Succession laws, after death of husband/wife

Has anyone been affected by the new laws of succession, after death of husband or wife.

I have a will, it should now be legal. We have paid a notaire to discover how this new law is going to work, and enable us to use our will!

According to the information published in the French to English news paper, we can now use our wills from this year onwards.

Our notaire is still not sure, we do have a document from when we bought our property over 20 years ago. (Donation Épouse).

Is there anyone out there who has information re the rights of owners and the new law.

Thanks Maureen.

Might be worth contacting an Avocat specialising in rights of succession here, they should be more au fait than a Notaire who is only really a tax collector and not a solicitor. My own personal experience of succession here was 13 years ago now and no english will was involved, only Donation entre Epoux which kicks in automatically. You might get a free consultation or even so, usually around €450 for an appointment but at least they would know.

Thank you for your reply. We have a very good notaire who speciises in this subject. Apparently, the EU told France that they needed to update their succession laws. They were given until this year, according to the French to English news paper, anyone applying to use their will can do so. The French government has set up a compensation package.

It does seem that even though this is now law, a few test cases are needed, to ensure that the introduction of the new rules become law correctly.

We have paid 300€ to have an answer to this question, but after speaking to thé Notaire, we are not confident that they understand. They have asked us to go and see them face to face!

Any chance you can provide a link to that as I’m not sure exactly what you are talking about.

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This seems to explain it reasonably clearly Changes in French Inheritance Law: What UK Expats Need to Know in 2024 - France Tax Law

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Thanks. I thought there was some new thing. This has been rumbling on for a while.

So not sure it helps understand what Maureen means by

As we could always use our wills? Nothing seems to have changed to me in that it is still reliant on no dispossessed relative challenging it.

a quote from the link provided above…

"Key provisions include determining the applicable law, defaulting to the deceased’s habitual residence, but allowing an option for the law of their nationality. "

We had our Wills drawn up in France, using the Option of Nationality, which was available at that time.

Nothing I’ve read so far tells me that this will not be honoured on our deaths…

Hello Jane, are you familiar with the French laws on Property? If you own a property and your partner dies, your children inherit 50% of the value, along with you. This is your partner’s share of the property.

The remaining partner then owns the remaining 50% of the property, plus their share of the portion which belonged to the deceased partner. Eg. if there are two children, along with the remaining partner, they each inherite. 1/3 of 50%.

A while ago, the EU had told France that they needed to change their ancient laws . The new laws for inheritance came into being this year in February. It now means that legal wills can be used to share out your belongings when you die, as in the UK.

I don’t buy the French/English news paper. My friend who buys this newspaper on line, she tried to send me a copy. You can’t copy it!

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Yes! They are not good for recomposed families. On the advice of a notaire and an international solicitor we have english will drawn up under english law - which is legal in France. It still doesn’t protect against being challenged, but hopefully provides more protection to those we wish to protect.

That is not the same as it was when OH died in 2011. I inherited my 50% of the property plus HALF (25%) of his share whilst our two children inherited 12.5% each making up the 50% of OH. Don’t think that has changed. Everything else had to be agreed between us, i.e. the family car had to be agreed by the kids that I could sell it for a new one etc.

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I had no idea English wills were valid, which is why we never made any. The Notaire is handling my wife’s estate at the moment and, as far as I know as we had Donation entre Epoux, her half of the property ‘belongs’ to her 3 kids but they can’t claim it till I die, then my 2 kids get the other half at the same time.

Works fine for me as I am happy where I am with no intention of liquidating the property in my lifetime, but I can see the difficulty if someone wanted to return to UK and rely on house sale proceeds to purchase another one there.

Yes you can have them. We went to see our French notaire about having French wills and knowing our family situation he shuddered and told us not to!.

Mon testament anglais va-t-il être reconnu par les autorités françaises (et inversement) ?

Cela va dépendre de la loi applicable à votre succession et de vos circonstances personnelles Un testament anglais est accepté et reconnu en France et vice-versa, mais le contenu de ce testament doit être rédigé avec précaution pour s’assurer qu’il produise les effets désirés dans les deux pays. Pour un testateur de nationalité française ou franco-britannique possédant des biens dans les deux pays, avoir un testament en France et un testament en Angleterre permet parfois de grandement faciliter la résolution de la succession et de réduire les couts de procédure pour faire reconnaitre un testament fait dans un autre système juridique. Nous pouvons vous conseiller sur les options possibles et les avantages et inconvénients de chaque type de testament, et ensuite une fois votre choix fait vous aider à préparer tant votre testament anglais que français. Cela permettra d’éviter des contradictions et assurer une parfaite coordination des deux.

I have read it and I think understood, but put simply, would it have suited us to make wills in England before leaving and not making the Donation Entre Epoux on arrival here? It certainly wasn’t the advice we got at the time.

I thought that the French imperative of absolutely to not disinherit children overode everything. Does it not still?

