Inheriting from Ireland: what do I do?

What happens when a French resident of foreign nationality receives an inheritance from Ireland?

Honorary avocat Gerard Barron replies: “The position is simple as there is no Franco-Irish treaty for the avoidance of double death duties. So in these circumstances (Irish resident deceased, French resident beneficiary), the beneficiary must make a French death duties return within 12 months of the death and must pay French duty on everything (including Irish real estate) that he or she receives from the Irish estate, in accordance with ordinary French rules.

In the absence of a treaty, the default rules of article 784A of the Code Général des Impôts allow the beneficiary to deduct Irish duty paid from whatever duty is due in France.

This is not the case with regard to all countries and the position varies depending on the treaties in place – or not. Seek advice from your tax office or a professional if in doubt.