Moving money from a British bank account to a child living in France can look like a simple family transfer. Legally, it may be a French gift, a loan, a customary present, or part of a wider estate-planning decision. Brexit does not create a general exemption merely because the donor remains connected with the United Kingdom. The French treatment depends on the nature of the transfer, the tax residence of the donor and recipient, the family relationship, previous gifts, and the date and quality of the declaration.

The French expression don manuel means a manual gift: a movable asset, including money, handed over physically or transferred from one account to another. The person who gives is the donateur (donor); the person who receives is the donataire (recipient). A child who receives money from a British parent may therefore have to make a French declaration even where no French tax is ultimately payable. The French tax administration also expects the recipient to preserve evidence of the transfer and the family relationship.

This article deals with money, not the purchase of French property. It explains the French tax perimeter, the €100,000 parent-to-child allowance, the additional family cash-gift exemption, the 2026 online filing rule, the special treatment of gifts above €15,000, and the evidence needed if the administration questions the transaction. The United Kingdom side must be reviewed separately: HM Revenue & Customs (HMRC) can still take a lifetime gift into account for UK Inheritance Tax, depending on the donor’s status, exemptions and survival period.

I. What French gift tax applies when a British parent sends money to France?

A. When does a transfer from a UK account become a French gift?

The first question is not whether the money came from the United Kingdom. It is what the transfer legally represents. If the parent intends to enrich the child permanently and the child accepts the transfer, the operation is normally a gift. If the money must be repaid, the parties should document a genuine family loan before or at the time of the transfer. A repayment promise that is created only after a tax enquiry will not automatically change the original legal character of the payment.

Article 894 of the French Civil Code defines a lifetime gift in precise terms: “La donation entre vifs est un acte par lequel le donateur se dépouille actuellement et irrévocablement de la chose donnée en faveur du donataire qui l’accepte.” In English, the donor must part with the asset immediately and irrevocably, and the recipient must accept it. The official text is available in the French Civil Code, Article 894. A transfer labelled “help with a deposit” or “family support” can still be a gift if there is no real repayment obligation.

Money is capable of being a don manuel. It may be handed over in cash, paid by cheque, or transferred by bank. The bank statement is not the gift itself; it is evidence of the transfer, its date, its amount and the identity of the parties. The legal event is the actual transfer coupled with the intention to give. The recipient should keep the payment instruction, the debit confirmation from the UK bank, the credit confirmation from the French bank, and a short written statement identifying the gift.

The ordinary rule for a lifetime donation is notarisation. Article 931 of the Civil Code states: “Tous actes portant donation entre vifs seront passés devant notaires dans la forme ordinaire des contrats ; et il en restera minute, sous peine de nullité.” See the French Civil Code, Article 931. A simple gift of money is an important exception because a manual gift is completed by the real delivery of the money. That does not mean that every family transfer should be made informally. A notarial deed may be preferable where the amount is substantial, several children are involved, the donor wants a right of return, the gift must be made outside the recipient’s future inheritance share, or the parties need to protect against a later family dispute.

The Cour de cassation explained the boundary in its commercial chamber judgment of 11 February 2026, appeal numbers 24-18.103 and 24-19.661. The case concerned company shares rather than a cash gift, so it must not be over-generalised. Its formulation is nevertheless useful for the mechanics of a manual gift: “Il résulte du premier de ces textes que si tous les actes portant donation entre vifs doivent, à peine de nullité, être passés devant notaire, il est fait exception en cas de don manuel, lequel n’a d’existence que par la tradition réelle que fait le donateur de la chose donnée, effectuée dans des conditions telles qu’elle assure la dépossession définitive et irrévocable de celui-ci.” The complete official decision is available on Cour de cassation, 11 February 2026, nos. 24-18.103 and 24-19.661. The decision also held that certain non-negotiable SARL shares could not be treated as manual gifts. That is why a cash gift and a transfer of company rights must not be treated as the same transaction.

The next distinction is between a substantial gift and a présent d’usage, meaning a customary present given for a recognised occasion such as a birthday, wedding or Christmas. The French tax administration explains that ordinary pocket money and customary presents are not treated in the same way as an unusual transfer of wealth. The relevant official guidance is Dons entre particuliers: seul le mode de déclaration change le 1er janvier 2026. A large payment intended to fund a home, repay a mortgage or build an investment portfolio should not be described as a birthday present merely to avoid a declaration. The amount must be considered in the donor’s circumstances and in the context of the family relationship.

