Inheritance Tax in Europe 2026: France on the Podium at 60%
With a top marginal rate of 60%, France has the third highest inheritance tax rate in Europe, behind Spain and Belgium. Above all, it is the OECD country that collects the most from it: 0.8% of GDP. Meanwhile, eleven European countries no longer tax transfers of wealth at all. A reading of a map that weighs heavily on choices of residence and estate planning.
I. A Europe split in two
Of the 35 countries surveyed by the Tax Foundation (August 2026), 24 tax inheritance or gifts. The other eleven have abolished them, sometimes long ago: Sweden (since 2005), Norway (2014), Austria (2008), Portugal, Estonia, Latvia, Slovakia, Romania, Malta, Cyprus and Georgia. The Czech Republic and Ukraine treat transfers as ordinary income subject to income tax.
Among the countries that do tax, the gaps are considerable:
Spain: 88% (top rate, varies by region)
Belgium: 80% (varies by region)
France: 60%
Denmark: 52%
Germany and Switzerland: 50% (Switzerland: depends on the canton)
Luxembourg: 48%
United Kingdom, Netherlands, Greece: 40%
Finland and Ireland: 33%
Turkey 30%, Poland 20%, Hungary 18%, Iceland and Lithuania 10%, Italy 8%, Bulgaria 7%, Croatia 4%
These are top rates across all categories of heirs, usually reserved for distant or unrelated heirs. In the direct line, France caps at 45%; Germany at 30%; Italy applies 4% after a €1 million allowance per heir.
II. Why does France weigh so heavily?
The marginal rate does not explain everything. Three factors make France the OECD’s top collector of transfer taxes, at 0.8% of GDP against an average of around 0.1%:
Modest allowances
The direct-line allowance is €100,000 per parent and per child, renewable every fifteen years, unchanged since 2012. The progressive scale reaches 20% from €15,932 of taxable share above the allowance, and 45% above €1,805,677. Germany grants €400,000 per child, Italy €1m.
Harsh treatment outside the direct line
Between siblings, the rate is 35% then 45% after a €15,932 allowance. Between relatives beyond the fourth degree and between unrelated persons — including an unmarried partner or a civil partner without a will — a single rate of 60% applies after a €1,594 allowance. This is the rate that puts France on the European podium.
A broad tax base
French residents are taxed on their worldwide estate; non-residents on their French-situs assets; and an heir domiciled in France for six of the last ten years is taxable on what he receives, wherever the assets and the deceased are located (Article 750 ter of the French Tax Code). Few countries go this far.
France 2026 at a glance Direct line: €100,000 allowance per parent and per child, rates from 5% to 45% Spouse and civil partner (PACS): full exemption from inheritance tax Siblings: 35% / 45% after €15,932 Unrelated persons: 60% after €1,594 Life insurance: €152,500 per beneficiary for premiums paid before age 70, then 20% / 31.25% (Article 990 I CGI)
III. The Franco-Swiss case
Switzerland appears on the map at 50%, but this figure hides a far more favourable reality: inheritance tax is cantonal, and almost every canton fully exempts the spouse and descendants in the direct line. Geneva and Vaud tax neither the spouse nor the children (subject, in Geneva, to the case of deceased persons taxed on a lump-sum basis). The 50% rate only concerns transfers between unrelated persons in certain cantons.
The difficulty lies in the absence of a treaty: the 1953 France–Switzerland inheritance tax treaty was terminated by France with effect from 1 January 2015. Since then, each State applies its domestic law, with a real risk of double taxation, mitigated only by the credit provided for in Article 784 A CGI for assets located outside France.
In practice, a Geneva resident whose children have lived in France for more than six years will pass on his worldwide estate under the French scale — up to 45% in the direct line — whereas Geneva would have levied nothing. Conversely, a French resident owning real estate in Switzerland will be taxed in France on that property, with a credit for any cantonal tax paid. The residence of the heirs matters as much as that of the deceased (see also our article on the law applicable to international successions).
IV. What this means for estate planning
Plan ahead with gifts
The renewal of allowances every fifteen years and the reservation of usufruct (scale of Article 669 CGI) make it possible to transfer wealth at lower cost during one’s lifetime. A gift at age 60 with reserved usufruct is taxed on only 50% of the value of the assets.
Protect an unmarried or civil partner
The 60% rate hits the unmarried partner; the civil partner (PACS) is exempt only if there is a will. Life insurance, a tontine clause or marriage radically change the outcome.
Measure the effect of a change of residence
Leaving is not enough: the six-out-of-ten-years rule applies to heirs, and French real estate remains taxable in France whatever happens. A move to Switzerland or Portugal must be thought through for the whole family, and over time.
Watch the legislative calendar
Transfer taxation is one of the most divisive issues of the 2027 French presidential campaign, between a higher direct-line allowance on one side and heavier taxation of large estates on the other. Major operations are best carried out under known law.
V. Conclusion
The European inheritance tax map says two things: France taxes heavily, and it taxes broadly. But the 60% that puts it on the podium only concerns transfers outside the close family; in the direct line, anticipation — staggered gifts, dismemberment of ownership, life insurance — usually brings the bill far below the headline rate. For Franco-Swiss families, the absence of a treaty requires a case-by-case analysis, starting from each person’s residence. After dividends, this is the second European ranking this autumn in which France sits near the top.
This article is also available in French: L’héritage taxé en Europe : la France sur le podium.
Frequently asked questions
Will my spouse pay French inheritance tax?
No. The surviving spouse and the civil partner (PACS) have been fully exempt from French inheritance tax since 2007. The civil partner must however be named as legatee in a will, as he or she is not a legal heir. An unmarried partner is taxed at 60% after a €1,594 allowance.
I live in Geneva and my children live in France: what will happen?
If your children have been domiciled in France for at least six of the ten years preceding your death, they will be taxable in France on all assets received, in Switzerland or elsewhere, at the direct-line rates (up to 45%), with a credit for any Swiss tax. Geneva, for its part, will not tax the transfer to descendants.
Does the 60% rate apply to my children?
No. In the direct line, rates range from 5% to 45% after a €100,000 allowance per parent and per child. The 60% rate only applies to transfers between unrelated persons or relatives beyond the fourth degree.
Does the France–Switzerland treaty protect against double taxation?
Not since 1 January 2015, when France’s termination of the 1953 treaty took effect. Only the foreign tax credit of Article 784 A CGI remains, and it applies only to assets located outside France.
Is it better to give now or wait?
Each gift uses up the €100,000 allowance, which is restored after fifteen years. Giving early, in bare ownership, provides a reduced tax base and several allowance cycles. The answer nevertheless depends on the donor’s age, the nature of the assets and the recipients’ situation: a simulation is essential.
Are French assets taxed if neither the deceased nor the heirs live in France?
Yes. Real estate and other assets located in France remain subject to French inheritance tax whatever the residence of the deceased and the heirs, subject to any applicable tax treaty. France has inheritance treaties with only a limited number of countries.
Sources: Tax Foundation, “Estate, Inheritance and Gift Taxes in Europe”, August 2026; OECD Revenue Statistics, 2023 data; Articles 669, 750 ter, 777, 779, 784 A, 790 G and 990 I of the French Tax Code (CGI).
Eve d'Onorio di Méo
Avocat Spécialiste en Droit Fiscal
Barreau de Marseille et Genève (Avocat UE/AELE)
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