“Alexis, I've been transferred to Amsterdam. I thought everything was harmonised between two European Union countries. Now I'm told there is no treaty on inheritance. How is that possible?”
The Netherlands is home to 29,886 French nationals on the consular register as of 31 December 2025, a rise of +6.67% over one year — one of the fastest increases in Europe, driven by Amsterdam, Rotterdam and The Hague.
It is a destination where the tax question is badly framed, because people assume a European harmonisation that does not exist. The European Union coordinates social security and facilitates the free movement of capital; it harmonises neither income tax nor inheritance tax. The France–Netherlands treaty of 16 March 1973 deals with income and wealth. It says nothing about inheritance.
At Balmont Conseil, we take this observation as our starting point: what EU membership gives you, and what it does not.
1. Why seek expert wealth management in the Netherlands?
Three European advantages, and one blind spot.
- Social charges. A person covered by the Dutch scheme is exempt from CSG and CRDS on French-source investment income: 7.5% instead of 17.2%. It is the most immediate advantage, and the one most often left unclaimed.
- The exit tax. For a move to a Member State, the deferral of payment is automatic and requires no guarantee. The constraint comes down to reporting formalities.
- Free movement. Your European savings wrappers remain accessible, and a Luxembourg contract moves with you without interruption.
- The blind spot: estate transfer. No treaty allocates taxing rights on death between France and the Netherlands. It is the only real substantive issue for this destination.
2. The France ↔ Netherlands framework in five verified points
Here is the applicable framework, verified against official sources as of 15 September 2026. Lines three, four and five sum up the situation: two European advantages and one gap.
| French nationals on the register | 29,886 as of 31 December 2025 (+6.67% over one year). |
| Income tax treaty | Yes — treaty of 16 March 1973 (Official Journal of 21 April 1974), amended by the protocol of 7 April 2004. It covers income and wealth. Private pensions taxable in the state of residence (Article 18), public pensions in the paying state (Article 19). Dividends: 5% or 15%. Interest: 10%. |
| Estate tax treaty | None. Despite their shared membership in the European Union, no convention governs inheritances or gifts between France and the Netherlands. |
| Exit tax — deferral of payment | Automatic deferral of payment, no guarantee required. The Netherlands is an EU Member State and shares with France the full set of exchange-of-information and collection-assistance clauses. |
| CSG and CRDS on property income and capital gains | 7.5% only. A person covered by a Dutch compulsory scheme is exempt from CSG and CRDS; only the solidarity levy remains due. Boxes 8SH or 8SI of form 2042 C. |
The European Union does not harmonise inheritance tax. This is the most widespread misunderstanding among European expatriates. France has concluded an estate tax treaty with only eight of the twenty-seven Member States : Germany, Austria, Belgium, Spain, Finland, Italy, Portugal and Sweden. The Netherlands is not one of them — nor are Ireland, Greece, Cyprus or Luxembourg.
Practical consequence. Article 750 ter of the French Tax Code applies with no treaty relief. 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, wherever those assets are. Only Article 784 A of the French Tax Code allows tax paid outside France to be offset, and only up to the French duties relating to the assets located outside France.
Conversely, the social charges advantage is immediate and quantifiable. On property income of €25,000, the difference between 17.2% and 7.5% amounts to €2,425 a year. You still need to tick the boxes and keep proof of affiliation.
3. Our services: 360° support for expatriates and investors
Three workstreams, one of which is a priority.
Addressing the inheritance blind spot
We establish each heir's position under Article 750 ter of the French Tax Code, then calculate the resulting French tax burden on your actual assets, Dutch assets included.
We then examine the available levers: gift schedule, choice of vehicles, structuring of ownership, and articulation with Dutch inheritance law — the latter point with qualified advice on site.
- Position of each heir under 3° of Article 750 ter.
- Calculation of the French tax burden, with and without the Article 784 A credit.
- Corrective levers and timetable.
Activation of the CSG and CRDS exemption
We check that your Dutch affiliation does give entitlement to the exemption, that boxes 8SH or 8SI are completed and that the proof is up to date. Where relevant, we examine a claim for the years not yet time-barred.
It is a profitable step, and an often overlooked one, in a common European case. It is not triggered automatically.
Managing your French assets and the portability of your wrappers
Your French assets continue to be taxed in France: property income at the non-resident minimum rate under Article 197 A of the French Tax Code, with the option for the average rate when more favourable, and the IFI (real estate wealth tax). We handle this follow-up.
On the wrappers, we examine what to keep and what to reallocate. The Luxembourg assurance-vie contract fits in naturally here: it falls under the European freedom to provide services and follows a policyholder who changes Member State without any break in the framework.
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 — Netherlands
How can there be no estate tax treaty between two EU countries?
Because direct taxation, and in particular gift and inheritance tax, remains a national competence. The Union coordinates social security and guarantees the free movement of capital, but it does not harmonise inheritance tax.
Estate tax treaties are therefore bilateral, and France has concluded them with only a minority of Member States. The Netherlands is not one of them.
What is the concrete risk for my children who stayed in France?
If one of them is domiciled in France on the day of the transfer and has been for at least six of the last ten years, France taxes all the assets they receive, including those located in the Netherlands.
Article 784 A of the French Tax Code allows the Dutch tax paid to be offset, but only up to the French duties relating to the assets located outside France. The double charge is capped, not removed. The calculation is done heir by heir.
How do I obtain the CSG exemption on my French rental income?
It requires affiliation to a Dutch compulsory social security scheme, and an active step: ticking boxes 8SH or 8SI of form 2042 C, and being able to produce proof of affiliation.
Your French-source property income and property capital gains then bear only the 7.5% solidarity levy, instead of 17.2%.
Does the exit tax apply to me?
The thresholds of Article 167 bis of the French Tax Code apply regardless of the host country. But for a move to an EU Member State, the deferral of payment is automatic and requires no guarantee.
Reporting obligations and follow-up until the tax is discharged remain, and we take care of them.
What happens to my French assurance-vie policy?
It can be kept. Its tax treatment in the Netherlands is a matter of Dutch law and should be checked with a licensed adviser on site — we do not state it in their place.
What we can say is that the structure of a Luxembourg contract is better suited to lasting European mobility, and that the decision to switch is easier to make before departure than after.
In summary
The Netherlands offers the usual European advantages — CSG exemption, automatic exit tax deferral, free movement of savings wrappers — and one gap that always surprises: the absence of an estate tax treaty.
It is therefore an easy destination for income flows, and a demanding one for estate transfer. The useful work lies in the second point.
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 check your CSG exemption and gauge your heirs' inheritance tax exposure. You can also start with a free contract X-ray.
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