From today’s France Insider

Death in France - Recovery of Social Benefits

24th Sept 2024

Beneficiaries of an estate in France can face a bill for social benefits and residential care services received by a deceased person.

Responsibility for social benefits and services in France is divided between several agencies, but most are provided either by the departmental councils or the main retirement fund, called the Caisse nationale d’assurance vieillesse (CNAV).

Under French law, under certain conditions, beneficiaries (including the surviving spouse) of an estate are required to pay back certain benefits that may have been received by the deceased. If there is more than one beneficiary, the amount to be reimbursed by each one is proportional to their share of the estate.

Practice does vary across the country, but most councils do demand that at least some reimbursement is made.

Scope

Although the rule does seem fearsome, the scope of the benefits and services covered by it is limited. There are three main benefits and services concerned:

i. L’allocation de solidarité aux personnes âgées (Aspa) - This benefit, which is a minimum revenue benefit for retired persons is administered by the CNAV, is recoverable on that part the estate greater than €104,000 net, a threshold that should rise each year in line with inflation. There is a maximum amount that can be recovered each year, currently around €8K for a single person and €11K for a couple. Recovery of the benefit is only possible against an inheritance. Around three-quarters of a million individuals are in receipt of Aspa, but many potential recipients do not take it up due to the liability on the inheritance.

ii. L’aide sociale à domicile - Social assistance at home (home help, meal delivery, etc.) is recoverable if the net value of the estate exceeds €46,000 and the amount to be recovered exceeds €760. It is also recoverable against gifts, without allowance, and against life insurance (assurance vie) policies on premiums paid after the age of 70 from the beneficiary if the premium is considered to be disproportionate.

ii. L’aide sociale à l’hébergement (ASH) - This benefit is payable to those in residential care. The assistance is reimbursable from the inheritance, without any allowance, although where the person is disabled, there is no recovery against the spouse, children or carer. It is also recoverable against gifts or increased wealth for those who are not disabled and against life insurance (assurance vie) policies on premiums paid after the age of 70 may also be recovered from the beneficiary if the premium is considered to be disproportionate.

No other social benefit is reimbursable, so beneficiaries of the RSA, or those in receipt of French retirement pension, are not concerned by these rules.

In some circumstances, recovery may take place even where the recipient is still living. Thus, where the recipient comes into a large sum of money (such as an inheritance), the rule of ‘retour à meilleure fortune’ applies. It is only enforced where there is a significant increase in the wealth of the beneficiary, and the sale of fixed assets (such as a property) by them does not trigger a recovery procedure.

Recovery is also possible against a beneficiary of a gift (donation) made by the person receiving social assistance, up to 2 years after receipt of the benefit. This is possible even though the person may not be a family member.

As the authorities are not always made aware of such actions, it is more often than not the case that recovery occurs on inheritance, when the notaire will be asked to provide relevant details of the succession to them.

Recovery Process

The recovery process will depend on the circumstances of the person concerned, so that some or all of the debt may be payable over a period of time, or simply delayed entirely.

Thus, recovery from the surviving spouse’s share may be deferred until his or her death, as may heirs aged at least 65 (60 in the case of unfitness for work, and at any age in the case of serious disability) who were living with and a dependent of the deceased.

Each heir or legatee must repay in proportion to what they receive from the inheritance. Heirs and legatees are not, therefore, obliged to repay from their own income.

If an inheritor or beneficiary considers the recovery action being taken to be unjustified, it is possible to challenge it. In terms of departmental social assistance, the claim must be made within two months of its notification, before the departmental Commission départementale d’aide sociale and, if necessary, before the national commission. In relation to the ‘Aspa’ benefit it is through the Commission de recours amiable (CRA) of CNAV.

I have received nothing in the way of having to pay back benefits since Fran died. She received 2 sets of home visits each day, CIAS and SSIAD, and, during the period that she was on oxygen and a drip, nusres came in twice a day also.

I was led to understand that the nurses and the SSIAD were free and without future charge. The CIAS did charge about €60 a month for their service which I paid immediately, but at the same time received a grant of some kind, always roughly the same amount, directly from the Departement.

not involving husband and wife… but It has happened in our village… inheritors asked to payback… whatever it was … or refuse to accept the inheritance…
Provided the inheritance came in under 15k (I think) there was no clawback… the sums are probably different nowadays… the examples I know of personally, were several years ago.

One instance involved a man who’d been in hospital care for years and years… his house sold under the magic number… was snapped-up by a local and transformed into a gite complex.

The RSA stops normally at the age of retirement and beneficiaries, if they own their property are supposed to claim ASPA if their pension is not sufficient - I could have but thankfully do not need to and therefore the children will get my house between them other wise they would have only got a shared €39k from a house worth €300k. This is why inheritors who know there are debts should refuse the sucession and walk away otherwise everything comes at them and they do go after them to repay outstanding debts andpayments, it used to happen when I was on the local CCAS committee and we had to help re-house some widows/widowers who were forced to sell the family home to pay it all off.