French tax payable on a uk inheritance

[SC]

I don't think that anyone's mentioned that Nicolas Sarkozy has said that he wants to abolish succession taxes. Of course, he's said a lot of things, but this seems eminently sensible to me[:)].

Article here on an anti Sarkozy website:  http://vandepj0.free.fr/spip.php?article24

Steve

[Gyn_Paul]

[quote user="Sc"]

I don't think that anyone's mentioned that Nicolas Sarkozy has said

that he wants to abolish succession taxes. Of course, he's said a lot

of things, but this seems eminently sensible to me[:)].

Article here on an anti Sarkozy website:  http://vandepj0.free.fr/spip.php?article24

Steve

[/quote]

Yea.. about as likely as lowering the VAT for restauranteurs  as his predicessor promised, I seem to recall !

pl

[TreizeVents]

[quote user="Sc"]

I don't think that anyone's mentioned that Nicolas Sarkozy has said that he wants to abolish succession taxes. Of course, he's said a lot of things, but this seems eminently sensible to me[:)].

Article here on an anti Sarkozy website:  http://vandepj0.free.fr/spip.php?article24

Steve

[/quote]

Well, you fooled me with this post.  I have no idea what you mean.  Do you really mean that not taxing the rich is a good idea, or does the smiley mean you are kidding.  Can you explain?

From the article you cited:

"On peut conclure que cette mesure qui permettrait de "laisser le produit d’une vie de travail à ses enfants"

ne touche réellement que moins de 10% des ménages. Cette mesure

favorise par conséquent de façon manifeste les plus riches, dont les

amis et soutiens de Monsieur Sarkozy. Nicolas Sarkozy est magicien, il

sait transformer un clientélisme éhonté en une mesure populaire."

[SC]

An only child long-term resident in France inheriting more than 100,000€ pays rights of succession, at over 115,000€ the rate is 20%. This is as good as it gets, the more children or the more distant the beneficiary the lower the level per beneficiary that taxes kick in. The levels and rates are shown here:

http://www.bnpparibas.net/banque/portail/particulier/Fiche?type=fiche&identifiant=Calculer_ses_droits_de_succession_20021010135112

My smiley meant that yes, I think that it's a good idea to abolish succession taxes on single children who inherit say an average house in the UK or indeed France, and that might include me [:)] and others who are reading this. Sorry if it wasn't clear that I was just smiling. 

I don't take the conclusions on the anti-Sarkozy website too seriously any more than I do Sarkozy's promises, however I can but hope.

I do think that its bit rich for the French to tax a French resident on inheriting UK estate, and a UK resident on inheriting French estate.

Taxing the rich doesn't affect me because I'm not in that group, and if I was I'd probably move elsewhere, as they do.

Steve

[TreizeVents]

Thanks for the site.  That is just what I needed.  Inheritance tax is a very intriguing topic.  It does allow those with wealth to continue to keep it in the family.  So families that have it, keep it.  As to the level of what is "rich" and waht the values of houses are and so forth, its all fun to argue about.   But not me, not here.

[SC]

An article by Bill Blevins in French News recently stated that French residents would not pay tax on an inheritance from the UK. I sent the editor a message with a link to the French government web page mentioned earlier in the post. The reply was follows:

The page quoted from the www.impots.gouv.fr website makes no mention of the impact of double tax agreements (DTAs - conventions internationales ).  DTAs override domestic legislation. There is some conflict between the UK and French inheritance tax systems, because the UK taxes the estate of the deceased whereas France taxes the beneficiary. However, Clause 5(2) of the inheritance taxes convention of 1963 between the UK and France makes it very clear that:

 

“Where a person was at the time of his death domiciled in some part of Great Britain duty shall not be imposed in France on any property not situated in France, and in determining the amount or rate of duty payable on a property which is chargeable in France, any property not situated in France shall be disregarded”.

 

The agreement also extends to Northern Ireland. 'Property' means assets. 'Domicile' has different meanings in the UK and France and where there is any doubt about the deceased's domicile for the purposes of the DTA, it is defined along normal tax residence lines. So, in practical terms where a deceased individual died tax resident in the UK, there can be no French inheritance tax (succession tax) except on French-situated assets (which would normally just be French real estate and shares in French-incorporated companies that the deceased had owned).  

 

Steve