A British parent who is genuinely tax-resident in France can usually give cash to a child living in the United Kingdom. The fact that the recipient is in Britain does not, by itself, remove French gift-tax rules. The parent must first identify the French allowances available, then declare the transfer through the correct channel, preserve evidence of what was given and decide how the gift should be treated in the eventual succession. A separate UK Inheritance Tax analysis is also required: the United Kingdom applies its own seven-year rules, exemptions and residence tests to the donor and the estate.

This distinction matters after Brexit. There is no single Franco-British gift-tax form that replaces both countries’ domestic rules. A bank transfer from France to a UK account may therefore create a French declaration, a UK Inheritance Tax record and a family-law question at the same time. This article deals with a cash or other movable-asset gift from a French-resident British parent to an individual child in the UK. It does not deal with buying a French property, creating a company or transferring shares in a French société civile immobilière (SCI, a French civil property-holding company). Those transactions require a different analysis.

I. Can a French-resident British parent give money to a child in the UK?

A. Which French gift-tax allowances apply when the child lives abroad?

The first question is the donor’s tax residence on the date of the gift, not the child’s nationality. In this article, the donor is the parent making the gift and the donee is the child accepting it. A French tax resident who gives cash to a UK-resident child remains within the French gift-tax framework. Article 750 ter of the Code général des impôts (CGI, the French General Tax Code) provides that gifts are subject to transfer duties when the donor is domiciled in France, including property situated in France or abroad. The official text begins: Sont soumis aux droits de mutation à titre gratuit : Article 750 ter CGI. A UK bank account is not a way to make a French-resident donor invisible to the French tax administration.

The civil-law starting point is also important. Article 894 of the French Civil Code defines a lifetime gift as an act by which the donor parts with the asset immediately and irrevocably for the benefit of the recipient who accepts it. The official wording is: 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. Article 894 Code civil. This is why the parties should not call a transfer a loan merely because they want to avoid a declaration. If repayment is genuinely expected, the loan must be real, documented and operated as a loan. If the parent has permanently enriched the child, the file should be treated as a gift.

French law distinguishes a don manuel, meaning a manual gift of movable property such as money, from a formal notarised donation. The manual form may be used for cash, a cheque or securities, but it does not eliminate the tax declaration. By contrast, a formal lifetime donation generally requires a notarial deed: Article 931 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. Article 931 Code civil. A French notary is not always mandatory for a straightforward cash transfer, but a notary becomes highly useful when the parent wants conditions, a right of return, protection against a future divorce, a gift to be taken out of the child’s inheritance share or a full family equalisation plan.

For a direct gift from a parent to a child, the main French allowance is the €100,000 parent-to-child allowance. It is available per donor and per child and is renewed over a fifteen-year period. The figure comes from Article 779 CGI. It is not a single family allowance shared between both parents: each parent must be considered separately, and every earlier gift to that same child must be checked.

A second allowance can apply to a cash gift. Article 790 G CGI allows an additional €31,865 family cash-gift allowance where the donor is under 80 and the recipient is an adult child, grandchild or, in certain cases, a great-grandchild. The conditions and the fifteen-year renewal period are set out in Article 790 G CGI. A child living in the UK is not excluded merely because the child is outside France. The decisive points are the relationship, the age of the donor, the age of the recipient and the nature of the asset.

The additional €31,865 allowance is not a general yearly exemption. It is not available if the donor is already 80 or older, and it does not apply when the recipient is a minor child. The €100,000 parent-to-child allowance may still be relevant in those situations. The French public-service guidance also confirms that a cash gift does not necessarily require a notary and explains the specific conditions for the family cash-gift allowance: French Government guidance on gift tax.

For a parent under 80 giving €100,000 to an adult child, the combined French allowances can therefore reach €131,865, assuming that no earlier gift has used the available fifteen-year allowances. The child may receive the money in a UK account, but the parent should keep a calculation showing why each allowance was claimed. If two parents are giving money, prepare a separate calculation for each parent rather than treating the couple as one donor.

B. How much French tax can be due and what must be declared?

The amount of tax depends on the taxable balance after the applicable allowances and on the relationship between donor and recipient. Direct-line rates are progressive. Article 777 CGI sets the scale, beginning at 5% for the first band and reaching 45% for the highest direct-line band. The declaration is required even when the allowances reduce the amount of tax to nil. “No tax to pay” and “nothing to declare” are not the same conclusion.

