The tax treatment of an international succession varies depending on whether or not there is a tax treaty between the countries concerned.
The main purpose of tax treaties is to fix the distribution between the states of the elements that they can tax and to limit situations of double taxation.
In the absence of a tax treaty, the risk is the application of taxation by each of the countries concerned.
Inheritance rights agreements exist in particular with: Germany, Algeria, Saudi Arabia, Austria, Bahrain, Benin, Burkina-Faso, Cameroon, Canada, Central African Republic, Congo, Ivory Coast, United Arab Emirates, Spain, States States, Finland, Gabon, Guinea, Italy, Kuwait, Lebanon, Mali, Morocco, Mauritania, Monaco, Niger, New Caledonia, Oman, Portugal, Qatar, United Kingdom, Saint-Pierre-et-Miquelon, Senegal, Sweden , Togo, Tunisia.
Declarations
When France has the right to subject all or part of the estate to transfer duties free of charge in application of domestic law or conventional law, it is necessary to file a declaration of succession in France.
Tax allowances are applicable regardless of the country of residence of the deceased or the heirs.
The reductions are the same as for residents of France for heirs with French nationality or that of a Member State of the European Union as well as Norway and Iceland or nationals of a State with which there is a reciprocity (non-discrimination or equal treatment clause).
The forms to use are those: Cerfa n°2705 – Cerfa n°2706 – Cerfa n°2705-S
Form n°2740 is to be used for the application of the tax credit of article 784 A of the CGI.
From www.joptimiz.comonline tax assistance
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