Cross-border succession law · France
Someone you love has died,with property in France.We handle everything.
English & Irish solicitor · for inheritance in France
Losing someone is hard enough without a foreign legal system and in another language. We take care of the whole French side for you — your own lawyer alongside the notaire, remotely, under a power of attorney, so you never need to travel — for a fixed fee agreed before we start. Every matter is signed off personally by Colin Carroll, a lawyer of 20 years’ standing.
A French estate on your desk? Keep your client — send us the French leg.
For solicitors & professional advisers
Where are you right now?
Two clear paths — choose the one that fits:
🕊 Someone has died.
We handle the whole French side: who inherits, the notaire driven and every deed explained, the tax return on its six-month clock, releasing the accounts, the property into the heirs’ names — and selling it later if you wish.
After a death →
🌱 No one has died — yet.
Planning ahead. Protect your family before anything happens: who would inherit today, a French will, what your marriage means for inheritance, whether your assurance-vie does what you think — and whether your UK trust still works in Europe. Tell us what you’d like to protect and we’ll guide you.
Planning ahead →
1888
a family of lawyers — almost 140 years
4
countries in southern Europe
20+
years as a solicitor
6
working languages
There’s no UK-style probate in France — so how does it work?
France has no probate in the English sense, and no executor administering the estate. A French estate is settled through a notaire — a public officer whose involvement, for real estate, is not optional: the acte de notoriété proves the heirs, the succession tax return (déclaration de succession) is filed — within six months of a death in France, twelve where the death was abroad — and the notaire’s attestation immobilière, published at the land registry, puts the property into the heirs’ names. The notaire is impartial; he is not your advocate. We are — the family’s own lawyer, driving the file, preparing the cross-border analysis the notaire needs, and explaining every deed in plain English before you sign.
▶ Read: Forced heirship across Portugal, Spain, Italy & France
After a death
What we can help with
Every fee is fixed and agreed in writing before work begins; the notaire’s regulated tariff and all third-party costs are separate and shown up front. (+ VAT.)
Settling the whole estate
Transfer a French property after a death
when the person who died lived abroad — alongside the notaire
€5,000
See the full service
Settle a French estate
when the person who died lived in France — alongside the notaire
€6,000
See the full service
Complex estates
trusts, SCIs, multiple properties, a business, minor heirs
from €20,000
See the full service
Or just one part on its own
Who inherits? — Inheritance Entitlement opinion
a standalone written legal opinion
€950
See the full service
Registering inherited property into the heirs’ names
driving the notaire through the attestation immobilière
€1,500
See the full service
Selling an inherited property
fixed-fee legal work, by the value of the property
from €2,900
See the full service
Also: how cross-border inheritance works, and certificates of foreign law (for the notaire here, or for an England & Wales grant) — for solicitors and advisers.
For lawyers & professional advisers
A foreign estate on your desk? Keep the client — instruct the foreign leg.
Our job here is simple: to help you help your client. Solicitor in Leeds, attorney in Boston, Rechtsanwalt in Munich, notary in Rotterdam — whoever your client trusts at home, you remain lead on the estate; we handle the French leg and report to you at every step. And two assurances worth stating plainly: we do no domestic work in your country at all — there is nothing on your side of the border for us to compete for, and your client comes back to you; and foreign law handled in-house is a quiet risk on your own indemnity record — referred to us, it is insured specialist work on ours, in every one of the four countries. Everything a referring professional needs is written down — starting with a walkthrough written for exactly the file in front of you.
The English solicitor’s guide to the French estate
Why there is no resealing, the route that runs instead, the deadlines that bite, and what to send on day one. Written for English solicitors — and used just as well by any lawyer with a client who owns property here.
Certificates of foreign law
Signed, notary-ready proof of the foreign law your file needs — produced in-house, in the right language.
Refer or instruct us
How the hand-off works, what it costs your client, and what you receive back — in two minutes.
A common situation — and why it really matters
Peter and Carol, both British, retired to the Côte d’Azur in 2019. They married in England, and each has two adult children from an earlier marriage — four children across two families. They own a villa worth €450,000 near Antibes in their joint names.
What most people assume — their English wills control what happens to the villa.
What the law may actually say — under the EU Succession Regulation (Brussels IV), if Peter dies while living in France without a choice-of-law clause in his will, French succession law may govern his estate — not English law. French law reserves a fixed share (the réserve héréditaire) of what Peter leaves for his children — and here that means Peter’s own two children, not Carol’s, become legally entitled to part of his estate, including a share of the family home, regardless of what his English will says — so Carol could find she is not free to sell or remortgage it without them, at the worst possible moment. And in France, unlike Portugal, real inheritance tax can arrive at the same moment.
What could have been done differently — a single clause electing English law under Brussels IV would have restored the freedom the English wills assumed. France’s 2021 statute was designed to blunt exactly that clause — but as at 2026 no court has ever applied it, and the European Commission has closed its file on France’s own concession that English law’s family-provision regime counts as child protection. A well-drafted election now does most of the work — and where French assets meet a blended family, this is precisely where a written, signed opinion earns its keep.
