If you live in France and have left money in a UK pension, 6 April 2027 is a date to put in your family’s legal calendar. From deaths on or after that date, the United Kingdom will bring most unused pension funds and pension death benefits into the deceased member’s estate for Inheritance Tax purposes. The change is enacted in the Finance Act 2026; it is not simply a proposal that can be ignored until a provider writes to you. The date of death matters even if the pension is paid later.

A French resident must then deal with two distinct questions. First, what does UK Inheritance Tax (IHT) charge under the new pension rules, including the member’s residence history and the identity of the beneficiary? Secondly, what does France charge as droits de mutation à titre gratuit, the French tax on gifts and transfers on death, and how does the France–UK succession convention prevent the same value being taxed twice? A French spouse exemption, a beneficiary nomination or a French tax return does not answer every UK question. This guide sets out the legal framework, the evidence to assemble before a death, and the steps an executor, administrator or French notary should take afterwards. It does not concern purchasing French property or creating a company.

I. How will the 6 April 2027 UK pension inheritance-tax change affect a British resident in France?

A. Which unused UK pension funds and death benefits enter the estate?

The starting point is the operative date. HM Revenue & Customs (HMRC) states in its technical note on Inheritance Tax and pensions that the reform applies to deaths on or after 6 April 2027. A member who dies on 5 April 2027 remains under the current pension-IHT rules even if the administrator pays the death benefit on 10 April. A member who dies on 6 April 2027 enters the new regime even if the scheme needs months to establish the beneficiaries. For a family living in France, the date on the death certificate should therefore be recorded separately from the date on which the pension provider releases funds.

The reform uses the concept of “notional pension property”. In practical terms, this is the value immediately before death of pension property held in arrangements that can provide benefits on the member’s death, less benefits expressly excluded by the legislation. It is not limited to a simple uncrystallised personal pension balance. The HMRC note explains that the calculation can include money purchase arrangements, such as a SIPP or defined-contribution pot, and defined-benefit arrangements where a lump sum or continuing scheme payment can arise. The provider must identify the arrangements and apply the statutory calculation rather than merely copy the figure displayed on an online account.

For a money purchase pension, the relevant enquiry is whether property in the pension pot can or may be used to provide a benefit on death. Amounts outside the pot can also matter where they can reasonably be expected to fund a death benefit, including an augmentation of the amount normally payable. For a defined-benefit pension, the calculation can include a lump sum and the value of a continuation payment assessed on the statutory assumptions. This means that a British resident should not ask only, “How much cash is in my pension?” The family should also know whether a final-salary scheme promises a widow’s, widower’s, dependant’s or nominee’s payment and how the scheme values it at death.

Most unused funds and death benefits are within the reform, but “most” is important. The official HMRC policy explanation identifies exclusions, including qualifying death-in-service benefits, continuing annuities and certain small funds. A death-in-service benefit is not simply any lump sum paid after a working person dies. The technical note says that it must arise from the member’s current employment or other work of the relevant description immediately before death. A refund or pension connected with a previous employment can remain a different benefit. The provider must classify each component; the family should obtain that classification in writing.

The distinction between a current employment benefit and an old deferred pension is particularly important for a British person who worked in several countries. A payment linked to a current French or UK employment may have a death-in-service character, while an old occupational pension kept after leaving a former employer may not. A nominated beneficiary does not turn an old pension into a death-in-service benefit. Nor does calling a pension “protected” on an adviser’s document answer the question under the new IHT legislation.

The scheme type also matters. For a long-term UK resident, HMRC says that notional pension property in a UK registered scheme, a qualifying non-UK pension scheme or a section 615(3) scheme can be within IHT regardless of where the scheme is established, subject to exemptions and reliefs. For a non-long-term UK resident, the new charge is directed at relevant pension property in a scheme established in the UK; the technical note says that non-UK schemes are treated differently in that case. These are UK statutory residence categories, not a simple test of nationality. Moving to France after Brexit does not by itself make a person a non-UK long-term resident, and holding a British passport does not by itself make the charge apply.

That residence question needs a personal timeline. Keep the dates of departure from the UK, returns, periods of work, former homes, and the evidence HMRC may use for long-term residence. The official GOV.UK guidance on long-term UK residents explains the separate residence regime introduced for IHT from 6 April 2025. It should be read with the pension technical note and the actual Finance Act, not replaced by an adviser’s general statement that “non-residents are outside UK inheritance tax”.

