Germany also allows dual nationality with another EU country IIRC (which is an EU level thing, also IIRC).
I can have German nationality and will probably apply for it if/ when I go and live there so I can keep an eye on my parents. The Germans arenât bothered about the 2 I already have. My surname in Germany is slightly different though, by law I have my stepfatherâs tacked onto my original nameâŠ
A few years ago it became possible, if you are the citizen of another EU country, to you choose the inheritance law of that Country rather than French law. I suspect that only applies to âmovableâ wealth (no matter where it is) and that property is governed by the jurisdiction it is in. Youâve remined me that I need to see the Notaire about that very topic.
Iâd call constantly having to justify it to yourself fretting Ronald.
Maybe I missed the drift Geof. Are British applicants being treated any different to other third country citizens? Does the UK now have level of English required for citizenship, I read somewhere that they were considering introducing for work visas. I think Australia has something similar and it seems to be the model for the UKâs new rules.
My understanding is that all over-60s (not just Brits) have to do the language test for French citizenship now.
I think (as I said earlier) itâs part of the moral panic about religious terrorism - imams etc not being fully integrated in French culture. It also plays well with right-wing nationalistic voters, and Macron for some reason thinks he has to attract these (a failure of analysis, in my view). Behind these right-wing ideas, in turn, is the notorious âgreat replacementâ fear (I may have got that term wrong - I mean the idea that European christian traditions are being replaced by islam, etcâŠ).
That is why so many Brits, including our daughter, rushed to take dual nationality before Brexit.
Again I have a slightly different understanding John - but I may be wrong - I thought the EU rule was now that you can indeed elect in your will to apply your home countryâs inheritance rules (though crucially not its tax rules) - but I didnât think it was limited to EU countries, and is therefore still possible for Brits.
@JaneJones will know.
That could well be the case Geof.
Having UK and French Citizenship makes no difference to inheritance. As a French resident you are subject to French inheritance tax laws no matter what nationality you are (and it is eye watering!). However if your retain UK citizenship you can opt for the UK inheritance SUCCESSION laws even if you also have French citizenship. You canât avoid French taxâŠ
This financial instrument Brussels IV has nowât to do with Brexit.
Ahhh, when itâs inheritance itâs not my residency Iâm worried about. If I have âŹ1000 in France and leave it to a UK resident where is the tax paid? If I leave them a house I expect that inheritance tax will be payable in France and potentially capital acquisitions tax (possibly offset by a double taxation treaty) by the UK Legatee?
Itâs all bloody complex and a bit unfair really IMO. If youâve no money to leave, it doesnât matter. If you are rich you can afford the best advice and financial structures to avoid any (or at least minimise) inheritance tax. But if you are an in-betweeny with a moderate estate you get clobbered
Spend everything before itâs too late ![]()
I donât understand, is the âyourselfâ you refer to me or some other person?
What I meant Ronald was that IMO anybody who keeps revisiting decisions they have already made are fretting. I think most people just get on with things.
If I recall correctly, you suggested that peopleâs criticism of the No. Ten regime was motivated not by a recognition of the poor job they have done but by a need to justifying their own decisions to move to France. My point was that I have seen no evidence of people having any such doubts about their decision.
Well thatâs good to hear - I think. I need to do some reading.
Definitely not. I think that people who move to another country may compare the old country unfavourably with the new, as I said, as a confirmation that they made a good choice. I donât think I ever said that they fret about it, or that this would invalidate any criticism of the country that they have left. I find the knee jerk response to the UK government unacceptable but not genuine and thoughtful critique. Heaven knows, with Johnson there is plenty of scope.
Tax is paid in France according to French tax laws (except that âŹ1,000 is below threshold). For non-family the threshold is around âŹ1500, and the tax is 55%+. Lots of tricksy exemptions and details for family and charities, and national heritage and so on.
Spend it or give it to charity⊠unlike in the UK you also canât even give as much money to your offspring while you are alive.
Well hereâs an example why the UK Govt is unacceptable⊠The great lump of lard will stand for the cameras on the steps of Downing Street and clap for the NHS then closes the door and pisses up their backsâŠ
but it goes on⊠front line workers such as the Police are not to be regarded as a priority for vaccination⊠yes the place is hell on earth and I make absolutely no apology for saying so.
Itâs disgusting and distasteful. As an NHS pensioner myself, I so feel for these very special people and the way they are being shat on.
Hereâs the link for the Police mention:
But are the succession laws that different, apart form not being able to disinherit your children in France?
I went through the succession process in 2014. My wife and I were resident in France when she died but our daughter was at college in Ireland. We had assets and property in both countries. It was complex but we used the same notaire as weâd used to purchase the house here as he was a thorough, meticulous and sympathetic man. He helped structure the succession in the most beneficial way for my daughter and I based on my wifeâs Irish will. In the end what was in Ireland was handled under Irish succession law and Irish inheritance tax.
Despicable IMHO.
Just like here then.