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Or this


Or this


They all stress that you have to declare it within 12 months of the death occurring.

Will we still have a double taxation agreement after Brexit? Who knows...

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 I wouldn't  have thought that the international taxation agreements would have been affected by leaving the EU. I thought that international tax agreements were something quite different.

One of the lists I have covers an awful lot of the world's countries who have agreements with France, and why would the UK be any different to say : the USA or Iran ???

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Brexit won't effect tax treaties because they are not negotiated via the EU. Tax treaties between EU countries and beyond are negotiated on a one (country) to one basis not between a none EU country and the EU.

I made an assumption earlier that the two countries in question were the UK and France which may not be the case so I removed the rest of my post.
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Then I would suggest.


If you move up a page then look under "G" for Germany you will see there are far more documents.

This is because unfortunately one cap does not fit all and tax treaties with different countries can cover more or less than say France. The treaty the UK has with Germany is much bigger and includes commercial bank tax for example (amongst others).

What you really have to do is find out the actual tax rates in each country then declare in the country in which you pay the least tax. You also have to understand how normal tax is calculated in that country.

As an example. I sold a house that belonged to my dad in the UK for lets say £100,000. I am not tax resident in the UK therefore have paid no income tax. HMRC considered that the one of payment fell within one week and therefore is one weeks salary/wage so they multiplied it by 52 which took the amount into the 45% tax bracket when it should have been in the 40% bracket. Normally I would have to wait till the end of the tax year then they would recalculate and give me back the overpayment. If you do the transaction in March it's not so bad but if it were May you would wait a 11 months for the money.

So what I had to do is pay (actually they just took it at source) the 45% tax in the UK then claim it back. I got a form printed off from the HMRC website, one part in English the other in German which I filled in. I then took it to my local tax office who stamped it and I posted the English bit back to the UK. I then got a check from HMRC for 45k which arrived about two weeks later. I then sent a copy of the check plus the German part to my local tax office who then charged me CGT in Germany which is only 10% on inheritance. Happy days.

If however CGT in France is more than the percentage of the tax band in which the amount in the UK falls it may be worth your while paying the tax in the UK, declare the money if you want to the French tax office and attach proof you paid the tax in the UK.
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  • 2 weeks later...
[quote user="woolybanana"]Thank you everyone.

CT, it is UK and France.[/quote]

    According to the  estates tax double tax treaty of 1963 (see link), no tax is due on a french resident receiving an inheritance from someone who has died UK resident;  so there is no requirement to declare it anywhere in France.


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