French tax residence then determines how wide the French tax net is. Article 750 ter of the French General Tax Code begins: “Sont soumis aux droits de mutation à titre gratuit :” The full territoriality rule is in Article 750 ter of the Code général des impôts. In practical terms, the following scenarios must be separated.

• If the donor is fiscally resident in France, French gift-tax rules can apply to gifts of assets in France and abroad, subject to the statutory conditions.
• If the donor is not resident in France but the recipient is fiscally resident in France and has been resident there for at least six of the ten years preceding the year of the gift, the French rules can reach movable and immovable property wherever located.
• If neither of those broad rules applies, France may still tax assets or rights with a French connection. The exact analysis depends on the asset, the recipient’s residence and the applicable legislation or treaty.

A British parent who remains in the UK and sends money to a child who has recently moved to France therefore needs a residence timeline. The child’s arrival date, French tax returns, tax notices, visa or residence documents, and the date of the gift may all matter. The child should not assume that a UK bank account keeps the transaction outside French reporting rules. Conversely, the donor should not assume that the child’s French address alone makes every possible foreign transfer taxable in France. The facts must be tested against Article 750 ter rather than against the location of the sending bank.

The person who normally makes the French declaration is the recipient, not the donor. Service-Public explains that “La déclaration doit être faite par celui qui reçoit le don” and identifies that person as the donataire. The official practical guide is Quelles sont les démarches fiscales pour un don manuel ?. If the recipient is a minor or an adult under a protective measure, the representative’s role must be checked. The donor should still cooperate by giving the recipient a complete file, because the recipient may need to prove the gift, the relationship, the donor’s age and the origin of the funds.

Finally, a French declaration is not the same thing as UK Inheritance Tax reporting. HMRC’s official guidance says that a gift can include money and that gifts made less than seven years before death may be relevant depending on the relationship, value and date. It also explains the annual exemption and the seven-year rule. A British parent should keep a parallel UK record using the current GOV.UK guidance on gifts and Inheritance Tax. The French declaration does not by itself settle the UK position, and a UK record does not replace the French filing.

B. Which allowance, rate and territorial rule should you calculate?

The French calculation usually starts with the relationship between the donor and the recipient, then checks earlier gifts. For a parent giving to a child, Article 779 of the General Tax Code provides a €100,000 allowance on the share of each parent or child. The relevant passage states: “il est effectué un abattement de 100 000 € sur la part de chacun des ascendants et sur la part de chacun des enfants vivants ou représentés par suite de prédécès ou de renonciation.” The official provision is Article 779 of the Code général des impôts.

The allowance is not a once-in-a-lifetime figure that resets whenever the family changes banks. It is normally available between the same donor and recipient over a fifteen-year period. Article 784 requires previous donations to be disclosed and says that earlier gifts are excluded from the calculation only when they were made more than fifteen years earlier. Its text refers to “l’exception de celles passées depuis plus de quinze ans”. See Article 784 of the Code général des impôts. A parent who already used part of the €100,000 allowance for the same child in the preceding fifteen years cannot calculate the new gift as though the allowance were untouched.

For a gift of money, there may be an additional exemption. Article 790 G covers a family cash gift made in full ownership. Its first paragraph states: “Les dons de sommes d’argent consentis en pleine propriété au profit d’un enfant, d’un petit-enfant, d’un arrière-petit-enfant ou, à défaut d’une telle descendance, d’un neveu ou d’une nièce ou par représentation, d’un petit-neveu ou d’une petite-nièce sont exonérés de droits de mutation à titre gratuit dans la limite de 31 865 € tous les quinze ans.” The full current text is in Article 790 G of the Code général des impôts.

For a parent-to-child cash gift, the €31,865 exemption can generally be added to the €100,000 relationship allowance if all conditions are met. The donor must be under 80 years old on the date of the transfer. The child must be at least 18 years old or emancipated. The gift must be made in full ownership, and the limit is measured between the same donor and recipient. A transfer to a child’s joint account, a gift subject to a retained right, or a payment that is really a loan may require a different analysis. The filing remains important even where the combined allowances mean that no payment is due.

The 31,865-euro exemption has a strict timing rule. Article 790 G expressly provides that the relevant cash gifts “doivent être déclarés ou enregistrés par le donataire dans le délai d’un mois qui suit la date du don.” A late declaration may leave the recipient with the ordinary relationship allowance but remove the specific family cash-gift exemption. The French tax administration gives the same warning in its official answer about a €30,000 family cash gift: Mon oncle m’a donné 30 000 € en espèces, est-ce un don familial de sommes d’argent ?. This is a powerful reason to record the actual date of the transfer rather than the date on which the family starts looking for a form.

