Double taxation France-Ireland inheritance tax

mcfrenchie

Hello,

I am an Irish national living as a French resident in France. I am wondering what the laws are in regards to double taxation on inheritance tax. Do I have to pay tax in France on an inheritance from Ireland? And if this is the case, are there any legal loopholes?
Thanks very much for any help/suggestions.

McFrenchie

namenotavailablE

The scope of this request is beyond what the forum can answer as it likely involves rules concerning issues such as territoriality and tax residence. You're likely to be advised by a moderator to seek professional advice.

In general, as a very general pointer, you may need to research 'Double Taxation agreements' but primarily be prepared to seek professional advice.

mcfrenchie

OK thanks for letting me know that. Was a long shot but haven't been able to find anything either through searches or the revenue website. Will try get some professional advice next time I'm back.

namenotavailablE

You've probably already got this link but just in case you can do a bit of preparation : http://www.revenue.ie/en/practitioner/law/double/france.html

nompere

namenotavailabl wrote: »

You've probably already got this link but just in case you can do a bit of preparation : http://www.revenue.ie/en/practitioner/law/double/france.html

This treaty doesn't actually apply to inheritance tax. Article 1 lists the taxes that it does apply to, and as it was signed 45 years ago, that list is pretty short.

MD1983

Ireland only has tax treaties covering inheritance tax with the US and the UK

You need tax advice in both Ireland and France, it may work best if you choose a firm with offices in both jurisdictions to help you although it is mainly the bigger firms that have that presence

http://www.revenue.ie/en/practitioner/law/notes-for-guidance/cat/cat-act-guidance-notes-2013.pdf

read section 11 of this guide and it pretty much tells you what will be subject to tax in ireland

mcfrenchie

Thanks MD, looks like it's way more complicated than I initially thought! Not a fan of double taxation but that's good advice re a firm that operates in both countries.

MD1983 wrote: »

Ireland only has tax treaties covering inheritance tax with the US and the UK

You need tax advice in both Ireland and France, it may work best if you choose a firm with offices in both jurisdictions to help you although it is mainly the bigger firms that have that presence

http://www.revenue.ie/en/practitioner/law/notes-for-guidance/cat/cat-act-guidance-notes-2013.pdf

read section 11 of this guide and it pretty much tells you what will be subject to tax in ireland