Take a simple illustration. A French-resident parent under 80 gives €200,000 in cash to an adult child in the UK, and the parent has made no earlier gift to that child during the relevant fifteen-year period. The €100,000 allowance under Article 779 and the €31,865 family cash-gift allowance under Article 790 G leave €68,135 potentially taxable. Applying the direct-line scale produces an indicative duty of approximately €11,821.35 before any issue concerning earlier gifts, a different relationship, valuation, a special exemption or rounding. This is an illustration, not a tax assessment. The result changes if the parent is 80, if the child is under 18, if one allowance has been consumed, or if more than one donor is involved.

A manual gift must be reported when it is made or revealed under the rules applicable to the gift. Article 757 CGI deals with manual gifts that are declared or revealed to the tax administration. The registration rule is linked to Article 635 A CGI, which requires the relevant gift to be declared or registered within the prescribed period after revelation: Article 757 CGI and Article 635 A CGI. For a newly made cash gift, the practical approach is to organise the declaration promptly, normally within one month, and to confirm the correct channel for the donor and recipient’s residence.

Since 1 January 2026, the French administration has generally directed individuals to declare gifts online through the personal tax account. A person who has no French income-tax obligations may fall within an exception to the online route and may need the paper form. The official non-resident guidance explains the distinction and identifies Form 2735, the declaration of a manual gift, as the paper route where it applies: impots.gouv.fr guidance for non-residents declaring a cash gift. The recipient’s UK address does not remove the French filing question when the donor is French-resident. Keep a copy of the submission, the acknowledgement, the payment notice if tax is due and the exchange-rate basis used for a euro calculation.

The French Supreme Court has also warned against treating the moment of disclosure as a casual detail. In its commercial chamber judgment of 4 March 2020, appeal no. 18-11.120, the court held that the taxpayers’ response to a tax request could itself reveal the manual gift: la réponse des contribuables valait révélation au sens des articles 635 A et 757 du code général des impôts. The full decision is available on Cour de cassation, commercial chamber, 4 March 2020, appeal no. 18-11.120. A late attempt to postpone the declaration until a bank, notary or tax officer asks a question can therefore create avoidable difficulty.

The transfer file should contain more than a bank statement. Record the donor’s and child’s full names, dates and places of birth, addresses, relationship, date of the gift, gross amount, currency, exchange rate, account details, the fact that no repayment is expected and whether the gift is intended as an advance on inheritance or an additional gift. Add the signed gift letter, the transfer confirmation, the child’s receipt and evidence of the source of funds. If the payment is in pounds, retain the pound amount and the euro conversion used for the French return. The description should be truthful: a gift letter cannot turn a real loan into a gift, and a label such as “family support” cannot answer the succession questions later.

Finally, check the fifteen-year history before filing. Article 784 CGI requires earlier gifts to be taken into account for the relevant fiscal calculation, subject to the statutory time rules: Article 784 CGI. The French tax look-back and the UK seven-year Inheritance Tax record are different clocks. A gift can fall outside one calculation while remaining important in the other, which is why the family should maintain one dated cross-border gift register rather than separate informal notes.

II. What does the gift change in the UK and in the French succession?

A. How does the UK seven-year rule interact with French tax?

The UK analysis normally begins with the donor and the donor’s estate, not with the child’s location alone. Under the UK Inheritance Tax rules, an outright gift to an individual can be outside the estate if the donor survives the relevant seven-year period, but the result depends on the type of gift and on the donor’s wider history. If the donor dies within seven years, the gift can be brought into the Inheritance Tax calculation. The UK Government’s current guidance covers the seven-year rule, gifts with reservation, the annual exemption, small gifts and other exemptions: GOV.UK: Inheritance Tax and gifts.

The UK annual exemption is generally £3,000 for a tax year, with a possible carry-forward of the unused exemption from the previous tax year. Other limited categories include small gifts of up to £250 per person and certain wedding or civil-partnership gifts. Regular payments may also qualify as normal expenditure out of income, but only if the statutory conditions are genuinely met and the donor can maintain their normal standard of living. These UK exemptions do not replace the French declaration. They are separate questions, with different currencies, tax years and evidence.

For example, a parent may use the French €100,000 allowance and the French €31,865 family cash-gift allowance, declare the transfer in France and still need to record the full gift in the UK seven-year file. Conversely, a payment that appears harmless under a UK exemption may still need a French declaration because the French rules focus on the donor’s residence, the type of asset and the statutory allowances. A cross-border spreadsheet should show the gross transfer date, the French euro value, the UK pound value, the exemptions claimed in either country and the remaining family allowances.

