The Same Flat, Three Countries: What a Child Really Pays to Inherit

One flat, one child, four different bills

The example below is deliberately plain: a parent dies owning one flat, valued at 400,000 euros, with no debts and no other assets, leaving one adult child as sole heir. Nothing about it is exotic. It is roughly the shape of the ordinary European inheritance, and it is the case in which the three national systems diverge most visibly, because each of them handles the first few hundred thousand euros in a completely different way.

France gives each child an allowance of 100,000 euros against each parent and then applies a progressive scale that reaches 20 % almost immediately — the 20 % band runs from 15,933 euros of taxable value all the way to 552,324 euros, so an ordinary flat sits squarely inside it. Italy gives each beneficiary a franchigia of 1,000,000 euros and charges 4 % only on the excess, which means a single flat almost never generates succession tax at all. Spain sets a modest state allowance of 15,956.87 euros and a scale that climbs to 34 %, and then lets each autonomous community rewrite the result — which is exactly what most of them have done.

France: the allowance is per parent, per child, and it renews

The French allowance of 100,000 euros is not an allowance on the estate. It is an allowance on each parent-to-child line, so a couple with two children can pass 400,000 euros free of duty in total, and the same allowance is used up by lifetime gifts made in the fifteen years before death. That fifteen-year clock is the single most consequential number in French estate planning, and it is the subject of the next article in this series.

The scale itself is steep at the bottom and then flat for a long stretch: 5 % up to 8,072 euros, 10 % to 12,109 euros, 15 % to 15,932 euros, then 20 % all the way to 552,324 euros, 30 % to 902,838 euros, 40 % to 1,805,677 euros and 45 % above. Those thresholds have not moved for years, which quietly increases the real burden every year that property prices do. On 300,000 euros of taxable value the arithmetic gives 58,194.35 euros, an effective rate of 14.5 % on the whole 400,000 euros — and the child has to find that in cash, because the flat cannot be paid in slices.

Italy: almost nobody pays succession tax, and that is by design

Italy charges 4 % to a spouse and to relatives in the direct line, but only on the net value exceeding 1,000,000 euros per beneficiary. Siblings pay 6 % above 100,000 euros each; other relatives up to the fourth degree pay 6 % with no threshold; everyone else pays 8 % with no threshold. A beneficiary with a severe disability recognised under Law 104/1992 gets a franchigia of 1,500,000 euros. Those figures are the Agenzia delle Entrate's own published rates.

«Nothing to pay» is not quite the whole story, and the difference matters if you are budgeting. Where the estate contains land or buildings, the mortgage tax and the cadastral tax are due alongside the succession declaration, together with stamp duty and the fees for the mortgage and cadastral services. And since successions opened on or after 1 January 2025 — the reform delivered by Legislative Decree 139/2024 — the succession tax is self-assessed by the taxpayer in the declaration rather than being computed by the office, with payment due within 90 days of the filing deadline. That is a real change in who carries the risk of a mistake.

Spain: the postcode decides, and it is the deceased's postcode

The Spanish inheritance and gift tax is a state tax whose yield and, crucially, whose reliefs are ceded to the autonomous communities. The state law sets a floor: an allowance of 15,956.87 euros for a descendant aged 21 or over, a scale running from 7.65 % to 34 %, and a multiplier applied to the resulting quota according to the heir's pre-existing wealth. Apply that floor alone to our 400,000-euro flat and the child owes 76,897.81 euros. Almost nobody actually pays that, because almost every community has legislated on top of it.

Madrid applies a 99 % rebate on the quota for groups I and II — children, spouses, ascendants — under article 25 of its consolidated tax text; a 2025 amendment extended a 50 % rebate to all of group III and added a full exemption for gifts under 1,000 euros, in force from 1 July 2025. Andalucía has applied a 99 % rebate to groups I and II since 11 April 2019, now carried in its Ley 5/2021. Catalonia does something structurally different: it has its own scale, starting at 7 % and reaching 32 % above 800,000 euros, its own kinship reduction of 100,000 euros for a child, and a rebate calculated as a weighted average that falls as the estate grows. The generous version of that table — 99 % on the first 100,000 euros of taxable base, then 97 %, 95 %, 90 % and downward — was cut back by Llei 5/2020 and now reaches only group I, the descendants under 21; a spouse or stable partner keeps a flat 99 %. An adult child sits in group II, whose table starts at 60 % on the first 100,000 euros and steps down through 55 %, 50 % and 45 %, reaching zero above 3,000,000 euros. For deaths from 1 May 2020, on a base of 400,000 euros that weighted average works out at 52.50 %, not the 95.25 % the old table gave.

