01Applicable law
Which law decides who gets what
- The testator lives in an EU country (France). Under the common European rules the whole estate is governed by that country's law — wherever the assets are.
Succession: France → France
What happens to the estate
Case complexity: low. The testator resides in France, the heir resides in France.
Testator
Citizen of France
Resident of France — the centre of life.
Heir
Resident of France
The estate stays in one jurisdiction — a simpler process.
02Forced heirship
Who the law forces you to include
- France: Réserve héréditaire — a strict regime: ½/⅔/¾ to children (1/2/3+), an in-rem share; since 2021 the droit de prélèvement limits bypassing it via professio juris.
- A workable route: choose the applicable law in the will in advance and/or move assets into a structure (foundation, trust, holding) where shares are inherited rather than the assets themselves.
03Tax
Where tax arises
- France: Droits de succession — progressive; reliefs for close relatives, rates up to 60% for distant / non-direct heirs.
04Recognition
How it is recognised and processed
- Within the EU there is a single document — the European Certificate of Succession: it is recognised across all EU states except Denmark and Ireland, with no need to go through the procedure in each one.
05What to set up
What to set up in advance
Key risk
Part of the estate is reserved by France law for close relatives — it cannot be freely reallocated by will.
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This is general guidance, not legal advice. The rules are simplified; confirm current rates and details with a lawyer.
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