Estate Planning in France (UK Nationals)
France is the jurisdiction where the gap between UK and local succession law is widest — and where getting it wrong has the most concrete consequences. French forced-heirship reserves a fixed share of the estate for children and overrides almost any contrary intention. UK Inheritance Tax sits on top, on the same assets. Two systems, one estate, almost no overlap.
France does not let you decide who inherits
Reserved heirship in France gives children a guaranteed slice of the estate — half if there is one child, two-thirds between two, three-quarters between three or more. A 2021 reform extended that protection even where foreign law was elected. The English-law election still works for many clients, but the safety margin has narrowed.
If you own a French property and die intestate or under default French rules, your children inherit the réserve héréditaire whether you want them to or not. A surviving spouse takes only the disposable quotité. For blended families, second marriages and any client who wants to leave a different proportion to the surviving partner, this is the planning question.
Brussels IV (EU Regulation 650/2012) still permits a British national to elect English law for succession in France in most cases — but the 2021 French reform allows reserved heirs resident in the EU to claim a compensating share against EU-located assets where they would have inherited more under French law. The election is no longer a complete shield. It is a planning tool that needs to be used with care.
On the UK side, your worldwide estate remains inside the UK IHT net for as long as you are UK-domiciled. The UK-France double-taxation treaty on inheritance does provide some relief — France is one of the few jurisdictions where this exists — but it does not eliminate the planning question. From April 2027 unused UK pensions enter the UK IHT estate, which changes the position again.
The English-law election after 2021
For most clients an English-law election under Brussels IV remains worth making — it gives the cleanest route to leaving your French property as you intend. But the 2021 reform means a reserved heir resident in the EU can, in defined circumstances, claim a compensating share. We draft the will to make the election explicit and coordinate with French counsel where the family situation makes a claim plausible.
Tontine, communauté universelle and SCI
Three French structures we look at regularly. A tontine clause on the property purchase can pass the whole property to the survivor outside succession. A communauté universelle marriage regime achieves a similar result for spouses. An SCI (Société Civile Immobilière) holds the property as company shares and can simplify both succession and lifetime gifting. None of these is right for every client. All need to be considered together with the UK-side plan.
Stepchildren — the hard case
French succession tax on transfers to non-blood beneficiaries is brutal — 60% above a small allowance for stepchildren and unmarried partners. A second spouse leaving the French house to a stepchild, with no planning, can produce a tax bill that exceeds half the property value. This is the case where planning is not optional.
Where we typically come in
English Wills with Brussels IV election
Drafted to elect English law and coordinated with your French notaire so the English and French documents work together.
Read more →UK Inheritance Tax Planning
The UK-France treaty helps but does not remove the planning need. We model the position under the 2027 pension change and across both jurisdictions.
Read more →Lasting Power of Attorney
An English LPA covers your UK assets and decisions. A French mandat de protection future covers the French side. Both are needed; neither replaces the other.
Read more →Property Trusts (UK)
Where UK property is retained — let or kept for visits — a Property Trust on the UK will protects against UK care-fee assessment and unintended onward transfer.
Read more →What we'd actually do for you
A first call is free and by video. We read what you have — English will, French will, property deeds, marriage regime, pension paperwork — and tell you what currently happens on death. From there we draft the English-side documents and coordinate with your notaire on the French side. Most clients need both wills rewritten and a clear written record of which assets each one governs.
Complete the Discovery first - then we'll book your free 30-minute consultation.
Common questions from clients in France
I have a French will from the notaire — does it revoke my English will?
It depends on how it is drafted. A poorly drafted later French will can revoke an earlier English will in full, leaving the UK estate to pass under intestacy. A properly drafted pair of wills — each limited to its own jurisdiction — coexists cleanly. We read both and tell you which you currently have.
Can I still leave my French house to my surviving spouse instead of my children?
Often yes, with planning — through an English-law election, a tontine clause on the property, a change of marriage regime, or an SCI structure. The right answer depends on whether the children are minors or adults, in the UK or the EU, and on the value of the property. There is rarely a single answer.
Does the UK-France inheritance tax treaty mean I won't pay UK IHT?
It allocates taxing rights between the two countries and provides some credit relief, but it does not eliminate UK IHT for a UK-domiciled person on their worldwide estate. The treaty narrows double taxation; it does not replace planning.
Do I need to come to your office to work with you?
No. We work nationally — and increasingly internationally. Most of our clients in France are seen by video call, with documents signed remotely or couriered when wet signatures are needed. The advice is the same. The convenience is yours.
Is Sean Kiani regulated?
Sean Kiani is a member of the Society of Will Writers and holds full Professional Indemnity Insurance. Estate planning is unregulated in the UK — which is precisely why credentials, supervision and indemnity matter.
What does a first conversation cost?
Nothing. A first call is free, confidential, and exists for one purpose: to find out whether your current arrangements still do what you think they do. If they do, we'll tell you. If they don't, you'll know exactly what's exposed and what to do about it.
Your 30 minutes. Simple. Yours.
No-obligation.
The path is simple: complete the Discovery first so we walk into the call already knowing the facts. Then in 30 focused minutes, I listen, answer your questions, and you choose if you'd like us to draw up your Inheritance Plan.
1. Start Your Discovery
Required first step. Complete the confidential financial position review so your no-obligation 30-minute consultation starts with the facts, not the basics.
2. Request a Callback
Prefer to speak first? Leave your details and we'll call you back to talk through the Discovery before you complete it.
You choose the date, time, and format - phone or online. Bring anyone you'd like.