Beneficiary discretion is no longer a complete answer either. Under the reform, pension administrators must identify the value of the notional pension property and the split between exempt and non-exempt beneficiaries. The member’s nomination can still influence who receives the benefit, but it does not remove a value from the estate merely because trustees or administrators exercise discretion. If a pension is paid to an adult child, an unmarried partner, a trust or another non-exempt beneficiary, the family must examine the UK IHT consequences even where the pension never entered the deceased’s ordinary bank account.

A beneficiary nomination and a will perform different jobs. The nomination is an instruction or expression of wishes under the pension scheme rules; the will deals with the estate to which it applies. The two documents can point to different people. A French will that leaves the house to a spouse does not necessarily change the beneficiary recorded on a UK pension. Conversely, a nomination to a child can create a tax and liquidity issue for the executor even if the will gives all other assets to the surviving spouse. The existing guide to UK wills used in France after Brexit should be read as a separate succession question, not as a substitute for checking every pension form.

Valuation is another likely source of delay. HMRC’s technical note says that a pension administrator should provide the open-market value at the date of death, and if a definitive value cannot be provided within 28 days of a formal request, an estimate with its basis should be supplied. The final value must follow when available. The personal representative should keep the request date, the response, the valuation basis, the exchange-rate method and every later correction. A statement issued on the date of death is stronger evidence than a later screen print showing a value after market movements.

The tax is not calculated by applying an automatic percentage to every pension balance. The estate must be tested against the relevant IHT bands, exemptions, reliefs, debts and beneficiary status. A pension paid to a qualifying spouse or civil partner may receive a UK exemption, while a payment to a child may not. Charitable giving, lifetime transfers, residential relief and long-term UK residence can also change the calculation. The practical lesson is to record the full estate rather than ask the pension provider for a stand-alone “tax figure”. Only the complete facts permit a reliable calculation.

Consider two otherwise identical deaths. If the member dies before 6 April 2027, a provider may distribute an unused defined-contribution pot under the rules then in force. If the member dies after the commencement date, the same pot may be a component of the estate for UK IHT even though the beneficiary still receives the money through the pension scheme. That comparison is why the family should review the pension now, but should not make a rushed withdrawal, transfer or change of nomination solely to avoid a tax that depends on facts not yet analysed.

B. Does French residence, the France–UK treaty or a French spouse remove the UK charge?

French residence does not create a universal UK exemption. It creates a second tax and legal analysis. Under Article 4 B of the French General Tax Code, French tax domicile, or domicile fiscal, can arise where a person has in France their home or principal place of stay, works there, or has the centre of their economic interests, unless an international convention treats the person as resident elsewhere. The Code states: Les personnes qui ont en France leur foyer ou le lieu de leur séjour principal. The test is factual and treaty-sensitive. A British citizen with a French home, French family life and French economic interests may be French tax resident even while receiving a UK pension.

Once French tax residence is established, Article 750 ter of the General Tax Code is the territorial starting point for French succession tax. It opens: Sont soumis aux droits de mutation à titre gratuit :. The first paragraph can bring worldwide movable and immovable property into the French tax base where the donor or deceased has French tax domicile. A separate rule can apply to worldwide property received by an heir, legatee or trust beneficiary resident in France who has had French tax domicile for at least six of the preceding ten years. If the deceased was not French resident, French-situs assets can still be taxable. Residence of the deceased, residence of the beneficiary and location of the asset must therefore be written as three separate entries in the analysis.

A UK pension is not automatically French-tax-free because it is administered in Britain, and it is not automatically taxed in France merely because the beneficiary lives in France. The classification of the payment, the death-benefit mechanics, the deceased’s domicile, the beneficiary’s domicile and the applicable convention must be reviewed together. A beneficiary who receives a pension death benefit may also face income-tax questions separate from succession tax. The firm’s earlier article on UK pension death benefits for beneficiaries in France covers that broader distinction; this article adds the specific 6 April 2027 IHT change.

France and the UK have a succession convention dated 21 June 1963. The French tax administration lists the current France–UK succession convention among its international agreements, and its BOFiP commentary on double-tax relief explains how the convention allocates the situation of assets and grants relief. That commentary describes the purpose as la suppression des doubles impositions, but relief is not a permission to omit the pension from either country’s analysis. A return can be required even where a credit or exemption ultimately reduces the amount payable.

