Finance

Franco-Moroccan succession: how to avoid double taxation

9 September 2026·2 min read

The lack of a Franco-Moroccan inheritance tax treaty risks double taxation. France taxes worldwide estates if the heir or deceased was a French tax resident, while Morocco levies near-zero duties. The French tax credit (Art. 784A CGI) only offsets duties actually paid in Morocco. EU Regulation 650/2012 allows choosing Moroccan law via will. In France, a €100,000 allowance per heir per parent every 15 years applies before progressive rates; lifetime gifts or SCI structures can optimize transfer.

Franco-Moroccan inheritance: how to avoid double taxation

There is no bilateral tax treaty between France and Morocco specifically dedicated to inheritance. The 1970 treaty only covers Moroccan securities forming part of the estate of a French national domiciled in Morocco, which are exempt in France. Real estate, bank accounts, and cash are not covered by this exemption.

In the absence of dedicated inheritance legislation, France applies Article 750 ter of the General Tax Code. If you have been resident in France for at least 6 of the last 10 years preceding the death, France taxes your share of the inheritance on assets located anywhere in the world, including in Morocco. The same logic applies if the deceased was a French tax resident within the 10 years preceding their death: their worldwide assets may be taxed in France.

On the Moroccan side, registration duties on direct-line inheritance between parents and children are very low, virtually non-existent. Article 784A of the French CGI provides for a tax credit equal to duties paid abroad. However, if Morocco has levied nothing, this credit is nil. If duties have nevertheless been paid in Morocco, particularly registration duties on a notarial deed, it is essential to keep the receipts to serve as the basis for the tax credit in France.

The European Succession Regulation 650/2012 applicable in France allows you to choose the law of your Moroccan nationality for your succession via a will. In France, direct-line heirs benefit from an allowance of €100,000 per heir and per parent every 15 years, before application of the progressive scale. Taking action at least 15 years before death allows you to optimise these allowances and escape the 6-year rule, notably through lifetime gifts or holding assets via an SCI.

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