Succession between France and Monaco: what the 1950 convention stipulates

Inheritance between France and Monaco is governed by a separate convention signed on April 1, 1950. For shares, equity interests, government bonds, and receivables, only one of the two states can levy the tax: the one where the deceased was domiciled. Domicile is defined as the location of the principal residence. A French citizen is considered domiciled in Monaco at the time of their death only if they had habitually resided there for at least five years, with some exceptions. Real estate is taxed where it is located.

This page presents Articles 1 (domicile), 2 (real estate), and 6 (securities and receivables) of the convention, the Monegasque tax scale, and the French rules of territoriality. It does not cover Articles 3 to 5, bank accounts, assurance-vie, debts, or income tax for Monegasque residents.

A separate text from the income convention

France's list of tax treaties places Monaco under a specific heading, "Tax treaty not primarily intended to avoid double taxation." The letter S, for inheritance tax treaties, appears alongside the treaty of April 1, 1950. This list is the version published in the BOFiP (Official Bulletin of Public Finances) on April 29, 2026, which includes the treaties in force on January 1, 2026.

The text of the convention is published by the French tax authorities.

The deceased's residence: Article 1

Article 1(c) defines domicile as the place where the deceased had their principal residence. It adds three rules specific to Monaco:

One point deserves careful consideration: the five-year requirement applies to individuals of French nationality and is calculated from the date of death. The case of a French citizen who does not meet this requirement is addressed in the full terms of the agreement and depends on their specific circumstances.

Securities, shares and receivables: Article 6

Article 6 concerns shares or equity interests, government bonds, unsecured or mortgage debt, to which Articles 2 to 5 do not apply. It distinguishes between two cases:

• The deceased was domiciled in one of the two states. These assets are subject to inheritance tax only in that State: "the said assets shall be subject to inheritance tax only in that State".
• The deceased was not domiciled in either state. These assets are subject to taxation only in the state of which he was a national. If he was a national of both states, "each specific case will be the subject of particular agreements between the French and Monegasque tax authorities."«

This is where the definition of domicile in Article 1 comes into play. It determines which state taxes the securities.

Buildings: Article 2

For the estate of a national of one of the two states, real estate and real estate rights are subject to inheritance tax only in the state where they are located. For an apartment located in Monaco, the convention stipulates that it is subject to inheritance tax only in that state, Monaco.

The Monegasque scale

The Monegasque government publishes a scale of inheritance tax based on the relationship between the heirs and the deceased. The page, updated on 30/07/2026, states that the tax "applies to assets located within the territory of the Principality.".

The page makes no mention of any reduction or exemption. Reading it does not allow us to conclude that none exist.

From the French side

The BOFiP (Official Bulletin of Public Finances) sets out the territorial rules for inheritance tax (BOI-ENR-DMTG-10-10-30, version posted on 12/09/2012). These rules apply subject to the following agreements:

• When the deceased is domiciled in France, all movable or immovable property transferred is subject to tax, whether located in France or outside France.
• When the deceased is not domiciled in France, the duties are due only for assets located in France.
• An heir domiciled in France on the date of the transfer, and who has had his tax domicile there for at least six years during the last ten years, is taxed on the assets received, located in France and outside France.
• When an agreement applies, the definition of the deceased's domicile or residence given by the agreement prevails.

The BOFiP dedicated to the Franco-Monegasque convention on income (BOI-INT-CVB-MCO-10) does not deal with inheritances.

France-Monaco succession: a numerical example (fictitious profile)

Situation. Marc, a French national residing in Lyon, owns an apartment in Monaco worth €1,000,000. He bequeaths it to his brother.

Issue. Two states could be involved: the state of his residence and the state where the apartment is located.

Strategy. Article 2 of the 1950 convention applies: real estate is subject to inheritance tax only in the state where it is located, in this case Monaco. The Monegasque rate for inheritances between siblings, 8 %, is then applied.

Result. 1,000,000 € × 8 % = 80,000 € of Monegasque duties, before any possible reduction which the Monegasque page does not mention.

This profile is fictitious. It does not apply to titles, which fall under Article 6.

Succession between France and Monaco: what changes depending on your situation

• The deceased's residence at the time of death, and for a Frenchman, the length of residence in Monaco.
• The nature of the goods : buildings (article 2), securities, shares and receivables (article 6), other assets (articles 3 to 5, not shown here).
• The nationality of the deceased, decisive when he was not domiciled in either of the two states.
• The family relationship, which sets the Monegasque rate.
• The situation of the heir in France, in particular six years of tax residence out of ten.

The rule depends on your situation. No results are guaranteed.