Amounts above the available allowances are not automatically taxed at one flat rate. Article 777 states: “Les droits de mutation à titre gratuit sont fixés aux taux indiqués dans les tableaux ci-après, pour la part nette revenant à chaque ayant droit.” The direct-line table starts at 5 per cent, moves through the intermediate brackets and reaches 45 per cent for the highest part. The current table is in Article 777 of the Code général des impôts.

Consider a parent who transfers €160,000 to an adult child and who satisfies the conditions for both allowances, with no relevant earlier gift. The first €100,000 uses the parent-to-child allowance and the next €31,865 uses the family cash-gift exemption. The remaining €28,135 is the starting taxable base before the progressive direct-line calculation. That is an illustration of the method, not a tax assessment: the correct euro value, previous gifts, donor age, recipient status, and any relief must be checked before filing. If the transfer was made in pounds, the file should state how the euro amount was obtained and preserve the bank’s conversion evidence.

The value date also matters. Article 757 provides that the rights are calculated on the value of the manual gift at the date of its declaration or registration, or at the date of the gift if that value is higher. The relevant statutory wording begins: “Ces droits sont calculés sur la valeur du don manuel au jour de sa déclaration ou de son enregistrement, ou sur sa valeur au jour de la donation si celle-ci est supérieure.” See Article 757 of the Code général des impôts. A sterling transfer should therefore not be converted casually using today’s exchange rate when the transfer and declaration occurred at different dates.

The recipient should also consider whether the gift is intended to be an advance on inheritance. A simple gift can affect equality between children and may be taken into account later in the donor’s estate. A short private document can state the family’s intention, but it cannot always replace a properly structured deed. If the donor wants the gift to be outside the recipient’s inheritance share, wants to balance gifts to several children, or wants to preserve evidence for the estate, a notary should review the structure before the money moves. The choice between a simple manual gift, a notarial gift and a gift-sharing deed is a succession decision as well as a tax decision.

On the UK side, HMRC’s rules are different in design. GOV.UK lists money as a gift, explains that gifts made within seven years of death can be taken into account, and describes the £3,000 annual exemption and other exemptions. The UK guidance also requires the people dealing with the estate to keep a record of what was given, to whom, when and at what value. A British donor should preserve that information even when the French tax due is zero. If the donor is UK-domiciled or has another UK connection, the estate should obtain advice on the current Inheritance Tax rules instead of treating the French allowance as a UK exemption.

II. How do you declare a UK-to-France gift and challenge an error?

A. Which form, documents and deadline apply?

For a child living in France, the first operational step is to identify the correct French tax account. The recipient should use the personal espace Finances publiques on impots.gouv.fr, not the donor’s account and not the spouse’s account, because the tax calculation depends on the identity and relationship of the donor and recipient. The online route is labelled “Déclarer un don ou une cession de droits sociaux”. The French tax administration’s current page is Don manuel.

Since 1 January 2026, the French administration states that a manual gift or money gift must normally be declared online through the secure account. Service-Public gives the same procedure and confirms that the recipient must declare even when the gift is below the allowance and no tax is payable. The 2026 rule is a change in filing channel, not a new tax exemption. The administration’s official form page explains that Form 2735 is used for manual gifts and money gifts under Articles 635 A and 790 G, while the normal route is now the online service: Form 2735 on impots.gouv.fr.

There are exceptions to the online route. A recipient without internet access or who cannot complete the electronic process may fall within a paper-filing exception. In those cases, Form 2735-SD is generally filed in duplicate with the French registration service responsible for the recipient’s domicile. The current form and notice should be used, not an old copy downloaded from an unverified website. If the child lives in France but has not yet received a French tax number or cannot access the account, the file should be escalated to the relevant tax office rather than leaving the gift undeclared.

The recipient should prepare the information before opening the online declaration. The minimum file should contain:

• the donor’s full legal name, date and place of birth, UK address and tax-residence position;
• the recipient’s full name, French address, tax number, date and place of birth, and proof of the parent-child relationship;
• the exact date on which the funds left the donor’s control and the date on which they arrived;
• the amount sent in pounds, the amount credited in euros, the exchange-rate method and the bank statements supporting both figures;
• the transfer reference, account identities and a signed letter confirming whether the payment is an outright gift or a repayable loan;
• the donor’s age on the date of the gift and the child’s age or emancipation status, if the family wants to claim Article 790 G;
• a schedule of earlier gifts between the same donor and child during the preceding fifteen years; and
• the UK record needed for any later Inheritance Tax review, including the date, value, recipient and any claimed UK exemption.