The convention has its own residence and asset-location rules. The phrase “the pension is in the UK” is not enough to apply them. The advice must identify what right is being transferred, how the UK treats it after the 2027 reform, whether France also taxes the same value, and which state is the domicile state under the convention. The BOFiP commentary says that where France is the domicile state, French law can be applied while the convention’s credit mechanism addresses tax levied by the other state on property regarded as situated there. It also describes a five-year period for a request for reduction or reimbursement under the relevant convention provisions. Keep that deadline on the file, but verify the correct form and starting point for the death in question.

French domestic relief can be generous to a surviving spouse without erasing the UK calculation. Article 796-0 bis of the General Tax Code provides: Sont exonérés de droits de mutation par décès le conjoint survivant et le partenaire lié au défunt par un pacte civil de solidarité. A pacte civil de solidarité, or PACS, is a French civil solidarity pact. This exemption concerns French duties on death. It does not automatically bind HMRC, and a French marriage certificate does not answer whether the UK spouse exemption conditions are met under the IHT regime, including the relevant residence conditions. The surviving spouse’s legal status must be evidenced in both systems.

The converse risk is also real. A spouse may be exempt in the UK for a qualifying transfer while a French child who later receives a benefit faces a different analysis. A civil partner, unmarried partner, stepchild, adult child and trust beneficiary are not interchangeable categories. For French purposes, the relationship to the deceased affects the allowance and rate. Article 777 of the General Tax Code sets the statutory tables for the net share received by each beneficiary, including separate tables for direct-line heirs, spouses and PACS partners, siblings and non-relatives. The table must be read with exemptions and allowances; quoting a rate without identifying the beneficiary can mislead.

French foreign-tax credit rules may help, but they are not self-executing. Article 784 A of the General Tax Code states: Dans les cas définis aux 1° et 3° de l’article 750 ter, le montant des droits de mutation à titre gratuit acquitté, le cas échéant, hors de France est imputable sur l’impôt exigible en France. The same provision limits the credit to the French tax associated with the relevant foreign property. In a UK pension file, “tax paid in Britain” must therefore be tied to the same value and the correct treaty or domestic category. Obtain the UK assessment, payment receipt, calculation and evidence of the pension value before asking for French relief.

The French Supreme Court’s decision in Cour de cassation, First Civil Chamber, 25 May 2016, no. 15-14.737, illustrates why a pension nomination should not be confused with every other death-benefit product. That case concerned French life-insurance contracts and the interaction of their beneficiary mechanics with the matrimonial community. It is not a decision on the 2027 UK pension-IHT reform. Its value here is methodological: identify the legal product, the governing statute and the beneficiary mechanism before borrowing a rule from life insurance, a UK pension, an annuity or a French succession.

Finally, do not mix the income-tax convention with the succession convention. The France–UK double-tax agreement for income may govern a pension paid during life, while the 1963 succession convention and domestic inheritance rules address a transfer on death. The fact that a person’s UK State Pension is reported in France every year does not settle the tax treatment of an unused SIPP at death. The personal representative should open a new succession-tax file instead of copying the annual pension return. For the lifetime income and reporting background, begin with the firm’s lifetime income and reporting overview, then apply the separate death-benefit analysis here.

II. What should a British family do before and after the death?

A. Which nominations, pension records and cross-border tax evidence should be prepared?

The best preparation is a controlled evidence pack that another person can use without guessing. Start with a schedule of every pension: provider, scheme name, member number, country of establishment, registered or qualifying status, money purchase or defined benefit, current value, date last valued, whether benefits have been crystallised, whether a drawdown or annuity is already in payment, and the rules for death. Include former workplace schemes that have been forgotten after a move to France. HMRC’s technical note expects personal representatives to take reasonable steps to identify all schemes, including by reviewing papers, bank accounts, relatives and advisers. A list kept only in the member’s head is not a succession plan.

For each scheme, request the current member booklet and the death-benefit rules. Ask the provider to identify, in writing, whether the arrangement contains a death-in-service element, a continuing annuity, a dependant’s pension, a nominee’s annuity, a discretionary lump sum or a benefit that depends on employment immediately before death. Ask how the administrator will calculate the open-market value at death and what documents it will require from an executor living in France. These questions do not ask the provider to give French legal advice; they create the factual record needed by HMRC, the French notary and the family’s advisers.

Review every beneficiary nomination after a major life event: marriage, divorce, PACS, birth of a child, death of a beneficiary, separation, a move to France or a change in the intended distribution. Save the signed form and the provider’s acknowledgement. If the scheme permits a letter of wishes, keep it with the nomination but do not assume that a letter overrides the rules. Record why a spouse, civil partner, child, trust or charity has been selected. The purpose is not to promise a tax result; it is to avoid a provider finding an old nomination after death and the family discovering that the intended recipient has changed.

