International inheritance tax

The particular situation of international successions creates special issues at the interface between the rules of international civil law and the tax rules of 2 or more States.

It is therefore necessary to determine the reporting obligations and applicable tax resulting from a cross-border gift or inheritance according to your nationality, matrimonial property regime and applicable inheritance devolution rules, as well as your tax domicile and, in the most complex cases, according to the international tax treaty.

AlterTax Avocats, in partnership with various notary offices, deals with all the legal and tax rules governing international successions, in order to resolve any double taxation situations that may arise in the course of such successions.

AlterTax is a recognized expert in international taxation. With over 25 years’ experience in international tax matters with major international law firms, we can advise you on optimizing your estate’s tax position and developing a real estate strategy.

In view of the highly complex framework of international successions, and the legal technicalities involved, it’s a good idea to surround yourself with tax lawyers who are experts in this field.

The complex paths of taxation are not a problem for us.
Gain peace of mind with experts, plan your strategy!

Our various services as an international inheritance tax lawyer

Our firm of international inheritance tax lawyers also offers advice in other tax matters

01.

Tax lawyer

As a
tax lawyers
we offer in-depth legal advice to effectively manage your tax liabilities and entitlements. Our expertise extends to all aspects of taxation, ensuring a comprehensive approach.

02.

Tax advice

We offer
tax advice
aimed at optimizing your tax situation while complying with current regulations. Our aim is to help you navigate the complex tax landscape with confidence and clarity.

03.

Tax audit lawyer

As a
tax auditors
our team offers expert representation to defend your interests. We intervene at every stage of the process to minimize the risks and potential impact on your financial situation.

04.

International tax lawyer

Our expertise as
international tax lawyer
can help you meet the tax challenges of cross-border operations. We provide legal advice on navigating complex tax regulations.

05.

i

Tax litigation lawyer

As a
specialized in tax litigation
we represent and defend your interests in tax disputes. Our approach is aimed at resolving disputes with the tax authorities effectively, with priority given to amicable solutions or representation before the courts.

06.

Wealth lawyer

We offer legal expertise in wealth
wealth management as a lawyer
with an emphasis on real estate taxation. We help our customers optimize the tax impact of their real estate assets, whether for management, acquisition or transfer.

AlterTax Avocats’ expertise in international inheritance taxation

  • Setting up inheritance strategies (gradual and residual gifts, and transgenerational shared gifts)
  • Assisting international families with their inheritance strategy, enabling them to anticipate tax burdens and provide useful advice to non-residents on the implementation of effective testamentary arrangements.
  • Constraints and “compliant” use of trusts and life insurance
  • Settlement of the estate in accordance with applicable international tax treaties.
  • The formalities for declaring the estate to the French tax authorities, as well as abroad.
  • Adjustment of the estate settlement, taking into account the value of the estate and the taxes due (IFI).
  • Applications to the tax authorities for the payment of inheritance tax (split or deferred).

Support for the settlement of a conflictual estate and the implementation of its division, including the sale of real estate assets, the closing of bank accounts, etc.

Cyril Maucour, tax lawyer with AlterTax

Cyril Maucour,
AlterTax tax lawyer

International inheritance tax FAQ

Here are some frequently asked questions about international inheritance tax:

What is an international estate?

An international succession concerns the transfer of assets after death when the deceased had assets in more than one country, or was resident in a country other than that of his or her nationality.

How are international successions taxed?

Taxation depends on the tax laws of the countries concerned. Some countries tax on the basis of the deceased’s place of residence, others on the basis of the location of the assets. Tax rates and rules vary considerably.

What assets are involved in an international estate?

All types of assets can be involved: real estate, bank accounts, investments, and personal property. The location and nature of the assets influence their tax treatment.

Are there any tax treaties for international successions?

Yes, some countries have double taxation avoidance agreements. These agreements determine which country has the right to tax which goods.

How to deal with double taxation in international inheritance cases?

Double taxation can be mitigated by tax credits, deductions or tax treaties. It’s important to consult an international tax expert when navigating these rules.

What impact do residence and nationality have on international successions?

The residence and nationality of the deceased may influence the competent jurisdiction for taxation. Some countries tax on a global basis, while others focus solely on goods located within their borders.

How are debts handled in an international estate?

The deceased’s debts are generally deducted from the value of the estate before taxation. However, the rules vary from country to country and can be complex if the debts are located in different countries.

Can pre-death gifts influence international succession?

Yes, in many countries, gifts made before death can be taken into account to reduce inheritance tax, but the specific rules vary.

How important is international estate planning?

Effective planning can help minimize the tax burden, avoid litigation and ensure that assets are properly distributed according to the deceased’s wishes.

Where can I get help with an international estate?

It is advisable to consult lawyers specializing in international inheritance law, tax specialists and financial advisors experienced in cross-border inheritance matters.

Your tax lawyer for managers and family groups, anywhere in France

AlterTax offers its services throughout France. Whether your tax needs are centered on Paris, or national and international, our team is ready to provide top-level tax expertise.