the payments.
Remote management of French wealth
The time difference and the distance make day-to-day monitoring difficult. We handle the French filing calendar, the taxation of property income at the minimum non-resident rate under Article 197 A of the French Tax Code — with the option for the average rate when it is more favourable — and the real estate wealth tax.
On savings wrappers, we examine what to keep and what to switch. A Luxembourg assurance-vie contract offers the advantage here of a stable framework, whatever your country of residence, which matters when adjustments are costly to make.
The Australian tax treatment of a French contract is a matter of Australian law: it should be checked with a licensed professional locally, and we help you put the question to them in the right terms.
4. Methodology: our way of working
We work in four stages, and at each stage you know where you stand.
- The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
- The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
- The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
- Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.
5. What the firm offers you
What concretely sets our work apart.
- Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
- A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
- Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.
Frequently asked questions — Australia
Are there inheritance taxes in Australia?
Australia does not levy gift or inheritance tax. This does not mean death is tax-neutral: the Australian system deals with transfers through its capital gains tax, with specific rules depending on the beneficiary's status.
These rules belong to Australian domestic law and should be checked with a licensed local adviser. We will not state them in their place — but we know these questions must be asked, and we ask them systematically.
If I inherit from my parents who remained in France, what happens?
If the deceased was domiciled in France, paragraph 1 of Article 750 ter of the French Tax Code makes all their assets, in France and abroad, taxable in France, whatever your own residence.
Your relocation to Australia does not exempt you from French inheritance tax on this estate. In the absence of a treaty, no treaty mechanism exists to remedy this outcome.
Do my French contribution quarters count towards my Australian pension?
No. There is no bilateral social security agreement between France and Australia, unlike the forty or so countries with which France has such agreements. The periods are not cumulative.
Your French pension rights remain valid and will be settled according to French rules, regardless of your Australian career. We will determine their status and settlement options.
Will the exit tax cause me a cash flow problem?
No — on this point Australia is well placed. It has the two required clauses with France — exchange of information and collection assistance — which opens automatic deferral of payment, with no guarantee or tax representative.
What remains are the reporting obligations and the annual monitoring until the tax relief is granted, which we take care of.
Will I pay CSG on my French rental income from Australia?
Yes, at the full rate of 17.2%. The CSG and CRDS exemption is reserved for people affiliated to a compulsory scheme of a European Economic Area state, Switzerland or the United Kingdom.
Australia falls under none of these cases, and no bilateral agreement makes up for it.
In summary
Australia combines a modern income tax treaty, an automatic exit tax deferral, and two notable gaps: no estate tax treaty, no social security agreement.
The useful work therefore focuses on the estate transfer — in both directions — and on coordinating pension rights. Both take a long time to prepare, which is just as well: the distance makes late corrections difficult.
Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.
Let's review your situation
A thirty-minute conversation is enough to gauge your inheritance tax exposure and the status of your pension rights. You can also start with a free contract X-ray.
Other destinations
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