The transfer letter should avoid vague language. It should state, for example, that the parent gives a specified amount to the child in full ownership on a specified date, that the child accepts the gift, that no repayment is due, and that the payment is not consideration for services. If the family actually intends a loan, the document should say so and include a repayment schedule, interest position if relevant, and evidence that the parties intended repayment at the time of the transfer. A false gift letter can create a worse evidential record than an honest loan agreement.

The ordinary cash-gift deadline is especially important where Article 790 G is claimed. The donor can initiate the transfer from the UK, but the recipient is responsible for ensuring that the French declaration is completed within one month of the gift where the statutory exemption requires it. The deadline should be measured from the actual donation, not from the date on which the recipient spends the money, buys a French asset, or receives a tax-office reminder.

For a manual gift above €15,000, French law provides a special option to reveal the gift and defer the declaration and payment of the rights until the donor’s death. This is not an automatic postponement. The recipient must use the appropriate revelation process and choose the option at the time of the revelation. The French administration describes Form 2734 as “Révélation de don manuel d’une valeur supérieure à 15 000 €” and explains that the revelation must be spontaneous. The current official guidance is available in the Don manuel section of impots.gouv.fr.

Article 635 A states that manual gifts covered by Article 757 must be declared or registered within one month after the recipient reveals the gift to the tax administration. For gifts above €15,000, the text addresses the choice between declaring after revelation and declaring after the donor’s death, including the situation where the revelation follows a tax enquiry. See the official Article 635 A of the Code général des impôts. The wording is not a licence to wait indefinitely: the recipient should take advice before making a late or incomplete revelation.

The filing channel and the legal deadline should be kept separate. Online filing may give the recipient an immediate receipt, but the receipt does not prove that the family’s calculation was correct. The recipient should download the submission confirmation, save the declaration data, preserve the bank file, and record the date of registration. If the online service calculates tax, the recipient should verify the relationship, previous gifts and exemption boxes before paying. A declaration that is technically submitted but factually incomplete can still lead to a later assessment.

If the child is a minor, the person with parental responsibility or another lawful representative may have to make the declaration. A British parent cannot simply use the child’s identity without checking the French rules on representation. The child’s residence status, tax number and bank account may also affect the evidence. If a minor’s money is being held by a parent or a trust-like arrangement, the transfer should be reviewed before it is described as an outright gift to the child.

B. What if the French tax office refuses the exemption or issues a penalty?

The most common dispute is not whether a bank transfer occurred. It is whether the transfer qualifies for the claimed exemption, whether the declaration was timely, whether earlier gifts were omitted, and whether the payment was really a gift. A recipient who has received a request for information should not answer with a bare sentence such as “this was family help”. The answer should be supported by a dated chronology and the evidence that existed when the money moved.

If a gift above €15,000 is revealed during a tax examination, the deferred-declaration option is particularly vulnerable. In Cour de cassation, commercial chamber, 25 January 2023, no. 20-16.700, the Court examined a gift revealed during an examination of the taxpayer’s personal tax situation. It stated: “Il résulte de ce texte que les dons manuels d’un montant supérieur à 15 000 euros révélés à l’administration fiscale par le donataire doivent être déclarés dans le délai d’un mois qui suit la révélation ou, sur option du donataire lors de la révélation du don, dans le délai d’un mois suivant la date du décès du donateur, une telle option étant exclue lorsque la révélation est la conséquence d’une réponse du donataire à une demande de l’administration ou d’une procédure de contrôle fiscal.” The lesson for a British family is practical: do not wait for a French audit before deciding how to disclose a large transfer.

The Court applied the same distinction in Cour de cassation, commercial chamber, 4 March 2020, no. 18-11.120. The decision concerned gifts discovered while the administration was asking questions about bank flows. The Court referred to the rule that the declaration of gifts over €15,000 must be made within one month when revelation results from a response to a request or a tax-control procedure. Its verified wording includes: “la déclaration des dons manuels supérieurs à 15 000 euros visés à l’article 757 du même code doit être réalisée dans le délai d’un mois qui suit la date à laquelle ce don a été révélé lorsque cette révélation est la conséquence d’une réponse du donataire à une demande de l’administration ou d’une procédure de contrôle fiscal”. The exact facts matter, but the decision shows why a family should not characterise a compelled answer as a spontaneous declaration.

The statutory framework also matters when the administration recalculates the taxable base. Article 757 uses the higher value at the donation date or the declaration date. Article 784 brings relevant prior donations into the fifteen-year calculation. Article 779 provides the parent-to-child allowance, while Article 790 G imposes its own age, relationship, full-ownership and one-month conditions. A refusal letter should therefore be analysed box by box: value, date, donor, recipient, relationship, previous gifts, residence, claimed allowance and evidence of actual delivery.

