French PACS vs UK Civil Partnerships

PACS is not recognised in the UK nor is a UK Civil Partnership recognised in anyway in France for anything.

You cannot enter into both. If for instance you have entered into a civil partnership in the UK you are prevented from entering into a Pacs in France unless you get divorced in the UK.

PACS in France comes under exactly the same inheritance tax rules as it does for a married couple. Civil Partnership in the UK carries absolutely nothing towards the avoidance of French inheritance tax.

To be eligible for entering into a PACS one of you must be French or have been French domiciled for a minimum of 2 years (Paid French Income Tax)

The main differences are a Civil Partnership in the UK is only possible for people of the same sex. Pacs in France can be for people of opposite sexes and carries no obligations to live together and has nothing to do with a sexual relationship (can be just for 2 friends) and can be dissolved very easily just be signing a form. Adultery for instance would not dissolve a PACS whereas it could a CP in the UK which has to be dissolved in exactly the same way as marriage between people of opposites sexes does-a divorce.

Forgot to add the bit about a Will.

A Will written in the UK cannot over-ride French inheritance laws for property in France.

In France you have to bequeath your property to your children/spouse if any. If none (and you have no wife/husband) then you are free to bequeath everything to anyone. However, if your property is bequeathed to a friend 65% of the value goes to the French Govt in inheritance tax and the friend would therefore only receive 35%. There is no free threshold before inheritance tax in calculated when bequeathing to friends (there is to a wife/husband or children).This is completely different to the UK system where the first £300,000 or so is free of inheritance tax and the remainder can be left to whomever you choose to leave it to where it is taxed at the same rate 40%. In France the figure varies depending on what relationship the people are to you, for children it is very generous and also for a wife/husband but to a friend it is 65%.

If you do a PACS in France then it is recognised in the U.K as being the same as a civil partnership as long as you are of the same sex. However, the French don't recognise a British civil partnerhsip. I don't think a British will would cover your French assets and there would be huge inheritance taxes to pay for a non PACsed partner. There is a double taxation treaty between France and the U.K and there is a non discrimination clause in it which does says that you should not be treated differently to how you a national in France would be treated ie if you are in a civil partnerhsip and therefore unable to do a PACS in France because of this then I can't see how the French tax authorities could treat you in a different way since you are in the same situation. It's probably best to do a PACS in France and then this would cover you for France and the U.K and your partner would pay zero inheritance tax. If you do it the other way and do a civil partnership then you pay zero inheritance tax in the U.K and have to argue with the French tax authorities and hope the double taxation treaty would cover you.