Discussion
In case you didn't know, today is a landmark for any ex-pat living in France. We are now entitled to have our will dealt with under the laws of our native country, not the horrendous Napoleonic code that applies in France. Mine was made in preparation a month or two back, is signed and witnessed, so I just put the date on and posted it.
Amateurish said:
I thought the UK opted out?
Yeah, foreign nationals in the UK can't choose the system of their country of birth, but in the UK they can leave a will that mimics that system if they wish. In France succession law more or less defines who inherits an estate and a will only defines who receives certain things within the settlement: "jewellery to my daughter" for example. France having opted in, means Brits and other foreign nationals here can choose to leave their estate in the same way as they can in their country of birth, in the case of UK nationals. leaving their estate to whom or what they wish. The thing is, as Smiffy says, the French succession tax system favours the French succession law, particularly because allowances cannot be passed between couples here as they can in the UK. Put simply, leave 250 000é equally to your son and daughter - no tax. Leave all of it to one or the other and they pay about 20-25K€ tax. Leave it all to a grandchild and the tax bill will be about 80K......
Steve
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