Align the pension record with the will, but treat the two as separate instruments. Keep the original or properly executed copy of any UK will, any French will, codicil and revocation, together with the marriage or PACS record and evidence of divorce or dissolution. If a French notary has prepared a testament, explain which pensions are intended to sit outside the estate and provide the scheme details. If a will chooses a law for succession, that choice still needs to be tested against the pension’s own beneficiary provisions and against the tax rules. A will cannot be used as a substitute for a pension nomination form.

Prepare a residence file for both countries. It should contain French tax assessments, income-tax returns, the French tax number, a certificate of French tax residence where available, proof of the French home and principal stay, and a dated record of UK residence. Add evidence of work, family and economic interests where the residence position could be disputed. Under Article 4 B, the French test is not decided by a single utility bill. Under the UK long-term-residence rules, the history of years and status matters. The file should allow an executor to explain why the deceased was or was not treated as long-term UK resident rather than forcing the family to recreate ten years of movements during bereavement.

Keep a financial inventory beyond the pension. List French bank accounts, UK accounts, securities, insurance policies, property, loans, gifts, trusts, business interests, vehicles of material value and liabilities. The purpose is not to publish a private balance sheet; it is to calculate the total estate, apply exemptions, and decide whether cash will be available for tax. A pension can look liquid while the tax falls on the estate, and a property can be valuable without being readily saleable. If the member intends to leave the pension to a non-exempt beneficiary while leaving cash or the French home to someone else, write down that mismatch before it becomes a dispute.

Keep documents proving the family relationship. A British birth certificate, marriage certificate, civil-partnership evidence, French PACS record, divorce order, adoption order and name-change document may all be needed. Foreign documents may require an apostille or sworn translation for a particular authority. Do not wait until the provider has frozen the pension to discover that the surviving spouse’s name differs between the passport, the scheme record and the French marriage certificate. A short discrepancy can delay the payment and complicate the classification of an exempt beneficiary.

Create a treaty-credit file before there is any UK tax to credit. It should have the current text or official commentary for the France–UK succession convention relief mechanism, the UK IHT computation when available, the French succession-tax calculation, payment references, the exchange rate used, and correspondence showing which pension value was taxed in each country. Article 784 A requires a connection between foreign tax paid and the foreign movable or immovable property covered by the French calculation. A bank statement alone may show payment but not that connection.

Plan for liquidity without taking an unreviewed tax gamble. The member should not transfer a pension to a QROPS or withdraw a lump sum simply because someone says that a French residence makes UK IHT disappear. A transfer can raise separate UK and French income-tax, reporting, investment and pension-protection issues. The existing QROPS and French reporting guide addresses that separate decision. Here, the immediate task is to know what the scheme holds, how it will be valued, who will receive it and how the family could fund a tax bill without selling an asset at a bad time.

Give the future personal representative a written instruction sheet. Name each scheme contact, the location of the will, the French notary’s details, the UK adviser’s details, the tax-residence documents and the people who may be beneficiaries. Explain that the personal representative may be an executor or an administrator, and that a prospective personal representative may need to prove authority before a grant of probate or equivalent document is issued. HMRC’s technical note anticipates information exchange before the grant in the new regime. A signed checklist is not a power of attorney after death, but it can prevent the first month from being spent looking for a provider.

Before 6 April 2027, repeat the review against the official guidance then in force. Finance Act 2026 has enacted the reform, but HMRC has said that secondary legislation, evidence requirements, templates and supporting guidance will be updated for implementation. Save the version date of the material consulted. Check whether the provider has changed its death-claim process, whether the member’s residence category has changed, and whether the nomination still reflects the family’s wishes. A review is particularly urgent when the pension is large, the member has lived in several countries, the arrangement is outside the UK, or beneficiaries include a trust or an unmarried partner.

B. How can the personal representative challenge, report or pay a disputed amount?

After the death, the first step is notification, not distribution. Obtain several certified copies of the death certificate as needed, locate the will, identify the executor or person likely to administer the estate, and notify every pension provider. Ask each provider for the date-of-death valuation, the scheme classification, the benefit components, the beneficiary decision or nomination record, and the documents required to release funds. If a scheme asks for a grant before sharing basic information, tell it that the 2027 process is designed to permit information exchange with a personal representative or prospective personal representative before the grant, and ask what evidence of identity and authority it accepts.