Read more: Which country’s law decides who inherits? · Forced heirship across Portugal, Spain, Italy & France.
Try it yourself
Who would inherit? A quick estimate
One thing first: these rules apply in full when the person made their home in France. If they lived in another EU country — Germany or Belgium, say — that country’s own rules apply instead, not these.
Lived in England or Ireland, with a home in France? Then find the will and look for one clause: a line saying which country’s law should apply — usually “the law of England and Wales”. If that clause is there and chooses the law of a country they were a citizen of, that law decides who inherits — under English law, for example, there are no fixed shares, though some family claims remain. We check the clause and confirm what it achieves. If the clause isn’t there, or there is no will at all, the French property usually falls under these rules after all — and who inherits may not be who the family thinks. Answering that one question is exactly what we do: a clear written answer from a lawyer — who inherits, and why — for a fixed fee.
Now choose the country and the family situation, and see how the reserved share works — the rule that surprised Peter and Carol above. Two minutes, and you don’t need to give us any details.
If there is no will
If there is no will, the answer depends on whether every child is a child of both of you.
If they all are: your husband or wife chooses either a life interest (usufruit — the right to use everything, or its income, for life) over the whole estate, with the children owning it equally; or one-quarter outright, with the children sharing the other three-quarters equally (3/8 each).
If any child is from another relationship: your husband or wife takes one-quarter outright, with no choice, and the children share three-quarters.
The choice belongs to the husband or wife. If a child asks in writing and no choice is made within three months, the law treats it as the life interest.
What the law protects against a will or gifts
The children's réserve héréditaire — the part the law protects for them — is two-thirds of the estate. A will or lifetime gifts can freely pass one-third. Where there are children, the law protects no fixed share for the husband or wife against a will — the life-interest or quarter above is what the law gives when there is no will.
Not included in this estimate
- With children who are all the couple's own, the husband or wife chooses between the life interest and the quarter — we show both.
- Married under shared property (communauté)? The shared property is split first; only the deceased's half and own property is shared out.
- A PACS partner or unmarried partner is not an heir under these rules; a PACS partner has a right to stay in the home for one year.
- A life-insurance policy (assurance-vie) usually sits outside the estate.
- Lifetime gifts count against shares (colação · colación · rapport · collazione).
- A child who died before the parent is replaced by his or her own children — not shown.
- Debts, tax and the value of each asset are not assessed.
- Which country's law governs at all is not assessed — see below.
This estimate is for the textbook family only: a husband or wife still married to the deceased, the children all living, no will, no lifetime gifts, and one country's law governing the estate. If anything else is true — a will, gifts, a child who died first, a divorce or separation, a partner, a second family, property in another country — the answer is our written opinion, on your family's real facts.
For your family's actual facts, a lawyer's signed written opinion — fixed fee, confirmed in writing before you commit.
Which country's law applies? These rules govern when the person lived in that country — unless their will chose the law of a country whose nationality they held, which the EU Succession Regulation allows. A British citizen choosing English law, for example, is then free of these fixed shares, though English law has its own family claims, and France can still let children take back their protected share from French property in some cases. Whether a clause works for your family is part of our written opinion.
Broad national default rules, for orientation only — and true only for the textbook family. In real life, few estates are: gifts made during a lifetime count against shares (colação · colación · rapport · collazione), the marriage property regime decides what is even in the estate before anyone inherits, the family home carries special rights for the widowed spouse, regional regimes (notably in Spain) rewrite the fractions, and foreign wills, usufructs and earlier deaths bend every number above. And “spouse” here means a married spouse: an unmarried or de facto partner — união de facto, PACS or concubinage, pareja de hecho, convivente di fatto — generally takes no automatic share, with narrow national and regional exceptions. That is why the answer that matters is a lawyer’s written one, on your family’s actual facts. This is general information, not legal advice on your situation. Read the full guide or tell us what’s happened.
Try it yourself
What tax would be due? A quick estimate
The second question every family asks. Your relationship to the person who died, roughly what you expect to receive — and what the local rules do with it. Two minutes, no details needed.
≈ €28,194 — the progressive scale after the allowance.
- Each child (and each parent) has a €100,000 tax-free allowance; what is above it is taxed on a rising scale — most family-sized inheritances sit in the 20% band.
And in practice: when we administer an estate, this tax is not your problem to work out — we compute it, prepare the return and file it on time, as part of the work.
The local rules, for orientation only — reliefs, prior gifts, property registration charges and your home-country tax (UK inheritance tax, Irish CAT) all change the picture. General information, not tax advice on your situation. Read the full guide or tell us what’s happened.
Which story is yours?
A whole estate
John lived in Manchester and left an English will. In France he owned an apartment near Nice and one bank account, and his two children agree on everything. We handled the French side — driving the notaire, the certificate of English law, every deed explained — working alongside his solicitor at home.
Brian made France his home: a house near Nice, one account here and one in the UK, and two children. Two legal systems, joined up cleanly.
