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Succession planning in France can highlight cultural differences
Partner article: Robert Kent of Kentingtons explains why some expatriates are surprised by the French approach to inheritance
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Where do we pay house inheritance tax in France?
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Key financial steps to take after the death of family member in France
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Will UK will still apply in France?
My wife and I have lived in France for nine years. When in England we had a will giving inheritance to the survivor and then in equal shares to our two daughters in the UK. We have not made any arrangements in France to adopt English inheritance. Could you explain what would happen if one of us died?
If one of you was to die at present then French law would apply to the estate with the usual rules of reserved portions for children.
One option would be to make a new will in which you make an explicit choice of English law. This could be a French will and you would probably want to revoke the previous one, but you would be best advised to speak to a notaire with experience in international matters.
However notaire François Trémosa said he would advise against choosing a different law when there are options available under French law. He said if you wish that the surviving spouse becomes the sole owner, it is possible to do so via a change in your marriage contract by adopting the communauté universelle avec attribution au survivant and your daughters will inherit afterwards.
