France Morocco Inheritance Tax Obligations Explained

For many Moroccan families, inheritances today take place between two countries. A parent may live in Morocco after having worked in France, still own an apartment in the Paris region, leave a French bank account, or have children settled in France. In these situations, the inheritance can quickly become a Franco-Moroccan affair.

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The important point is simple: the place of death is not sufficient to determine tax obligations. A person may die in Morocco but leave property in France. In this case, the French tax administration may be concerned with the succession. Property located in France belonging to the deceased may fall within the scope of French inheritance rights.

This concerns in particular an apartment, a house, land, a commercial premises, but also certain assets or holdings held in France. For Moroccan or Franco-Moroccan heirs, the fact of living in Morocco is therefore not always sufficient to rule out any proceedings with the French tax authorities.

The situation can also become complicated when one of the heirs lives in France. The tax service reminds that property located in France belonging to the deceased may be taxable, but also, in certain cases, property located in France and abroad when an heir has been a French resident for at least six years during the ten years preceding death.

A deadline of 12 months if death occurs in Morocco

When death occurs abroad, the succession declaration must in principle be filed within 12 months. For a person who died in Morocco with taxable assets in France, the process is carried out with the Non-Residents Tax Office. The declaration must be accompanied by payment of any rights due.

This deadline is longer than that provided for death in France, where the declaration must generally be filed within six months. But it does not mean that heirs can wait indefinitely. After the deadline, interest or penalties may be added if rights were due.

In MRE families, the risk often comes from a misunderstanding of the situation. Some heirs believe that the succession falls solely under the country where the deceased lived. Others are unaware that real estate retained in France may be sufficient to trigger a French declaration obligation.

It is also necessary to distinguish two questions: who inherits, and where tax may be due. The civil rules of succession determine the heirs and their rights. Taxation, on the other hand, looks in particular at the location of assets, the residence of the deceased and sometimes that of the heirs. It is this intersection that makes Franco-Moroccan successions sensitive.

For MREs, the right reflex is therefore to take inventory of the deceased’s assets in both countries: housing in France, bank accounts, life insurance, assets in Morocco, debts, past donations or notarial documents. It is from these elements that declaration obligations can be verified.

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An inheritance between France and Morocco does not automatically result in tax in France. But it may require a declaration, an examination of the situation and sometimes the payment of rights. The French tax authorities do not only look at the country of death: they also look at where the assets are located and what links the heirs maintain with France.