The valuation request should be written and dated. HMRC’s technical note says that a scheme administrator should normally provide the value of notional pension property within 28 days of receiving the request; a later estimate should state its basis, followed by the final value when known. The family should ask for the value of benefits going to exempt beneficiaries and the value going to non-exempt beneficiaries separately. Do not accept a single total that makes it impossible to test a spouse exemption, a death-in-service exclusion or a child’s share.

Build two linked ledgers. The first is the UK IHT account: pension values, other assets, liabilities, gifts, residence status, exemptions, reliefs and beneficiary allocations. The second is the French succession-tax file: French residence, French-situs property, worldwide property where Article 750 ter applies, relationship-based relief, the treaty classification and foreign tax credit. Use the date-of-death exchange rate consistently and preserve the source. A value should not be counted twice simply because the pension provider reports in pounds and the French notary reports in euros, and it should not be omitted because it is paid through a scheme rather than through the estate bank account.

If UK IHT may be due, the personal representative should consider the new withholding and payment mechanisms. HMRC’s technical note states that a personal representative can give a withholding notice where IHT may be due. A valid notice can operate from the death until 15 months after the end of the month of death, and it can protect the estate by keeping part of an unpaid benefit available while the calculation is completed. The scheme should be told which benefits are excluded or destined for an exempt beneficiary. The notice is not a finding that tax is due; it is a controlled way of preventing the whole pension being released before the liability is understood.

The optional Pensions Direct Payment Scheme provides another route. A personal representative or beneficiary can give a payment notice for an exact amount of UK IHT and interest, and the administrator can pay HMRC directly from available pension funds. The technical note says that a valid notice is to be paid within 35 days of receipt and that the process can be used before probate. The tax is then deducted from the benefit, so the beneficiary and adviser must also consider any income-tax consequence of receiving the balance. The family should use the official HMRC template and current instructions when they are published; an informal email to a provider is not necessarily a valid payment notice.

Do not assume that the provider will divide the tax in the way the will would divide the estate. HMRC describes the pension beneficiary as jointly and severally liable with the personal representative for IHT attributable to notional pension property once that property has vested, subject to the statutory framework. If a beneficiary receives the pension and the estate has no cash, a dispute can become a personal recovery issue. The personal representative should show every beneficiary the calculation, the proposed withholding or payment, the treatment of exempt shares and the effect on net pension benefits before asking for consent to a practical arrangement.

France has its own filing deadlines. Article 641 of the General Tax Code provides: Les délais pour l’enregistrement des déclarations que les héritiers, donataires ou légataires ont à souscrire des biens à eux échus ou transmis par décès sont : six months from the death where the deceased died in metropolitan France, and one year in other cases. That is a French registration deadline; it is not the UK timetable for an IHT account or pension payment. A British family living in France should ask the French notary to state in writing which deadline applies to the death location and the assets being declared.

The filing is detailed. Article 800 of the General Tax Code states: Les héritiers, légataires ou donataires, leurs tuteurs ou curateurs, sont tenus de souscrire une déclaration détaillée. The declaration must be built from the complete inventory, including the UK pension and evidence explaining its treatment. An apparent exemption does not always remove the need to declare. The statutory exceptions are limited and depend on the value and relationship conditions described in the article. Ask the notary or tax adviser to confirm whether a filing is required rather than relying on the fact that the spouse may owe no French duties.

Payment and disagreement must also be planned. Article 1701 of the General Tax Code says: Les droits des actes et ceux des mutations par décès sont payés avant l’exécution de l’enregistrement. It also says that payment cannot be deferred merely because the taxpayer disputes the amount, subject to a later restitution claim where appropriate. In practice, the family should distinguish a request for more time, a payment arrangement, a formal claim and an appeal. The existence of a dispute should be put in writing, but it should not be treated as an automatic suspension of a statutory payment or filing obligation.

Late compliance can create an avoidable second problem. Article 1727 of the General Tax Code provides: Toute créance de nature fiscale … qui n’a pas été acquittée dans le délai légal donne lieu au versement d’un intérêt de retard. It adds that the interest may be accompanied by the sanctions provided by the Code. For late succession declarations, Article 1728 sets the applicable increases, including a ten-per-cent increase in the circumstances described by the article and later increases after a formal notice. The family should send a complete provisional file with an explanation of any missing UK valuation rather than wait silently until the deadline has passed.

