Question 1798 — treaties and conventions

Summary

Ms. Marie-Ange Rousselot draws the attention of the Minister of the Economy, Finance and Industry to the resumption of negotiations with Switzerland to establish a new tax convention on the double taxation of inheritances. While the Franco-Swiss tax convention of December 31, 1953 made it possible to govern these situations and avoid double taxation, it was denounced by France on June 17, 2014. Since January 1, 2015, In France, the provisions of the general tax code apply, sometimes leading to double taxation, as in the case where a French resident inherits property located in France belonging to a deceased Swiss resident. This situation may impose taxation on the heirs in Switzerland and then in France, which may reach an amount greater than the value of the inheritance. Faced with this delicate situation which can impact many families settled in cross-border territories, a new tax convention between Switzerland and France aimed at avoiding double taxation appears particularly desirable. On September 19, 2023, the Swiss National Council adopted a motion to relaunch negotiations with France with a view to a new convention. In France, an amendment to the convention between France and Switzerland of September 9, 1966 was tabled in the Senate by the Minister for Europe and Foreign Affairs on June 26, 2024, but this only concerns double taxation in terms of taxes on income and wealth and not inheritance. In July 2024, Bruno Le Maire, Minister of the Economy and Finance, publicly declared his readiness to revise the inheritance tax convention during a trip to Geneva. She therefore requests details on the progress of this reflection and the steps envisaged for a resumption of negotiations with the Swiss authorities.

Machine translation from French. The official text remains authoritative.

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