Moving from the United Kingdom to France does not automatically end every UK inheritance-tax connection. Since 6 April 2025, the United Kingdom has used a long-term UK residence test for many foreign assets, while France applies its own rules based on the deceased’s and beneficiary’s tax residence, the location of assets and the France–UK inheritance-tax convention. A family can therefore face two assessments even where the deceased had lived in France for years.

The practical question is not simply “am I resident in France?” It is: which country may tax which asset, under which domestic rule, and how will the tax already paid in one country be credited or reclaimed in the other? The answer depends on the date of death, the UK residence history, the French tax domicile, the beneficiary’s residence, the situs of each asset, the deceased’s treaty domicile and the paperwork filed on time.

This guide focuses on the UK 10-year tail after departure, French succession tax (the French tax on gratuitous transfers, called droits de mutation à titre gratuit), the 1963 convention and a workable double-tax relief process. It does not replace advice on a particular estate: a will, trust, lifetime gift, company, pension, property or debt can change the analysis.

I. How does UK inheritance tax work after moving to France?

A. What does the 10-year long-term UK residence rule actually measure?

The first distinction is between a domestic UK connection and a treaty connection. The United Kingdom changed its domestic framework from 6 April 2025. HM Revenue & Customs states that “From 6 April 2025, the domicile and deemed domicile rules were replaced by new long-term UK residence rules.” The starting point for a British citizen who has moved to France is therefore the tax-residence history, not the passport and not the address written on the death certificate.

Under the current UK framework, a person is generally a long-term UK resident if they were UK tax resident for at least 10 of the 20 tax years immediately before the relevant year. The official guidance on inheritance tax for a long-term UK resident explains the change and the treatment of assets outside the United Kingdom. It also states that a person leaving the UK can retain a long-term UK residence connection for a period after departure. The length of that tail depends on the number of UK-resident years in the preceding 20-year period.

For a simplified planning illustration, the post-departure tail is usually read as follows:

UK-resident years in the preceding 20 years	Indicative tail after leaving the UK	Why it matters
10 to 13 years	3 tax years	Foreign assets can remain within the UK domestic inheritance-tax net during the tail.
14 years	4 tax years	The date of death must be tested against the remaining tail.
15 years	5 tax years	A move to France does not immediately remove the UK exposure.
16 years	6 tax years	The evidence of each UK tax year becomes important.
17 years	7 tax years	The tail can outlast a French residence permit or tax-registration date.
18 years	8 tax years	Foreign investments and accounts need a UK review.
19 years	9 tax years	The transition can remain relevant for almost a decade.
20 years	10 tax years	The maximum post-departure period is potentially engaged.

This is a working framework, not a substitute for a year-by-year residence schedule. HMRC’s Inheritance Tax Manual guidance on long-term residence matters because it addresses how residence years are counted. In particular, split-year treatment can count as a complete UK-resident year for this purpose. Someone who left during a tax year cannot assume that a part-year automatically disappears from the calculation.

The relevant history should be reconstructed from documents rather than memory. Gather self-assessment returns, P60s, P45s, employment records, tenancy or property records, travel calendars, HMRC correspondence and any evidence used to establish split-year treatment. If the move occurred near 6 April, the residence count can change even though the French move took place only a few days apart. A death shortly after the move can therefore produce a different UK result from a death several years later.

The UK domestic question is also separate from the question of what the France–UK convention calls the deceased’s domicile. The HMRC manual explains that the France convention is a pre-1975 agreement and that its domicile wording has a particular common-law meaning. The relevant HMRC guidance on the France convention says that the convention applies to inheritance tax on death and does not simply convert the modern domestic 10-year test into the treaty test. This is a critical safeguard: a person may be a long-term UK resident for UK domestic purposes while the treaty analysis still requires a separate examination of domicile, permanent home, family life and the other facts recognised under the convention.

The question should be recorded in two columns:

• UK domestic column: UK tax-resident years, the 10-out-of-20 test, the departure tail, the status of foreign assets and any relevant reliefs.
• Treaty column: the deceased’s domicile for the 1963 convention, the situs of each asset, the country with the primary taxing right and the credit mechanism.

