French Estate Planning 

We help you plan thoughtfully and comprehensively, covering: 

• Matrimonial Regimes
  We explain which French matrimonial regime applies (how property/wealth is divided during marriage and on death), how to change it if possible, and how this impacts your estate planning.
  

• French Wills / Donation entre époux
  Advising whether you need a formal French Will (or handwritten holographic Will), whether a donation entre époux (a gift between spouses effective on death) makes sense, bearing in mind forced heirship rules.
  

• Choice of Law under Brussels IV (European Succession Regulation)
  Electing the law of your nationality (e.g. English law) to govern your whole estate, which can increase testamentary freedom; used correctly, this can simplify administration and help achieve your objectives.

• Forced Heirship (réserve héréditaire)
  Understanding who has entitlement under French forced heirship rulesand exploring legal strategies (e.g. using SCI, tontine clauses, matrimonial regime choice) to reduce unintended consequences.
  

• French Inheritance Tax
  Assessment of your exposure: what assets are taxable in France vs UK; how double taxation treaties apply; projecting tax under different scenarios; understanding rates, allowances, and responsibilities.

• Lifetime Gifting (Donations)
  Guidance on gifts of property or other assets during your lifetime, including options retaining usufruit (life interest), and implications in both France and the UK (e.g. UK gift rules, potential tax liabilities).
  

• Trusts (Lifetime or Testamentary)
  Although Trusts are a key tool in English law, they bring strong reporting and tax consequences in France. We assess whether a trust or trust-alternative may be more suitable, and how to structure things so your goals are met without unexpected burdens.
  

FAQs

Do I need a French Will if I already have an English Will?

Sometimes, yes. An English Will may be valid in France but may not address French inheritance laws, forced heirship, or produce the outcome you expect. We advise when a separate French Will makes sense, or how to draft one that works alongside your UK Will.

What is a donation entre époux?

A legal deed between spouses under French law, giving certain benefits to the surviving spouse after death. It is effective only at death. But its usefulness may be limited in cross-border situations depending on nationality, children, and forced heirship rules.

Can I choose that English law applies to my French assets?

Yes, under the European Succession Regulation (Brussels IV) you can elect the law of your nationality. This often allows greater freedom of testamentary disposition. However, there can still be French tax or procedural implications, so expert advice is essential.

How does forced heirship work in France?

French law reserves a fixed portion of your estate for close heirs (usually children, sometimes spouse), which cannot be overridden by Will. There are legal mechanisms to mitigate impact (e.g. certain lifetime gifts, using SCI, choosing a different matrimonial regime, or using Brussels IV where allowed).