Now we don't have to follow French Inheritance rules can we ditch the Assurance Vie?

The Connexion expat paper has a story saying the EU has voted a rule whereby we can choose the inheritance regime we want to be used when we die. So if one wishes to leave most/all of one's legacy to someone other than one's natural children (which you can't do in a straightforward way here in France) then one now can by writing a will which says it is to be interpreted in a British way.

At the moment the only(?) way of achieving this with money is via the Assurance Vie as sold by Blevins, Spectrum etc, and that has significant costs. It seems to me that as long as one keeps breathing till 2015, when the rule change comes into effect, then that might open up all sorts of different investment/savings possibilities at lower cost.

I'm writing this so others can correct me please.


I think it only fair to update my original comment by saying that Mary has been in touch and has arranged a meeting for me with her Firm's local office. Given Mary's businesslike and very professional response to my emails I can only imagine that my original unsatisfactory contact with Blevins was an anomaly.

Thanks Mary.

Mary, Absolutely, I'm more than happy to give you the details of my interaction with your colleague. If you'd like to give me an email address I'll be in touch.

Quite obviously i am very disappointed to hear this. I must point out that there are Partners operating in different areas. I am certain in the real world, that any company will strive for excellence but have odd occasions where something went wrong. What is important is what they do about it in my view.Firstly, it is key to know what happened exactly & perhaps you would connect to me personally so I can see what happened, prevent it occurring again, and hopefully enable you to gather any assistance you require now. That way I hope you feel able to post a different perspective but i think it is best we deal with this with you personally first.

I've just found this thread and thought I might add that I found Blevins service unresponsive and quite poor. I couldn't recommend them.

Hi Mary

I've edited your post to remove the BF link as we don't allow commercial links on SFN.

Also can you please, pretty please, upload a profile photo - it makes a huge difference to the dynamic when people can see who they are talking too!

If you're not sure why it is so important, here's what some of our members have to say about it to do it,

and here's a link to show you how

Dear Steve,

The reason I entered this blog was simply to clarify what I could and save the misinformation on the new rules I was reading, going further. I am sorry that I have commitments to my work/clients that means I cannot keep going back and forth trying to answer points like this. I hope you understand. I suggest you email me your number so I can complete your questions to some conclusion, and save having to do this piecemeal. The FSA would of course bother about all they regulate, even if that is in France, Spain or anywhere in EU that a company passports their services to. This is fact, and our web site states our regulatory status in the variety of countries we advise, if you have a look.. I too, like to sleep at night and have a strong ethical belief in what is a hugely important role in the lives of clients.There are always different investment offerings but if direct investment[ie not within a tax wrapper]is not tax efficient, then this may not be appropriate advice, and potentially more costly to clients. As I have said, the client needs are different and the solutions tailored to them. There are facilities for fees, investment advisory fees etc.I have already explained it is a cost/benefit analysis. Just also to re-iterate, i am not a one man band; I am part of a strong company of over 36 years [with 11 of my years with them] & with admin, client, pension, specialist tax and marketing staff/depts employed as support. Thus i have time for my clients. I would not have lasted 21 years in the profession otherwise! I hope this helps and for others reading, this was never meant to be a BF advert! Just an encouragement to not self advise, and find what you need from experienced professionals [ ie paid for what they do].There will be more articles on Blevins Franks & will consult with the site owners for any that they want & which might be useful here. Kind regards....Mary Taylor

Mary, I fully accept that being regulated by anyone is a good thing; if it did ever come to a full blown quarrel or compensation claim, surely the FSA would just say it's nothing to do with them being as it's outside UK?

I think the argument about ongoing good service being a good way to attract new clients doen't really go that far, you can only put so much time into "promotional" activity. And really it turns your situation into essentially one of being simply a sales person, once the client has invested there isn't any more to be earned. I'd have thought you could succesfully sell a "portfolio review" paid for service. Or a percentage of profits thing, or ...

You didn't take up the point about having additional investment offerings beyond AV.


Being regulated full stop, ensures that clients have protection against incorrect advice and inappropriate investments, so I really don’t follow that point with respect. at least my clients would be able to deal fully in English for any complaint process, and probably have some prior understanding of how the UK FSA works. We all have a choice of course. I am part of a company not a one man band, and thus have a team to administer client cases and a fully qualified private client manager employed to help review clients regularly. So we can, and wish to, manage the review process and thus try to provide service long term.any type of business would wish to do this and thus promote referrals to new clients I would have thought? We also have a fee based service using specialist tax advisers. If you wish to, you can look me up on our web site and call to discuss this further if you are still unclear.

