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Assurance vie outside France before arrival in France


lacote0_0

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I am told that if I take out an assurance vie in e.g. Luxembourg before becoming resident in France I can leave all the proceeds when I die without tax, i.e. the payments to the beneficiaries are not subject to the limits which apply with a French assurance vie.

Is this correct? Does anyone know the authority for this position?
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If you affect a European based assurance vie, prior to moving to France, the allowances as per code 990-I of the Code General des Impôts cannot be applied under a European ruling and as outlined in the JO 7 K-1-00. My concern for you regarding this product is that it may not be compliant. I would always advise taking a compliant investment as a future French resident for tax efficiency reasons and ease of administration (a non compliant product can cause real headaches with the tax authorities). What company has been recommended to you?

 

Kate

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Thank you for your most helpful reply.

I agree that it needs to be a French compliant assurance. Some are offered by UK managers, but not only could this give rise to issues in dealing with the Impots, it might also result in a liablity to UK inheritance tax.

At present I am looking at Barclays France (although I am not sure they have a non-French vehicle), Lombard ( Friends Provident), who sell through French-based advisers, Mondiale Europartner, and Cortal Consors (BNP). Do you have any experience of these?

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A French contract in France, has the same advantage, i.e. it gives the same benefits for inheritance tax, though by using a non French contract you can avoid wealth tax on it (if this is an issue for you) for the first five years. I considered you may want an offshore investment just to be able to invest in Sterling and not use Euros just yet, which as far as I know can only be achieved outside France. Barclays France is fine, Lombard is not fine, even though owned by Friends Provident (steer well clear), Friends Provident International is outside the European Union (Isle of Man) so avoid, as this will cause you nightmares. La Mondale Europartner is a very good option, as it is legal in the UK and France (I have one of these, so consider it a recommendation) and Cortal Consors are fine.

Find a good adviser who is happy to give you a good discount as this is often more cost effective than going direct (an adviser may sacrifice his commission to reduce the cost). Make sure they are legal to give advice in France, check http://www.amf-france.org/bio/rech_CIF.aspx?lang=en&Id_Tab=0 type in name of person or company (either will do) in the "nom de CIF" box

If they do not come up, stay clear of them too! If you would like a recommendation, let me know. My adviser put all this detail in a written report for me, which is how I appear to be an insatiable know it all!!

I hope this helps

Kate

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