The estate’s liabilities should be evidenced as carefully as the assets. Article 768 of the General Tax Code, available in the official Légifrance section on the deceased’s debts, states that debts are deducted when their existence at the opening of the succession is duly proved. Article 770 in the same section requires requested deductible debts to be itemised in a certified inventory and supported by the relevant deed or judicial decision. A pension-provider charge, a loan, tax debt or expense should not be deducted just because someone remembers it. Keep the invoice, date, creditor, contractual basis and proof of payment or outstanding balance.

If the UK and French figures appear to tax the same pension value, ask for a written reconciliation before accepting that the result is inevitable. The questions should be precise: what pension component is being valued; on what date; who is the beneficiary; is the benefit exempt or excluded; which residence rule applies; what treaty article allocates the asset; what foreign tax has actually been paid; and what French tax is attributable to the same property? Article 784 A and the 1963 convention may support relief, but they do not replace this matching exercise.

A challenge should preserve the evidence without stopping the administration of the estate. Ask the UK provider for its scheme rule, valuation method and beneficiary allocation. Ask HMRC or the UK adviser to identify the legislative basis for treating the pension as notional pension property and to correct any error in the account. Ask the French notary or tax office to explain the Article 750 ter category, the beneficiary rate under Article 777 and the foreign-tax credit calculation. If the answer remains disputed, a French tax lawyer can prepare the appropriate claim or court route, while a UK adviser deals with HMRC. The two procedures should share the same facts and exchange rates.

Do not abandon the file when a pension appears after a clearance or after the French declaration. HMRC’s technical note explains that a newly discovered pension must still be reported, with a corrective account where necessary. A clearance certificate can protect the personal representative in the circumstances set out by the UK process, but it is not a licence to omit an asset found later. On the French side, a corrected declaration and a claim for repayment may be needed. Make a dated note of when the pension was found, what searches were made earlier, and when each authority was notified.

Take a hypothetical death on 20 April 2027. The deceased, a British national living in France, leaves a £550,000 unused UK personal pension, a French bank account, a French home and an adult child as beneficiary. The personal representative should treat the pension as potentially within the new UK regime, request the date-of-death value and test the deceased’s UK residence history. The French notary should map the worldwide and French-situs assets under Article 750 ter, identify the child’s relationship-based position under Article 777, and test any treaty credit under Article 784 A. The figures cannot be calculated from the £550,000 alone.

Change only two facts: the beneficiary is a qualifying surviving spouse, and a substantial part of the pension is an excluded death-in-service benefit. The outcome may be materially different, but the valuation and reporting work does not disappear. Now move the death date to 30 March 2027 while leaving the payment date in May. The new pension rule is not triggered on the facts described by HMRC’s commencement guidance, although other UK or French rules may still apply. A family should therefore record facts first and conclusions second.

Three common shortcuts are unsafe. “I live in France, so the UK cannot tax my pension” ignores the UK residence and scheme rules. “My spouse is named, so nobody needs to declare anything” ignores the difference between UK and French exemptions and the reporting obligations. “The pension provider has paid, so the tax file is finished” ignores date-of-death valuation, later corrections and the French declaration deadline. Each shortcut can produce a late filing, a frozen payment, an incorrect treaty claim or a dispute between beneficiaries. A short written cross-border review before the death is usually less costly than reconstructing the file after it.

Conclusion

For a British resident in France, 6 April 2027 changes the succession planning question for unused UK pension funds. The decisive issues are the date of death, the pension arrangement, the excluded components, the UK long-term-residence category, the beneficiary and the complete estate. French residence does not cancel UK IHT, while a French spouse or PACS exemption does not automatically determine the UK result. France may tax the same value under Article 750 ter, but the France–UK succession convention and Article 784 A can provide a route to relief only after the asset, residence and tax have been matched correctly.

Before the change takes effect, obtain every scheme rule, update nominations, align the wills, preserve residence and family evidence, and plan liquidity. After a death, notify every provider, request date-of-death valuations, keep UK and French ledgers, meet the filing deadlines and challenge a wrong classification in writing. HMRC’s implementation guidance will continue to be updated before April 2027, so the file should record the official version used. A focused review with a lawyer and the relevant notary can turn an uncertain cross-border pension into an evidence-led succession plan.

Need a quick opinion on your case

If you live in France with a UK pension, a cross-border estate or a beneficiary dispute, arrange a telephone consultation within 48 hours with a lawyer from the firm to review the pension documents, residence evidence and urgent filing dates.

Call +33 6 46 60 58 22 or use the firm’s contact page to send the key documents. We assist clients in Paris and Île-de-France as well as British families dealing with French succession procedures from elsewhere in France.