One connecting rule decides which of those regimes applies, and it is not the one most people assume. For a death, the competent community is the one where the deceased had their habitual residence, not the one where the heir lives and not the one where the flat stands. A British or Irish child inheriting a Madrid flat from a parent who had retired to Alicante is judged by Valencian rules, not Madrid ones. Since a 2014 reform, made after a Court of Justice of the European Union judgment, non-resident heirs may claim the same autonomous-community reliefs as residents — which used to be the single largest trap for cross-border families.

What actually moves the number, once you know the rates

The first lever is whether the tax is charged on the estate or on each heir's share. France, Spain and Italy all tax the share, which means splitting an estate between three children is materially cheaper than leaving it to one — three French allowances of 100,000 euros instead of one, three Italian franchigie of 1,000,000 euros instead of one, three trips up a progressive scale from the bottom instead of one trip up the whole thing. The English-speaking instinct, formed by estate-level taxes, gets this backwards.

The second lever is valuation, and it is where most disputes start. Each administration has its own rule for what a flat is worth on the day of death, and none of them simply accepts the family's estimate. The third is the deadline, which is short everywhere and unforgiving: broadly six months from death in France and in Spain, twelve months in Italy. Missing it triggers interest and penalties on a sum the heirs may not yet be able to raise, because the asset generating the tax is precisely the one that cannot be sold quickly.

Frequently asked questions

Is there really no Spanish inheritance tax in Madrid?

There is: the tax is calculated in full and then 99 % of it is rebated for groups I and II. On our 400,000-euro example the child still files a return and still pays 769 euros. The distinction matters because the return is compulsory whether or not tax is due, and because the rebate is a regional provision that a future regional parliament can change — as Madrid's own parliament did in 2025 when it raised the group III rebate to 50 %.

Which country taxes me if the parent, the child and the flat are in three different countries?

Potentially more than one, which is why this question needs advice rather than an article. Immovable property is almost always taxable where it stands, and most of these countries also tax on the residence of the deceased or of the heir, so double taxation is a live risk and the relief comes from a bilateral treaty or from a domestic credit, not automatically. Note that the EU succession regulation, which decides which country's inheritance law governs the estate, says nothing at all about which country's tax applies — they are separate questions and they routinely give different answers.

Does the surviving spouse pay in these countries?

In France the surviving spouse and the surviving PACS partner are entirely exempt from succession duty. In Italy the spouse has the same 1,000,000-euro franchigia and the same 4 % rate as a child. In Spain the spouse sits in group II with the child, so the same regional rebate applies — 99 % in Madrid and in Andalucía, 99 % flat for a spouse or stable partner in Catalonia. The exemption is one of the sharpest differences between marriage and cohabitation in all three systems.

Can the child pay the French duty in instalments?

Deferred and instalment payment schemes exist in France and, in a different form, in Italy and Spain, and they are precisely what the six-month deadline is designed to be survivable with. They are not automatic: they are granted on application, usually against a guarantee, and they carry interest. Ask the notary or the tax office about them at the start of the process rather than at the end, because the application generally has to be made when the return is filed, not after the demand arrives.

Do these figures change if the child is under 21?

In Spain, yes and materially: a descendant under 21 falls into group I, whose state allowance is 15,956.87 euros plus 3,990.72 euros for each year under 21, capped at 47,858.59 euros — and Catalonia's own group I reduction starts at 100,000 euros plus 12,000 euros per year under 21, capped at 196,000 euros. In France and Italy age makes no difference to the allowance; what changes there is who administers the share until majority, which is a civil-law question rather than a tax one.