01Applicable law
Which law decides who gets what
- Under United Kingdom rules, money, accounts and shares are inherited by the law of the country where the person lived, while real estate follows the law of the country where it physically sits.
Succession: United Kingdom → France
What happens to the estate
Case complexity: low. The testator resides in United Kingdom, the heir resides in France.
Testator
Citizen of United Kingdom
Resident of United Kingdom — 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
- United Kingdom: Testamentary freedom; dependants may challenge inadequate provision under the Inheritance (Provision for Family and Dependants) Act 1975.
03Tax
Where tax arises
- United Kingdom: IHT 40% above the nil-rate band (£325k). From 6 April 2025 — residence-based: a long-term resident (10 of the last 20 years) is taxed on worldwide assets; a 3–10 year "tail" applies after leaving.
04Recognition
How it is recognised and processed
- Testator and heir in different countries — documents will need cross-jurisdiction recognition and legalisation (apostille, translation, sometimes a repeat procedure).
05What to set up
What to set up in advance
← Check your own case in the interactive navigator
This is general guidance, not legal advice. The rules are simplified; confirm current rates and details with a lawyer.
Contact information
If you have questions or need a consultation, our experts will be glad to help.