Do not assume that moving to France ends every UK Inheritance Tax connection. Since 6 April 2025, the UK uses a long-term UK residence test for many foreign-asset questions. The Government describes a long-term UK resident as someone who has been UK tax-resident for all of the previous ten tax years or for at least ten of the previous twenty tax years, with possible continuing exposure for a period after departure. The test is not based simply on a British passport and is not identical to French tax residence. The official guidance is GOV.UK: Inheritance Tax if you are a long-term UK resident.

This means that a British parent living in France should review the date of departure from the UK, the UK tax-residence record for the previous ten and twenty-year periods, the nature of the asset given and the parent’s remaining estate. French residence may be decisive for French gift tax while the UK long-term-residence status remains relevant to UK Inheritance Tax on foreign assets. A UK bank account, UK investments or other UK-connected property may require separate asset-situs analysis. The cash gift should not be isolated from the rest of the estate plan.

The France–UK inheritance convention also requires care. The UK Government’s double-taxation guidance explains that estate and inheritance conventions do not all use the same concepts and that the France convention is an older instrument with its own allocation rules: GOV.UK: Inheritance Tax double-taxation relief. HMRC’s technical guidance on the France convention records relief mechanics for UK Inheritance Tax due on death and the treatment of particular assets: HMRC Inheritance Tax Manual, France convention. Neither page supports the proposition that a French-resident parent can skip a French lifetime-gift declaration because a child lives in Britain.

Do not use the 2008 France–UK income and capital-gains convention as if it were a general gift-tax treaty. That convention concerns income and capital gains and has a different purpose: 2008 UK–France double-taxation convention. If the same event can produce a French gift duty now and a UK Inheritance Tax issue later, the family must test the treaty provisions, the asset’s location and the relevant residence rules rather than promise that one country will automatically credit the other.

The UK child should therefore receive a clear explanation of the record-keeping plan. The cash itself is not the child’s salary, but subsequent interest, investment income, benefits, financial-assessment consequences or a later transfer of the money can create their own issues. The recipient should keep the gift letter, the French declaration and the transfer record with the UK estate papers. If the parent has a trust, a retained benefit, a family company or a condition that allows the parent to use the money, the simple seven-year analysis may not apply.

B. How can a British family document equality, reserved heirs and the cross-border file?

Tax is only one layer. The parent must decide whether the gift is intended to be an advance on the child’s inheritance or an additional benefit. In French succession terminology, a gift brought back into the accounting of the estate is subject to rapport; a gift intended to remain outside the child’s normal share may be described as hors part successorale, meaning outside the inheritance share. These phrases should never be inserted mechanically. Their effect depends on the deed, the applicable succession law, the family structure and the available portion of the estate.

Article 843 of the French Civil Code sets the starting rule for gifts received by heirs, subject to the exceptions and wording provided by law. It is available in the official Code civil provisions on the report of gifts. Article 860 addresses valuation and subrogation questions when a gift is reported, including the relationship between money given and an asset acquired with that money: Article 860 Code civil. A parent who wants equal treatment between a child in Britain and a child in France should set out the intended treatment while memories and account records are still available.

The case law illustrates why an apparently simple transfer can later become contested. In a civil first chamber judgment of 6 March 2024, appeal no. 22-14.745, the Supreme Court stated that only a genuine liberality with both impoverishment and an intention to benefit the heir is reportable: seule une libéralité, qui suppose un appauvrissement du disposant dans l’intention de gratifier son héritier, est rapportable à la succession. Read the exact decision at Cour de cassation, civil first chamber, 6 March 2024, appeal no. 22-14.745. This is useful when distinguishing a gift from a genuine loan, reimbursement, expense paid for the child or money held on the parent’s behalf. It is not a licence to re-label an unconditional gift after the event.

In another civil first chamber judgment, 14 February 2024, appeal no. 23-19.059, the court described the report as an obligation that makes each heir account to the succession for the gifts received. The decision uses the words oblige chaque héritier à rendre compte à la succession des libéralités qu’il a reçues and can be checked at Cour de cassation, civil first chamber, 14 February 2024, appeal no. 23-19.059. A donation deed can therefore be central to the family’s later calculation. The parent should say whether the amount is an advance, whether it is to be taken outside the share, whether an equalisation payment is expected and how any currency difference should be treated.

