#WEALTH & ESTATE PLANNING
Five million euros passed on to an only child, in direct line. Depending on the legal packaging, the duties owed are either 1,967,394 euros or 103,194 euros. Both figures are computed by France's public levies council.
Published on August 24, 2026
In its December 2025 report on wealth taxation, the Conseil des prélèvements obligatoires (CPO), a council attached to the French Court of Audit, prices two scenarios for a single transfer: 5,000,000 euros to an only child, in direct line. In the first, the wealth passes on death with neither a Dutreil pact nor a split of ownership: 1,967,394 euros of duties, an effective rate of 39.3%. In the second, the same amount is gifted at age 60, combining a Dutreil pact with a split between bare ownership and usufruct: 103,194 euros, or 2.1%. The gap reaches 1,864,200 euros for the same sum, the same family link and the same statutory schedule. The CPO draws a structural conclusion: French inheritance tax combines high headline rates, up to 45% in direct line, with a base it describes as heavily eroded by derogatory schemes whose impact keeps growing, especially when they stack.
What does it actually cost to pass 5 million euros to an only child in France?
Between 2.1% and 39.3% depending on the packaging: 103,194 euros through a gift at 60 with a Dutreil pact and a split of ownership, 1,967,394 euros on death with neither, according to the CPO's own computations.
In other words: in France, the inheritance tax rate actually paid depends less on the amount transferred than on how early it was planned and on the legal nature of the assets.
Four caveats, because they matter
- The 2.1% scenario is not open to everyone: a Dutreil pact requires transferring shares in a company and honouring holding commitments. A portfolio made of cash or rental property does not qualify.
- It also requires planning ahead. The gift is simulated at age 60, before the 70-year limit that conditions several advantages: an unplanned transfer on death closes most of these options.
- These are two illustrative cases computed by the CPO, not an average measured across actual estates. The CPO itself notes that public data on transferred wealth remains insufficiently precise.
- The report is advisory, not law. Its recommendations, including restricting the Dutreil pact to genuine business assets and cutting its partial exemption from 75% to 50%, had not been enacted when this page was published.
Why it still matters: the French debate on inheritance tax is fought over the statutory schedule, which climbs to 45%. The CPO's costing moves the question elsewhere: with the schedule unchanged, the gap between a planned and an unplanned transfer reaches 37 percentage points of effective rate on the same sum.
For you
- The same amount, the same heir, taxed at 39.3% or 2.1% depending on the packaging: do you read that first as a rate problem or a tax base problem?
- Were you aware that on a 5-million-euro transfer, the choice of legal packaging alone could move the tax bill by 1.86 million euros?
Source: Conseil des prélèvements obligatoires (French Court of Audit), 'Corriger les principales distorsions de l'imposition du patrimoine', summary report, December 2025, table 'Droits de donation ou succession avec et sans optimisation (ligne directe, enfant unique)'.
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