«"Alexis, I've been transferred to Amsterdam. I thought that between two European Union countries everything was harmonized. Now I'm being told that there's no convention on inheritance. How is that possible?"»
The Netherlands hosts 29,886 French citizens registered with the consular register as of December 31, 2025, an increase of +6.67 % over one year — one of the fastest growth rates in Europe, driven by Amsterdam, Rotterdam and The Hague.
This is a destination where the tax question is poorly framed, because it assumes a European harmonization that does not exist. The European Union coordinates social security and facilitates the free movement of capital; it does not harmonize neither income tax nor inheritance tax. The Franco-Dutch convention of March 16, 1973 deals with income and wealth. It says nothing about inheritance.
At the house of Balmont Conseil, We take this observation as our starting point: what is acquired through membership of the Union, and what is not.
1. Why seek expertise in wealth management in the Netherlands?
Three European advantages, and one blind spot.
- Social security contributions. A person affiliated with the Dutch social security system is exempt from CSG and CRDS taxes on their French-source capital income: 7.5% instead of 17.2%. This is the most immediate benefit, and the most often unclaimed.
- The exit tax. For departures to a Member State, the deferral of payment is automatic and without guarantee. The only requirement is a declaration formality.
- Free movement. Your European savings accounts remain accessible and a Luxembourg contract can be transferred there without interruption.
- The blind spot: transmission. No agreement allocates the right to tax inheritances between France and the Netherlands. This is the only real substantive issue concerning this destination.
2. The France ↔ Netherlands framework in five verified points
Here is the applicable framework, verified in official sources as of September 15, 2026. Lines three, four and five summarize the situation well: two European advantages and one gap.
| French registered in the register | 29,886 as of December 31, 2025 (+6.67 % over one year). |
| Income Convention | Yes — Convention of 16 March 1973 (Official Journal of 21 April 1974), amended by the addendum of 7 April 2004. It covers income and capital. Private pensions are taxable in the State of residence (Article 18), public pensions in the paying State (Article 19). Dividends: 5 % or 15 %. Interest: 10 %. |
| Convention on Successions | None. Despite their shared membership in the European Union, no convention governs inheritances or donations between France and the Netherlands. |
| Exit tax — deferral of payment | Automatic payment deferral, without guarantee. The Netherlands is a member state of the Union and has with France all the clauses for the exchange of information and assistance in recovery. |
| CSG and CRDS on capital income | 7.5 % only. A person affiliated with a Dutch compulsory social security scheme is exempt from CSG and CRDS contributions; only the solidarity levy remains due. See boxes 8SH or 8SI of form 2042 C. |
The European Union does not harmonize inheritance taxes. This is the most common misconception among European expatriates. France only has an inheritance treaty with eight out of twenty-seven member states Germany, Austria, Belgium, Spain, Finland, Italy, Portugal and Sweden. The Netherlands are not part of it — nor are Ireland, Greece, Cyprus or Luxembourg.
Practical consequence. Article 750 ter of the French General Tax Code applies without any treaty adjustment. Paragraph 3 makes all assets received by an heir domiciled in France for at least six of the last ten years taxable in France, regardless of where those assets are located. Only Article 784 A of the French General Tax Code allows for the crediting of tax paid outside France, and only up to the limit of the French tax due on the assets located outside France.
Conversely, the social benefit is immediate and quantifiable. On rental income of €25,000, the difference between 17.2 % and 7.5 % represents €2,425 per year. However, this requires checking the boxes and keeping proof of affiliation.
3. Our services: 360° support for expatriates and investors
Three projects, one of which is a priority.
Addressing the inheritance blind spot
We establish the situation of each heir with regard to article 750 ter of the general tax code, then we calculate the resulting French tax burden on your actual assets, including Dutch assets.
We then examine the available levers: donation schedule, choice of vehicles, structuring of ownership, and articulation with Dutch inheritance law — the latter point with qualified advice on site.
- Situation of each heir with regard to point 3 of article 750 ter.
- Calculation of the French charge, with and without imputation of article 784 A.
- Correction levers and timeline.