The proof of a gift can become a civil dispute between siblings or between the recipient and the donor’s estate. Article 1353 of the Civil Code states: “Celui qui réclame l’exécution d’une obligation doit la prouver. Réciproquement, celui qui se prétend libéré doit justifier le paiement ou le fait qui a produit l’extinction de son obligation.” The official text is Article 1353 of the French Civil Code. A parent who claims that a transfer was a loan needs evidence of the repayment obligation; a child who claims an outright gift needs evidence of the transfer and the donor’s intention.

The Cour de cassation’s first civil chamber has also dealt with the evidential presumption attached to possession of a manual gift. In Cour de cassation, first civil chamber, 4 November 2020, no. 19-13.202, the verified extract states: “Il résulte de ces textes que le possesseur qui prétend avoir reçu une chose en don manuel bénéficie d’une présomption et qu’il appartient à la partie adverse de rapporter la preuve de l’absence d’un tel don, ou de prouver que la possession dont se prévaut le détenteur de la chose ne réunit pas les conditions pour être efficace.” That case involved the characterisation and challenge of gifts, not a UK-to-France transfer. It nevertheless underlines the value of a contemporaneous bank trail and a clear family document when the estate later becomes contested.

If the administration issues a proposed adjustment, the recipient should preserve the envelope or electronic notice, identify the legal basis cited by the tax office, and observe the response deadline. The response should explain why the payment was a gift, loan or customary present; prove the actual date and euro value; identify every relevant earlier gift; and show why the claimed allowance applies. If the problem is a factual error in an online declaration, Service-Public explains that an online rectifying declaration may be possible within the stated correction period, while a paper declaration is not corrected through the same online route. The current instructions should be checked on Service-Public’s manual-gift procedure page before a correction is filed.

A penalty can have more than one cause. It may relate to late payment, a late or incomplete declaration, failure to use the online route where required, or the loss of a particular exemption. Service-Public currently warns that failure to comply with the online declaration and payment obligation can trigger a 0.2 per cent increase of the tax due, subject to a minimum amount. The recipient should not accept that a penalty is inevitable: the notice, the date of the gift, the date of the filing, the online-access situation and any genuine impossibility must be reviewed. A request for a goodwill waiver is not the same as a legal challenge to the tax base, so both tracks may need to be considered.

The UK and French consequences should be coordinated. The French recipient should retain the French declaration and tax calculation. The British donor should retain the transfer record and the UK gift schedule. If the donor dies within the period relevant to UK Inheritance Tax, the executor may need the gift date and value even if France granted an allowance. If the child later receives a request from HMRC, the French declaration can help prove the nature and date of the transfer, but it does not determine the UK tax result.

The family should also test whether the money is genuinely available to the child. If the donor retains effective control, imposes an informal condition, or continues to use the funds, the analysis may differ. A transfer that is meant to fund a French property purchase may require separate advice on the property transaction, source-of-funds checks, co-ownership and the inheritance consequences. This article does not turn a cross-border gift into a property-purchase guide; it identifies the gift and reporting issues that should be settled before the purchase file is opened.

The practical response to a French assessment is therefore documentary and legal at the same time. First, identify the transaction. Second, rebuild the timeline. Third, recalculate the allowances with all gifts in the fifteen-year period. Fourth, check the donor’s and recipient’s residence during the relevant years. Fifth, separate an Article 790 G claim from the ordinary Article 779 allowance. Sixth, verify whether a large-gift deferral was chosen spontaneously or only after a tax question. Seventh, submit a reasoned response before the deadline in the notice. A short, unsupported denial is rarely enough for a cross-border file.

Conclusion

A British parent can often transfer money to a child in France without immediate French gift tax, but the result depends on residence, relationship, previous gifts, donor age, the child’s age, the nature of the transfer and the filing date. The practical sequence is to document the gift before transfer, preserve the pound and euro bank trail, check Article 750 ter, calculate the €100,000 allowance and the possible €31,865 family cash-gift exemption, declare through the correct French channel, and keep a separate UK Inheritance Tax record.

The French declaration remains important even when the available allowances produce a nil tax calculation. A missed one-month deadline can affect the family cash-gift exemption. A large gift revealed during an audit may not qualify for deferred payment. A later succession dispute may turn on whether the payment was irrevocable, whether it was intended as a gift or a loan, and whether earlier gifts were disclosed. The safest file is one that states the family’s intention clearly and supports every number with a dated document.

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