French reserved-heir rules may also matter. If French succession law applies and the parent has children, part of the estate may be reserved for them. A gift that exceeds the disposable portion can face a reduction claim after death. Article 921 of the Civil Code provides the relevant limitation framework, including the five-year period from the death or the two-year period from discovery of the infringement, subject to the statutory long-stop: Article 921 Code civil and the action for reduction. A UK-resident child is not outside the family-law analysis merely because the child lives abroad. The applicable succession law must first be established, including any valid choice of law in a will and the parent’s habitual residence.

The UK child may also be an heir under the succession law that ultimately applies, or may be a beneficiary of a will without being treated in the same way under French civil law. A will drafted in England and Wales, a French will, a Scottish succession position, a spouse’s rights, a previous donation and a family trust can each change the result. The parent should not write “this is outside the estate” in a private letter without checking whether the sentence is intended to have tax, civil or testamentary effect.

There is a further warning about declarations. In a criminal chamber judgment of 20 November 2024, appeal no. 23-84.817, the Supreme Court held that le défaut de déclaration par le donataire n’est pas susceptible de constituer en soi une fraude fiscale. The exact decision is available at Cour de cassation, criminal chamber, 20 November 2024, appeal no. 23-84.817. That narrow criminal-law holding does not make a gift declaration optional. It does not cancel the tax duties, the interest or penalties that may apply, the civil report issue or the evidential damage caused by an unexplained transfer. The safe approach remains truthful, timely disclosure and a preserved file.

A practical cross-border checklist should include the following questions before the transfer:

1. Was the parent genuinely tax-resident in France on the date of the gift, and is there any competing UK residence or long-term-residence position?
2. Is the asset cash, securities, a loan, a trust distribution or something else, and what is its euro and pound value on the transfer date?
3. What gifts has this parent already made to this child during the previous fifteen years, and what gifts has the other parent made?
4. Is the child an adult, and is the donor under 80 so that the family cash-gift allowance can be considered?
5. Is a manual gift appropriate, or does the family need a notarial deed with conditions, a right of return or a clear out-of-share instruction?
6. Should the gift be treated as an advance on inheritance, and how will children in different countries be equalised?
7. Has the transfer been made traceable, with a signed letter, account statements, a receipt and an honest statement that distinguishes gift from loan?
8. Has the French online declaration or Form 2735 route been confirmed, with the submission, acknowledgement and tax calculation retained?
9. Has the UK seven-year record been updated, including annual exemptions, possible tapering, the donor’s estate and any gift with reservation?
10. Has a professional reviewed the France–UK treaty position if both countries could tax or relieve the same asset or succession event?

The family should also keep the wider succession documents together: current wills, marriage or civil-partnership documents, evidence of habitual residence, prior gift deeds, trust instruments, bank statements and a schedule of the parent’s remaining assets. The French administration may focus on the declaration, while a future heir or executor may focus on intention and equality. One coherent file reduces both risks. For the broader French private-client context, see our French private-client legal services page.

If the transfer has already happened, do not destroy messages or attempt to rewrite the reason for payment. Assemble the original evidence, identify the date on which the gift was made or revealed, verify the fifteen-year French history and obtain a corrected filing strategy. A late but accurate declaration is usually more defensible than a sequence of inconsistent explanations. If there is a dispute between children, obtain advice before sending a new family email: an admission about equality, repayment or the intended inheritance treatment can become important evidence.

Conclusion

A French-resident British parent can often give money to a child in the UK, but the transfer should be treated as a three-part file. First, calculate the French allowances and progressive duty under the donor’s residence and the parent-child relationship. Second, declare the manual gift through the correct French channel, even if no French tax is payable, and preserve the transfer evidence. Third, record the gift for the UK’s seven-year Inheritance Tax analysis and for the family’s succession plan. Brexit does not merge these rules and a UK bank account does not remove the French declaration.

The amount, the donor’s age, the child’s age, earlier gifts, the donor’s UK residence history, the existence of other children and the wording of any will can change the answer. The safest document is not the longest one; it is the one that accurately identifies the transfer, explains its intended civil treatment and can be reconciled with both countries’ tax records.

Need a quick opinion on your case

A cross-border gift can be reviewed during a telephone consultation within 48 hours with a lawyer from the firm. We can help you check the French declaration, the UK seven-year record and the succession wording before the transfer creates a dispute.

Call +33 6 46 60 58 22 (Maître Reda Kohen), or use the contact form for kohenavocats.fr.