Activation of the CSG and CRDS exemption
We verify that your Dutch affiliation entitles you to the exemption, that boxes 8SH or 8SI are completed, and that the supporting document is up to date. If necessary, we will review a claim for the years not yet time-barred.
This is the most cost-effective action in a typical European case. It doesn't happen on its own.
Management of French heritage and portability of funds
Your French assets continue to be taxed in France: rental income at the minimum rate for non-residents under Article 197 A of the French General Tax Code (CGI), with the option to choose the average rate when more advantageous, and wealth tax on real estate. We are monitoring this.
Regarding the envelopes, we examine what is preserved and what is subject to arbitration. The Luxembourg life insurance contract fits in here naturally: it falls under the European free provision of services and supports a subscriber who changes Member State without breaking the framework.
4. Methodology: our way of working
We work in four stages, and you know where you are at each stage.
- The initial assessment. We assess your actual situation: composition of assets, project timeline, situation of each member of the household, and tax domicile of your heirs — because it is theirs that dictates, not yours.
- The applicable reference framework. We establish, source by source and with its date, the framework that concerns you. What we do not know, we write "to be confirmed" — never anything else.
- The arbitrations. We present you with the numerical options, along with their respective consequences, and you decide. Heritage engineering comes after the decision, not before.
- The follow-up. An annual review, offered free of charge, which verifies that the framework has not changed — the conventions are modified, the attractiveness schemes are eliminated, the thresholds change.
5. What the firm offers you
This is what specifically distinguishes our intervention.
- Sources, not claims. Each item in your file has its reference number and date. You can check. This is the only way to work on a subject where most of the information available online is outdated.
- A single point of contact in France. We coordinate with your local advisors, we do not replace them: the internal tax regulations of the host country are handled by a qualified professional on site. Our role is to maintain overall consistency and to defend the French side of the case.
- Fees that are easy to understand. Firm fees: €500 including VAT per hour. Annual follow-up is included. No hidden kickbacks, no performance-based billing.
Frequently Asked Questions in the Netherlands
How can there not be a succession agreement between two countries of the Union?
Because direct taxation, and particularly inheritance and gift taxes, remains a national competence. The Union coordinates social security and guarantees the free movement of capital, but it does not harmonize inheritance taxes.
Inheritance agreements are therefore bilateral, and France has concluded them with only a minority of member states. The Netherlands is not among them.
What is the actual risk to my children who remained 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 he receives, including those located in the Netherlands.
Article 784 A of the French General Tax Code allows for the deduction of Dutch tax paid, but only up to the limit of French tax due on assets located outside France. This deduction is capped, but not eliminated. The calculation is performed on an heir-by-heir basis.
How can I obtain CSG exemption on my French rental income?
It requires affiliation to a compulsory Dutch social security scheme, and an active step: ticking boxes 8SH or 8SI of the 2042 C declaration, and being able to produce proof of affiliation.
Your French-source property income and capital gains are then subject only to the solidarity levy of 7.5 %, instead of 17.2 %.
Does the exit tax apply to me?
The thresholds in Article 167 bis of the French General Tax Code are assessed independently of the host country. However, for departures to a Member State of the European Union, the deferral of payment is automatic and without guarantee.
There are still reporting obligations and follow-up until the tax relief is granted, which we take care of.
What happens to my French life insurance policy?
It can be kept. Its taxation in the Netherlands falls under Dutch law and should be verified with a qualified advisor on site — we are not making this assertion on their behalf.
What we can say is that the structure of a Luxembourg contract is better suited to sustainable European mobility, and that arbitration is more easily decided before departure than after.
In summary
The Netherlands offers the usual European advantages — exemption from CSG, automatic deferral of exit tax, free movement of envelopes — and one shortcoming that always surprises: the absence of an inheritance convention.
It is therefore an easy destination in terms of data flows, but demanding in terms of transmission. The useful work focuses on the second point.
Firm's fees: €500 including VAT per hour. Annual follow-up is offered.
Let's review your situation
A thirty-minute exchange is all it takes to verify your CSG exemption and assess the inheritance tax implications for your heirs. You can also start with a Free X-ray of your contracts.
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