Diane also made her life here, and left a portfolio, a pension, a French assurance-vie and three children. Everything Brian’s family needed — with the assurance-vie’s separate regime handled and the cross-border tax coordinated too.
Or just one part
Margaret’s mother rented her home in Nice, so all she left in France was one frozen bank account. There was no need for a full estate service — we drove the notaire through the acte de notoriété, made the tax filing, and the bank paid Margaret directly.
David’s father died years ago, but the flat near Nice was never put into the children’s names. Now they want to sell — so we drove the attestation immobilière through and the records across.
Helen and her brother inherited an apartment near Nice, already in their names, and both live in the UK. We took the sale all the way from the offer to the deed before the notaire.
▶ See the full France pricing — what’s included, what’s not, and the notaire’s tariff explained
What will it cost to settle an estate?
Our cost estimator is for settling an estate — tell us a little about it (the property, the accounts) and it shows a fixed-fee range straight away, before you give us any details about yourself. No login, no obligation.
The other services are each a simple fixed price: bank & asset release from €1,750, title work €1,500, and selling an inherited property from €2,900.
How it works — from wherever you are
01
Tell us what’s happened
Our short online form — no obligation, nothing to pay to find out where you stand.
02
A fixed quote, in writing
Our full price and what it includes — and the notaire's estimate obtained and explained — before you decide anything.
03
We handle everything remotely
Under a power of attorney, in plain English — you never need to travel.
04
The estate reaches you directly
Property registered, accounts released bank-to-heir. Your money never sits with us.
How you pay
We agree your fixed fee in writing before any work begins. To open your matter we ask for the first part of our fee — invoiced and receipted immediately — then further instalments at the milestones, so there’s never a single large bill. Third-party costs (the notaire, the taxes, translations) are never part of our fee and are never held by us: we prepare each payment for you and you pay it directly. We never hold client or estate money.
▶ How you pay, and who pays the lawyer — the full picture · Why we never hold your money
Who prepares your work
In France, much of what passes for “inheritance help” is sometimes done by people who are not lawyers at all — agents and intermediaries who are not regulated or insured. We are the regulated, insured lawyer — which, for an estate that matters to your family, is the difference that matters.
Your matter is handled and signed off personally by Colin Carroll — a dual-qualified solicitor, admitted in both England and Ireland, who has lived and worked on the European continent for twenty-five years. Today he is the registered, insured lawyer with the Ordre des Avocats (the French Bar) and the bars of Portugal, Spain and Italy, under EU Directive 98/5/EC, with professional-indemnity insurance in each country of practice. He works in English and speaks fluent French, Portuguese, Spanish and German.
Knowledge: France
Common questions
Is there probate in France?
No — France has no probate in the English sense and no executor. A French estate is settled through a notaire: the acte de notoriété proves the heirs, the succession tax return is filed on a six-month clock (twelve where the death was abroad), and the notaire's attestation immobilière puts the property into the heirs' names. We are the family's own lawyer alongside that process, driving it in plain English.
If France requires a notaire, why do I need my own lawyer?
The notaire is an impartial public officer — not your advocate. We give you independent cross-border legal control of the succession while the notaire performs the reserved acts: we drive the file, prepare the cross-border analysis and certificates, review and explain every deed before you sign, and obtain and explain the notaire's cost estimate at the outset.
Who inherits under French law?
French law reserves fixed shares (the réserve héréditaire) for the children — half for one child, two-thirds between two, three-quarters between three or more — and gives the surviving spouse important rights, including over the family home. Under the EU Succession Regulation (Brussels IV) you can usually elect the law of your nationality in your will; France's 2021 statute was designed to blunt such elections, but as at 2026 no court has ever applied it and the European Commission has closed its file — a well-drafted election now does most of the work.
Do I have to travel to France to deal with the estate?
No. We act for you under a power of attorney drawn to French standards and handle the whole French side remotely, in plain English.
What does it cost?
Our fixed fee, agreed in writing before we start: €5,000 to transfer a French property, €6,000 to settle a French estate alongside the notaire, and €9,500–€12,000 for a cross-border estate. Standalone services are fixed too — releasing a bank account from €1,750, title work €1,500, and selling an inherited property from €2,900. And one honest thing we say up front: a French estate pays two legal professionals — the notaire, on a tariff set by the State (commonly several thousand euros, by the estate's value), and us. The two bills are separate, and we obtain and explain the notaire's written estimate at the outset, next to our fixed fee.
Is there inheritance tax in France?
Yes — and unlike in our other countries, it is real money for many families. The surviving spouse (and PACS partner) is wholly exempt; each child has a €100,000 allowance and then pays on a progressive scale rising to 45%; unrelated beneficiaries — stepchildren included — pay up to 60%. Two things change the arithmetic: the matrimonial-property regime, and any assurance-vie (which sits largely outside the succession under its own gentler regime). We compute, prepare and file the succession tax return as part of the work; tax back home is not ours, and we say early where an adviser at home is needed. The tax itself is never part of our fee.