That two-column method prevents a common error: treating a French tax residence certificate as proof that no UK inheritance tax can arise, or treating the UK 10-year rule as proof that France has no taxing right. Neither conclusion follows automatically.

There are also timing issues around gifts and transfers during life. The 1963 convention is designed around taxes due on death. HMRC’s manual guidance on the convention’s scope states: “The provisions of the Convention only cover UK Inheritance Tax (IHT) that is due on death.” A potentially exempt transfer, a chargeable lifetime transfer, a trust contribution or a gift with reservation of benefit may require a separate UK and French analysis. Do not assume that a credit available on death automatically resolves tax charged on a lifetime transaction.

The practical result is that a British person moving to France should obtain a dated inheritance-tax review at the time of departure, after the first French tax return, when acquiring or selling a major asset, when creating a trust or SCI, and whenever the family structure changes. An annual review is particularly sensible while the UK tail remains open.

B. Which assets and beneficiaries can remain exposed in both countries?

France starts from its own statutory connecting factors. French inheritance tax is part of the droits de mutation à titre gratuit system. Article 750 ter of the French General Tax Code begins with the words “Sont soumis aux droits de mutation à titre gratuit” and then sets out three important situations.

First, where the deceased or donor is fiscally domiciled in France, France can generally look at assets wherever they are situated, subject to an applicable treaty. Secondly, where the deceased or donor is not fiscally domiciled in France, France can generally tax assets situated in France. Thirdly, where the beneficiary is fiscally domiciled in France and has been so domiciled for at least six of the previous 10 years, France can in principle tax assets received from anywhere in the world, again subject to a treaty.

The phrase “French tax domicile” means domicile fiscal. Article 4 B of the French General Tax Code identifies factors such as the household or principal place of stay, professional activity and centre of economic interests. Those domestic criteria must be read with the applicable tax convention. A French tax return, a residence card, a French home and a French bank account are evidence; none is a universal answer to every succession question.

The six-out-of-10 beneficiary test is easy to overlook. For example, a British parent living in Manchester may leave a portfolio to an adult child who moved to France eight years ago. Even if the parent was not French tax resident, the child’s French residence history can bring worldwide inherited assets into the French domestic analysis. The convention and asset situs rules may then limit or reallocate the result, but the French filing question should not be ignored.

The reverse case also occurs. A British person who has lived in France for only two years may die owning a French house, a UK investment portfolio and a British pension. The French domestic rule can still reach the French-situs house, while the UK domestic long-term residence rules may reach the foreign portfolio if the departure tail is active. The treaty then becomes the mechanism for deciding where each category is taxed and how relief is given.

The estate must be mapped asset by asset. Typical categories include:

• French real estate: a house or apartment in France is normally connected with France by its physical location. The valuation should reflect the open-market value at the date of death, together with secured debt and ownership structure.
• UK land and buildings: UK property remains a UK-situs asset. A French tax residence does not turn it into French property, although France may also have a claim under its domestic residence rules.
• Bank and investment accounts: the account provider, debtor, company and legal nature of the instrument matter. The statement alone may not identify the treaty situs.
• Shares: the convention can use the place where the company is incorporated, but special rules may apply to entities, property-rich companies and anti-avoidance provisions.
• Pensions and life insurance: classification, ownership, nomination, surrender value and the death benefit must be checked. A pension article or a lifetime income rule is not automatically an inheritance-tax answer.
• Trusts: the French treatment of trusts has its own reporting and tax provisions. Article 792-0 bis of the [French General Tax Code](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000037526690/2026-05-13) should be checked where a trust is involved.
• Debts and expenses: a debt may be deductible in one country, both countries or neither, depending on its connection and the statutory limits. Obtain the loan agreement, repayment statement and proof of the debt at death.

French allowances and rates are not the same as the UK nil-rate band. For a direct-line gift or inheritance, Article 779 of the French General Tax Code contains the principal parent-to-child allowance. Article 777 of the same Code sets out the progressive direct-line rates, which range through 5%, 10%, 15%, 20%, 30%, 40% and 45% brackets. The relationship, prior gifts, disability allowances, grandchildren, siblings and unrelated beneficiaries can produce very different results.

