Inheritance of a non-resident: assets located in France

When the deceased was not domiciled in France, France generally taxes assets located in France: real estate, tangible personal property, businesses operated in France, receivables from debtors domiciled in France, and shares in companies headquartered in France. If an heir has been domiciled in France for at least six of the ten preceding years, assets located outside France also become taxable for them. Tax treaties may alter this outcome.

This page lists the assets that France considers to be its own. It does not calculate inheritance tax: the sources consulted do not specify whether allowances and tax rates apply in the same way to a non-resident heir, and the rule depends on your individual circumstances, which should be verified before making a decision. It also does not cover life insurance or the content of country-by-country tax treaties.

The basic rule, on the deceased's side

The French tax authority (BOFiP) states that when "the donor, or the deceased, the donee, the heir, or the legatee does not have their tax residence in France," "gift tax is due only on movable and immovable property located in France" (BOI-ENR-DMTG-10-10-30, § 70, version of 12/09/2012). Tax residence is defined by Article 4 B of the French General Tax Code (CGI) and is assessed on the date of the taxable event, in this case, the death (§ 30). This version of the BOFiP bears the notation "in force from 12/09/2012 to the present"; it has not been compared with Article 750 ter of the current CGI.

One exception: an heir domiciled in France on the date of death and for at least six of the ten preceding years is liable for inheritance tax on all assets received (§ 20, 3°); according to § 390, these six years need not be continuous. The page "Non-resident heir: inheritance tax in France" provides further details on this point.

What properties are located in France?

Regarding the last line, this page does not state that these assets are located in France, nor that they are not: this point is verified in your file.

Foreign companies with a predominance of real estate

Securities of legal entities whose registered office is outside France, and which are not listed on the stock exchange, are subject to taxation when the value of real estate and real estate rights located in France represents "more than 50% of the value of the company's assets located in France" (paragraphs 110 to 140, as read; the basis for this ratio, compared to that of the proportion in paragraph 150, is verified in the text). Real estate used for the company's own operations is excluded from the threshold (paragraph 120). For persons not domiciled in France, these securities are subject to taxation "up to the proportion" (paragraph 150). The BOFiP (French Official Tax Bulletin) does not specify this proportion in the passages read: its methodology is verified in the text before any calculation.

The French building held indirectly

A French property is deemed to be indirectly owned when it belongs to a legal entity in which the deceased, alone or with their relatives, holds more than half of the shares, including through a chain of ownership, regardless of the number of intermediaries (§ 170 to 250). For the 50% threshold, the shares of the deceased's spouse, ascendants, descendants, and siblings, as well as those of the ascendants, descendants, and siblings of their spouse, are added to the deceased's shares. Only shares held personally by the deceased on the date of death are taxed; those held by their family are used solely to determine the threshold.

The trust

The assets or rights comprising a trust as defined in Article 792-0 bis of the French General Tax Code (CGI) are subject to this tax, as are the capitalized returns within the trust. The tax is due based on the beneficiary's tax residence in France, even if they are not an heir (BOFiP, § 300).

Tax treaties

The conventions allocate the right to tax based on the deceased's state of tax residence, regardless of that of the heirs (§ 420). Their definition of domicile takes precedence over that of domestic law (§ 430). The official list (BOI-ANNX-000306, in force since 29/04/2026) indicates "S" for inheritances: Germany, Spain, Switzerland, the United Kingdom, Italy, Portugal, and Belgium are included, but Luxembourg is not. The "Inheritance Conventions" page provides the complete list.

Declaring the estate of a deceased person domiciled abroad

• Deadline. Six months if the death occurred in metropolitan France, twelve months if it occurred abroad, and twenty-four months if ownership of real estate had not been established by a deed registered or published before the death (impots.gouv.fr). Specific time limits apply to Guadeloupe, Martinique, French Guiana, Réunion, and Mayotte: these can be verified on the impots.gouv.fr website.
• Form. The 2705-SD, "Declaration of Succession".
• Drop-off location. For a deceased person domiciled abroad, the declaration is sent by post to the Directorate of Non-Resident Taxes (Non-Resident Revenue Office, in Noisy-le-Grand).
• Exemption. The deposit is not mandatory if the gross assets are less than €50,000 for direct line heirs and the surviving spouse (without prior undeclared gifts), or €3,000 for other heirs.
• Notary. It is mandatory if real estate or real property rights are transferred.
• Payment. The tax must be paid when the return is filed. impots.gouv.fr also provides for payment in several equal installments over a maximum period of one year, extended to three years if the assets include at least 50 % of illiquid assets, subject to interest of 2 % for applications made since 01/01/2026. The payment pages do not mention non-residents.

Inheritance of a non-resident: numerical example (fictitious profile)

Situation. Henri, a fictional character, died in 2026, residing outside of France. He left behind an apartment in Paris worth €600,000, shares in a simplified joint-stock company headquartered in France worth €150,000, a debt of €300,000 owed by someone residing abroad, and a house abroad worth €250,000.

Hypotheses. Fictitious values. The company's shares are linked to France through its registered office (BOFiP, § 100). The debt and the house are located outside France according to the BOFiP (§ 160). No tax treaty applies. No tax is calculated.

Issue. What proportion of assets is included in the taxable base in France?

Strategy. The heirs take stock of Henri's residence on the day of his death, the list of his assets and their own residence, before filing the declaration.

Result.

Of the €1,300,000 in assets, €550,000 remains outside the taxable base for the daughter. This profile is hypothetical; the calculation illustrates the mechanism and does not predict your specific situation.

Inheritance of a non-resident: what changes depending on your case

• The deceased's residence on the day of death : he commands the whole thing.
• The home of each heir : an heir domiciled in France for six out of ten years changes the tax base for him.
• The nature of the goods : real estate, securities, receivables, accounts, foreign company or trust are not classified in the same way.
• Ownership by a company : the 50 % threshold and family ties count.
• The applicable convention : it can distribute the right to tax differently.
• Life insurance and bank accounts : not covered here.

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