Thanks again

Being UK regulated probably doesn't help us French expats much.

Here are my worries:

If you are approached by someone who isn't a suitable candidate for an AV do you have other options which still allow you to get paid?

I was told (not by you, by a competitor) that once somebody is signed to to an AV you don't earn any more unless they add more funds. It's hard then to understand how you are able to devote sufficient time to keep looking after them when what earns you a living is signing up new customers


If you look at a company website Steve, you should find how and in what country, their advisers are regulated. So being UK regulated, this would include the following. When an individual client is advised, they would receive a document at outset, covering all terms of business. This is mandatory in UK, and content is specified by the regulator and is very clear fro the individual client. This also states for example, my registration number to look up on the UK FSA web site. Advice is provided in writing. This written report is checked by a compliance department to ensure it is within the regulators rules (even my short article for you was checked before publication) & thus provides protection and clarity for you, on what and why recommendations were made.Where a company has been advising for a good number of years, and the adviser themselves has documented experience, should also help consolidate the professionalism of the advice. Finally you can always seek a recommendation from others who may have sought professional advice. At the end of the day, after 21 years, I would hope to be able to demonstrate some professionalism by now :). As I write it has provided a useful break to revising for a final exam this week to upgrade my qualifications in the Uk, albeit I technically do not need to, and thus trying to maintaining and improve professional standards. Hope this helps. I just would wish to encourage folks to take personal advice and not rely on piecemeal information, that actually is only relevant to someone else’s background and objectives, and perhaps wrong perception of advisory firms.
Of course if tax changes come in that changes the way an individual needs to hold assets, then this is acted upon. A frim would not stay in business otherwise, and is also why a review process takes place regularly with pur clients. The article you read has already been delivered to my clients and database as an example. This change is yet a long way off and does not affect tax that may become due, only succession law, and AVie also already can help overcome that.
Back to revision…

Um yes but Rob you do collect some of my money, you aren't a charity. As I remember the fees we pay to the Insurance company amount to something like 8% plus etc etc spread over a number of years. There's no doubt the costs are higher than we are used to in the UK and need taking into account when determining a strategy, because in some circumstances they could outweigh the benefits.

And Mary, thanks very much for the excellent word document; how do we know you folks are professional, by whom you regulated, and are you sure that the change in the legal framework doesn't mean that some of your old clients might be advised to change strategy?

No professional and regulated adviser would advise on a strategy where the costs outweigh benefits. just to be clear…

You are welcome :wink:

Thanks to Mary Taylor for stepping in and clarifying this. My fingers were itching too, as a fellow professional adviser in France. The only thing I would have added would have been a reference to traditional French obfuscation. Edicts from Brussels are introduced very swiftly into French legislation if they suit the French. If not, things are rather different. Be prepared for a lengthy period of stonewalling over this, with notaires dragging their heels over every centimetre of the way.

Going back briefly to your original question Steve, whatever happens to succession law will not change succession tax, so Assurance Vie will be as relevant as ever. I can't speak for Blevins, but I can assure you that at Spectrum the benefits you will get from assurance vie far outweigh the costs. New products are coming to the market regularly, and costs are therefore being driven down. We don't drive costs, as we don't charge anything at all to the client.

I am a Partner for Blevins Franks. I feel very concerned about the misinformation that seems to be developing here. Therefore I have hopefully attached an article, we have put together for our client database in response to this Connexion article. I have cleared this with the site owners. This may help, but I encourage you to seek advice according to your own situation and set of circumstances, with whoever you feel you need to. In addition,with an AV, you effectively create tax free allowances for those who wouldn’t otherwise have them (e.g. step children, unmarried and unPACSed partners, god children etc), and you effectively double the tax-free amount to a child.

The UK inheritance rules would make no difference, because it is a life assurance policy and you nominate the beneficiary. The French tax rules would still apply to the AV if you die as a French resident, regardless of which inheritance laws apply.So hopefully you will see that you do not need to ditch anything.

'Estate' does sound like property and assets, fingers crossed that's what it means, do you have to make a will in France, Uk or both?

S C I (I'm guessing you have british telly)

sorry I can't find it on their website, other than the image of the printed paper front page on the website home page (I hope that's clear?).

This is what the circular email said

The European parliament has passed a regulation which allows expats in France to dictate in a will that they want the law of the state of their nationality to apply to their estate and not French inheritance law. This, in effect, means Britons in particular can leave their estate to whoever they wish and not be bound by strict inheritance rules as at present.

Hi. Can I politely beg to differ. Having read the draft legislation it will apply to all assets, including property.