The official Service-Public overview of evaluating an estate and calculating inheritance tax is useful for checking the French sequence: identify the gross estate, deduct permitted debts, apply the family relationship and then calculate the duty. It is a general guide, so a UK asset, treaty credit or trust still needs the cross-border analysis set out below.

The surviving spouse or civil-partnership partner must also be separated from the children in the calculation. Article 796-0 bis of the French General Tax Code provides an exemption for the surviving spouse and the surviving partner of a French civil solidarity pact, known as a PACS. The exemption does not mean that the estate has no declaration or valuation obligations, and it does not make every transfer to an unmarried partner tax-free in every country.

French reserved-heir rules are a separate succession-law question. Article 912 of the French Civil Code describes the reserved portion of an estate protected for qualifying reserved heirs when they accept the succession. Whether French succession law applies, whether a valid choice of law was made, and whether a will is effective are separate from the tax calculation. A British will can be relevant to the distribution of assets while the tax computation still follows French, UK and treaty rules.

Consider a worked example. James left the UK in September 2026 after 15 UK-resident years in the previous 20. He becomes French tax resident, owns a French home worth €650,000, UK investments worth £500,000 and a small UK rental property. If he dies during the five-year UK tail, the UK domestic analysis may include the foreign assets. France may also tax the French home because it is French-situs property and may examine all assets if James was French tax domiciled. The outcome cannot be calculated from his nationality: the estate needs the UK residence schedule, French domicile facts, treaty domicile and credit calculation.

Another example concerns the beneficiary. Sarah inherited UK shares from her mother while Sarah had been French tax resident for seven of the previous 10 years. Article 750 ter may make the worldwide inheritance relevant to French tax. The UK may tax the mother’s estate under its own rules. The executor should not wait for a demand from the second country: both filing timetables and the treaty credit route should be assessed from the start.

II. How do you claim double-tax relief between the UK and France?

A. How does the 1963 France–UK inheritance convention allocate taxing rights?

The France–UK convention is a specific inheritance-tax treaty, not the general income-tax convention used for salary, pension or investment income. It was signed in Paris on 21 June 1963, approved in France by Law no. 64-562 of 17 June 1964 and brought into force by Decree no. 64-789 of 27 July 1964. The official French tax authority copy of the convention is the document to use when checking the wording. The BOFiP commentary confirms the convention’s France–UK inheritance-tax subject matter.

The treaty works through several linked questions.

1. What tax is covered? The convention covers French inheritance tax and the UK estate duty / inheritance-tax charge within its scope. It is directed at tax arising on death. HMRC’s guidance also warns that the convention does not provide a universal answer for lifetime gifts or every trust charge. For a lifetime transfer, analyse the domestic rules and any other instrument separately.

2. Where is each asset situated? The convention uses asset-specific connecting rules. Immovable property is generally situated where it is located. Debts and rights require the relevant treaty rule. Shares and securities can depend on the issuing company’s incorporation or another prescribed connection. Life-insurance proceeds and business assets may have their own provisions. Do not classify every account as “UK” merely because the bank has a UK address, and do not classify a company interest from the address shown on a dividend statement.

3. Which country has the primary taxing right? The treaty’s domicile and situs provisions can give one country the first taxing right over an asset. It may also protect assets situated in the other country from a second unrestricted charge. The deceased’s treaty domicile is a factual and legal question. The modern UK domestic long-term residence status is relevant background but does not, by itself, answer the convention question.

4. How is double tax relieved? The treaty provides a credit mechanism. If both countries charge tax on the same asset, the credit is normally limited to the tax attributable to that asset or the amount of the foreign tax, depending on the applicable provision. A credit is not a promise that the higher of the two bills disappears. It is a calculation that must be supported by the tax assessment and proof of payment in the other country.

5. What is the time limit? Article 7 of the convention provides a five-year period for a claim for credit or repayment after the death or other relevant taxable event. This is a treaty deadline and should be diarised even if the domestic French or UK assessment is being discussed. The date of death, date of payment, date of assessment and date of the request should be preserved in the file.

