good news for couples

 

private client image

 

 

French Property News, November 2007

 

A new bill will have a positive effect on inheritance, regardless of couples' marital position.

 

It seems that not everyone in France was relaxing this summer. The Palais Bourbon didn't close at the end of June for its traditional summer break. The French Parliament was also still at work. On 21 August 2007 it voted on a bill known as TEPA which introduces various tax incentives and which will have a significant impact on UK buyers or property owners in France.

 

equal partners

 

A major improvement has been made for couples, whether married or not. Couples in a long-term relationship who entered into a French pacte de solidarite (or UK civil partnership) will be allowed to leave assets to the surviving spouse/partner without being subject to any French inheritance tax.

 

Estates subject to French inheritance tax will be exempt from French death duties when the beneficiary is the surviving spouse/partner. (The PACS is an agreement registered through the local civil court between long-term partners of the same sex or not). The reversion of the French life interest (i.e. usufuit) will also be tax exempt between spouses or partners.

 

Despite these new measures, people investing in France still need to find out which structure (eg in one name or both names, as individuals or through a company, with a tontine, a marriage contract or en indivision, with an usufruit or a droit d'usage ou d'habitation) is the most appropriate for their personal circumstances. It remains essential to get advice before completion in France, as modifying the title deed might prove to be expensive if still possible at a later date.

 

Those who want to take advantage of these new measures should adapt or vary their current titles or review their wills. The signing of a French marriage contract still bears significant advantages to those wishing to circumvent the impact of the French statutory rules of inheritance and prepare the settlement of their estate.

 

an end to sibling rivalry

 

The position has also changed between siblings. In some cases a full inheritance tax exemption will apply between siblings who have been living together. Otherwise the inheritance or tax-free gift thresholds between siblings has increased from €5,000 to €15,000.

 

life insurance bonds

 

The 20% tax applicable on death to sums paid to the beneficiaries in execution of life insurance bonds (assurances-Vie) will be cancelled where the beneficiary is the surviving spouse or partner. As in the UK, the inheritance tax-free thresholds and the tax bands will be indexed annually.  The first indexation will start on 1 January 2008.

 

tax thresholds for gifts

 

The inheritance or tax-free gift thresholds between parents and children will increase from €50,000 to €150,000 per parent per child, whereas the general tax-free threshold against the overall estate (ie €50,000) has been cancelled.

 

The tax-free gifts threshold to nephews or nieces is now €7,500. Gift tax between partners who signed a PACS agreement is the same as spouses.

 

Cash gifted to family members will be tax exempt up to €30,000 where the donee is a child, a grandchild, a great-grandchild or a nephew/niece in the absence of direct heirs. The donor needs to be less than 65 years old and the donee over 18 (subject to conditions).

 

These rules will apply from 22 August and will expand the possibilities of tax and estate planning concerning French assets. This should be considered at the time of purchase and when French wills are drafted.

 

 

For more information, please contact Christophe Dutertre in Blake Lapthorn's French Private Assets and Tax team on  023 9253 0379; email christophe.dutertre@bllaw.co.uk.