Inheritance agreements: which countries have an agreement with France

France's official list of tax treaties includes the letter S, for inheritance tax treaties, for 38 of the 128 states and territories it lists. In this list, the entries for Luxembourg, Cyprus, Singapore, and Thailand do not include this letter. It only indicates agreements in force as of January 1, 2026.

This page lists the 38 states and explains how to read them. It does not cover the content of each treaty: rates, domicile rules, covered goods. Nor does it state that a country without the letter S has no treaty with France.

Where does the list come from?

The list is maintained by the tax authorities in the BOFiP (Official Bulletin of Public Finances), appendix BOI-ANNX-000306, entitled "INT – List of tax treaties concluded by France". The version consulted on 18/10/2026 is in force since 29/04/2026.

Three clarifications from the page itself:

• It only lists agreements in force on January 1, 2026. It states: "Only agreements or conventions in force on January 1, 2026 are listed in this annex."«
• For agreements that are no longer in force, or that entered into force after this date, it refers to the Treaties and Agreements database of the Ministry for Europe and Foreign Affairs.
• The third column, "Taxes concerned and specificities", uses acronyms: D for gifts, DE for registration fees, IF for wealth tax, IR for income tax, S for inheritances.

The 38 states whose line bears the letter S

Of the 128 states and territories listed, 38 have the letter S in the column for taxes covered:

Monaco has a special presentation. The list places it under the heading "Tax Convention not primarily intended to avoid double taxation" and places the letter S next to the convention of April 1, 1950. See also our page on inheritance between France and Monaco.

Three States in this table have a note in the list: for Burkina Faso and Mali, the list indicates a suspension of the convention until December 31, 2024, followed by its denunciation from January 1, 2025; for Niger, a suspension from June 5, 2024. The letter S appears on their line, but this annotation requires checking with the source the status of these texts before any conclusion.

For several countries, the letter S is accompanied by other abbreviations in the same cell, for example, "IR – IF – S" for the United Arab Emirates. Reading the list does not allow us to determine, for these countries, whether the letter S designates a separate inheritance tax provision or a reference to the income tax treaty. The text of the treaty should be consulted on the tax authority's website before any agreement is reached.

Current states whose line does not bear the letter S

Here are a few lines from the list, without the letter S:

Paraguay does not appear on the list. In total, 90 states and territories on the list do not have the letter S.

This observation describes the list. It does not prove that no text exists. The list only includes agreements in force on January 1, 2026: a text signed since then, or a convention of another type, is not included. The tax page on international conventions (updated on October 2, 2026, according to the page's metadata) also presents, separately, texts that are "signed but not yet in force (pending ratification).".

What changes with the existence of an agreement

In domestic law, the BOFiP (Official Bulletin of Public Finances) points out that the rules governing the territoriality of inheritance and gift taxes "apply only subject to agreements concluded between France and various foreign countries." It adds that, when an agreement applies, the definition of the deceased's domicile or residence given in the agreement prevails.

Regarding gifts, the tax website states that France "has signed tax treaties with certain countries that may address gifts." This is the meaning of the letter D in the list, associated with S for several countries (Germany, Austria, Canada, Italy, Portugal, Sweden, Switzerland, and the United States, for example).

To know what a convention says, you have to read its text. The tax website maintains an alphabetical list of more than 100 states and territories with the original text and, sometimes, a consolidated version, including texts entitled "Successions - Gifts".

Inheritance and gift agreements: a numerical example (fictitious profile)

Situation. A fictional family owns property in five countries: Spain, Portugal, Luxembourg, Cyprus, and Thailand. They want to know where to find a succession law document related to France.

Issue. Without the list, there's no indication of where to begin. Five states, five readings of texts.

Strategy. We open the BOFiP list and, for each State, we note the column of taxes concerned. For those whose line bears the letter S, we read the text first; for the others, we check in the Treaties and Agreements database.

Result. Of the five states, two have the letter S (Spain and Portugal) and three do not (Luxembourg, Cyprus, Thailand). For the entire list, 38 out of 128 states have it, representing 29.7%, and 90 out of 128 do not, representing 70.3%.

This profile is fictitious. The count says nothing about the content of the agreements.

Inheritance and gift agreements: what changes depending on your situation

• The country where the assets are located, and that of the deceased's residence: the letter S is read State by State.
• The type of transmission : inheritance (S) or gift (D).
• The date of the texts : the list stops at agreements in force on January 1, 2026.
• States not included in the list or without the letter S : the rule depends on your situation, to be checked in the Treaties and Agreements database.
• The content of the convention : it can be read in his text and is not described here.

No results are promised.