For a French resident estate with UK assets, the usual sequence is not “pay France and hope HMRC sorts it out”. The executor should model the UK charge, the French charge, the treaty asset allocation and the credit before deciding which return and payment are needed first. The HMRC inheritance-tax guidance for people with assets outside the UK explains that an executor may be able to use a double-taxation treaty to reclaim tax, but the claim must be evidenced.

The French domestic credit rule is also relevant. Article 784 A of the French General Tax Code states, in the cases defined by Article 750 ter, that foreign inheritance tax paid can be credited against French tax. The credit is connected with foreign-situs assets and cannot simply be applied to any French tax balance. The asset, the foreign tax and the tax paid must line up.

Imagine an estate containing a French apartment and UK shares. France taxes the apartment under its domestic law. The UK charges estate tax on the shares under its domestic rule, but France also includes the shares because of the deceased’s French domicile or the beneficiary’s six-out-of-10 residence. The French return should identify the UK shares, report the UK tax and claim the permitted credit. If the UK tax was paid first and the final French tax is lower, the credit may be capped; if the wrong country charged tax under the treaty, a repayment or correction route may be needed rather than a larger French credit.

The convention does not remove the need to examine UK domestic reliefs, French allowances or the legal ownership of the asset. A jointly owned home, a life policy written in trust, a pension death benefit and a company shareholding can each produce a different tax base. A treaty paragraph cannot cure an incorrect valuation or an incomplete list of gifts.

B. What should an executor or heir do before filing and paying?

The first task is to secure the timetable. In France, the inheritance-tax return is called a déclaration de succession. The French tax authority explains on its official declaration page that the declaration is generally due within six months of a death in metropolitan France and within 12 months where the death occurred outside France. Article 641 of the French General Tax Code expresses the same six-month and one-year distinction. A non-resident estate may need to deal with the Non-Residents Collection Office, so confirm the receiving office before sending the return.

The obligation is not limited to paying a number. Article 800 of the French General Tax Code requires a detailed declaration by heirs, legatees or donees in the situations covered by the Code, with exemptions in specified cases. The return should be complete enough to explain the estate, the family relationship, prior gifts, debts, valuations, foreign assets and any treaty credit. A blank field can create a later question about whether an asset was omitted or merely not taxable.

Payment and contesting are separate issues. Article 1701 of the French General Tax Code governs payment of transfer duties before registration. If cash is tied up in a property or an overseas investment, check the available payment arrangements early. Article 1717 of the same Code provides for split or deferred payment in situations and under conditions laid down by the rules. An application for time to pay is not the same thing as a refusal to file.

If the French assessment is wrong, the executor or heir should identify whether the error concerns residence, asset situs, valuation, a deduction, a rate, an allowance or the treaty credit. Article L190 of the French Tax Procedures Book describes claims concerning an error in the basis or calculation of tax, or the benefit of a right arising from legislation or regulation. The ordinary claim time limit should be checked against the exact tax and event. Article R*196-1 of the same book contains the general framework for claims concerning taxes other than local direct taxes, including the deadline calculated by reference to the second year after collection, assessment or the relevant event. A treaty’s five-year claim period may operate alongside a domestic procedural deadline; record both and use the earlier safe date while the position is checked.

The file should contain a document pack. At a minimum, prepare:

• the death certificate, the will, any codicil, the grant or equivalent probate document and the family-status documents;
• a 20-year UK tax-residence schedule, with self-assessment returns, P60s, P45s, HMRC residence correspondence and evidence supporting any split-year treatment;
• French tax returns, tax-residence evidence, residence permits, household records and documents showing the centre of economic interests;
• date-of-death valuations for French and UK property, bank accounts, shares, funds, business interests, pensions, life policies and digital or unusual assets;
• property deeds, land-tax records, mortgage statements, loan agreements and proof of debts or expenses claimed;
• records of gifts, trust contributions, transfers of value and insurance nominations, with dates and recipients;
• the French succession declaration, tax assessment, payment receipt and any certificat d’acquittement, meaning evidence that the French tax has been paid or cleared;
• the UK inheritance-tax account, calculations, payment evidence, correspondence with HMRC and any certificate or statement needed for a treaty claim;
• the treaty analysis showing each asset’s situs, the country taxing it first, the foreign tax paid and the credit requested;
• certified translations where a bank, notary, tax authority or court requires them. Keep the original English and French versions together so a translation does not hide a qualification.

Before filing, run four numerical checks. First, confirm the gross estate and the ownership percentage. Secondly, verify the date-of-death value rather than using a later sale price without explanation. Thirdly, test deductions and prior gifts under both countries’ rules. Fourthly, calculate the credit asset by asset. A spreadsheet should show the UK tax, French tax, foreign tax paid, treaty limit, domestic credit limit and residual amount. The numbers should reconcile to the returns, not merely to an informal estimate.

There are also procedural traps. A French notary may request proof of tax clearance before transferring French property. A UK bank or investment platform may request an HMRC form or confirmation before releasing funds. A request from one institution does not prove that its tax conclusion is correct. Ask for the legal basis, the asset classification and the document required, then compare it with the treaty map.

A beneficiary who receives a demand from the French tax authority should not ignore it because the deceased was British. The response should preserve the deadline, request the calculation if necessary, identify the foreign tax already charged and state whether a treaty credit or correction is being claimed. If the beneficiary is a UK resident who inherited French property, the same logic works in reverse: identify French-situs property, UK residence, treaty domicile and the correct relief route.

The executor should also distinguish inheritance tax from succession-law disputes. A disagreement over the validity of a UK will, the reserved portion of French children, an option to accept or renounce an inheritance, or the powers of a French notary can affect who owns what. It may not, by itself, decide where the tax is due. The related guide on whether a UK will works in France after Brexit addresses the choice-of-law and reserved-heir questions; this article concentrates on the tax connection and double-tax process.

A final worked example shows why timing matters. Eleanor left the UK in 2021 after 12 UK-resident years, became French resident and died in 2028. Her UK tail may still be active under the domestic UK residence calculation. She owned a French house, UK shares and a French bank account. The executor should not file a single “French estate” return without testing the UK exposure. The French return must be filed within the applicable period, the UK account must be prepared, the convention must allocate the assets, and a five-year treaty claim must be diarised from the death. If the French house is sold in 2029, the sale price is not automatically the date-of-death value; keep an independent valuation and the later sale evidence to explain any difference.

In another example, David has been French resident for nine of the last 10 years and inherits a UK portfolio from an aunt who lived in England. France may examine the worldwide inheritance under the beneficiary residence rule, while the UK estate may be taxed because the aunt was UK resident and the assets or estate fell within UK domestic rules. David should obtain the UK tax paid certificate, report the inheritance in the French declaration if required, and claim the credit under the correct asset-situs rule rather than assuming that a UK tax receipt is enough.

The safest workflow is therefore:

1. freeze the date-of-death asset list and valuation evidence;
2. reconstruct UK residence for the relevant 20-year period and the departure tail;
3. establish French tax domicile and the beneficiary’s six-out-of-10 residence history;
4. classify each asset under the convention’s situs rules;
5. calculate UK and French tax separately before applying relief;
6. file each required return on time, even if a treaty position is under review;
7. obtain proof of tax paid or cleared in the first country;
8. submit the credit, refund or correction claim with the treaty analysis and preserve the five-year deadline;
9. keep a complete bilingual audit file for the notary, HMRC, the French tax office and the family.

Conclusion

Moving to France does not make the UK inheritance-tax question disappear, and becoming a long-term UK resident for domestic purposes does not answer the France–UK treaty question on its own. The decisive work is a dated comparison of UK residence years, the post-departure tail, French tax domicile, beneficiary residence, asset situs and treaty domicile.

The estate should be mapped before the French déclaration de succession is filed. The 1963 convention can allocate taxing rights and provide a credit or repayment route, but it requires evidence, asset-by-asset calculations and timely claims. French allowances, rates, reserved-heir rules, trusts and payment arrangements must be checked separately from the UK account. The same document pack should support both countries and explain every difference in value, ownership and tax paid.

This is general information for British readers settling in France. A consultation is appropriate where the death is imminent or has occurred, the UK 10-year tail may apply, a French residence history reaches six of the previous 10 years, the estate includes property or trusts, or both countries have already issued assessments.

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