French tax office challenges the value of the house I inherited

Two years after your father’s death, a registered letter arrives from the French public finance directorate: the house declared at €180,000 in the estate is worth, according to the tax office, €240,000. Nearby sales are cited, additional tax is claimed, with interest. You have thirty days to reply. This guide explains the procedure, what the tax office has to prove, what you can prove in return, and how a counter-valuation fits into the discussion.

What happens in practice

The inheritance tax return was filed within six months of the death, with a value for each asset. The tax office then has a reassessment period running until 31 December of the third year following the year of registration (article L. 180 of the French Tax Procedure Code). During that period, it compares the declared value with the sales recorded in the area.

Where it considers the value too low, it sends a reasoned tax reassessment notice (proposition de rectification, articles L. 55 and L. 57 of the Tax Procedure Code). It states the value adopted, the sales used as comparables, the additional tax and the late-payment interest. You have thirty days to submit your observations (article L. 11), extendable by thirty days on request (article L. 57).

The tax office replies to your observations. If it maintains all or part of the reassessment, you can, as it can, refer the matter to the departmental conciliation commission (article L. 59 B of the Tax Procedure Code, article 1653 A of the General Tax Code). The commission hears the parties and gives an opinion. The tax is then put into collection, and there remain the formal complaint and then the tribunal judiciaire, which has jurisdiction over registration duties.

At each stage, agreement remains possible: the tax office frequently accepts an intermediate value when the taxpayer’s observations are serious and documented.

What French law says

The basis is real market value. For transfers on death, the tax is calculated on the real market value of the assets at the date of death, according to the detailed and estimated declaration of the parties (article 761 of the General Tax Code). The tax office may correct the price or valuation of an asset where it appears lower than that value (article L. 17 of the Tax Procedure Code).

The tax office proves its case by comparison. The Cour de cassation (the French supreme court for civil and commercial matters) recalls that market value must be assessed “taking into account all the factors that make it possible to obtain a figure as close as possible to that which would have resulted from the normal interplay of supply and demand” (translated from the French; Cass. com., 9 July 2025, appeal no. 24-13.540, discussed on this site). The tax office must cite sales of similar properties, before the death or close to it. The taxpayer may criticise those sales and produce others.

Date and condition govern everything. The value is assessed at the date of death, in the condition of the property at that date. A taxpayer who relies on a particular feature of the property must prove it at that date, with contemporaneous documents; later evidence is not enough unless it reveals a situation that already existed (Cass. com., 6 May 2026, appeal no. 25-13.442, discussed on this site).

Allowances are limited. The deceased’s main home benefits from a 20 % allowance where it is occupied as a main home by the surviving spouse, the civil partner or a minor or protected adult child (article 764 bis of the General Tax Code). For let property, a discount is accepted depending on the type of lease; none for property left at the disposal of family members (Charte de l’expertise en évaluation immobilière, the French property valuation charter, 6th edition, November 2025, Title II, § 8.14).

Interest and penalties. The additional tax carries late-payment interest of 0.20 % a month (article 1727 of the General Tax Code). The 40 % surcharge requires deliberate non-compliance proved by the tax office (article 1729).

What a valuation report changes

The reassessment notice is a valuation by comparison. Replying to it with an assertion, or with two estate agents’ opinions, does not move the debate. Replying with an expert valuation moves it onto the ground where it belongs: the comparables and the adjustments.

The report establishes the market value at the date of death, in the condition of the property at that date. Where works have been done since, it reconstructs the earlier condition from photographs, surveys and invoices. It then examines each sale cited by the tax office: date, floor area, condition, floor level, aspect, presence of a lift, land, and measures what brings it closer to or further from your property. It produces its own references, drawn from the notarial databases and the public DVF sales database, and explains the adjustments. It costs the works needed at the date of death from quotes or a professional estimate, not as a percentage.

The report may conclude that the tax office is right, in whole or in part. That too is useful information: it allows a quick settlement rather than a challenge with no basis. The Charte treats valuation for tax purposes as a specific assignment (Title II, § 8.14) and requires the assumptions and reservations to be set out in writing (Title I, § 2.2).

What the report does not do: it does not suspend the time limits, it does not replace the written reply to the tax office, and it does not guarantee that the reassessment will be dropped.

A worked example

A flat in Quimper, on the third floor without a lift, inherited by an only son on his mother’s death in January 2023 and declared at €180,000. In March 2025, a reassessment notice adopts €240,000 on the basis of four sales in the same district. The additional tax, in the 20 % band of the direct-line scale, comes to €12,000, plus about €600 of late-payment interest.

The counter-valuation notes that two of the four sales cited concern renovated flats in buildings with a lift, and a third a top floor with a terrace. The flat itself had its original kitchen and bathroom, an energy performance certificate in class F and windows to be replaced: €35,000 of works costed from quotes dated 2023. On five comparable sales of flats without a lift and in need of refreshing, the value at the date of death comes out at €200,000.

The conciliation commission adopts €205,000. The additional tax falls to €5,000, plus interest, instead of €12,000. The valuation cost €975 travel not included. In a case where the notice had been well founded, the same valuation would have made it possible to accept and pay without proceedings.

Common mistakes

• Not replying within the time limit. Without observations within thirty days, possibly extended, the reassessment is deemed accepted and the discussion becomes much harder.
• Replying with today’s values. What counts is the market at the date of death. A market that has fallen since is not an argument.
• Relying on occupation by a family member. It does not justify a discount. Only a lease enforceable against third parties opens one.
• Claiming works without documents. A flat-rate deduction for dilapidation is regularly rejected; dated quotes are not.
• Forgetting what was declared elsewhere. A higher wealth tax (IFI) value for the same property, or a sale price close in time, will be raised against you. The report must explain them.

What to gather

• The complete reassessment notice, with its appendices and the list of sales cited.
• The inheritance tax return and, where applicable, the property certificate (attestation immobilière).
• The title deed, the property tax notice, and the surveys carried out at the death or shortly after.
• Photographs of the property at the time of death, before any works.
• Dated quotes and invoices for works, before and after the death.
• Any leases in force at the death.
• The general meeting minutes for a flat in a co-ownership.
• Earlier wealth tax returns, if any, and the deed of sale if the property has been resold.

Timeframe and fee

The service is a market value report at a past date, with an inspection: about 15 hours, that is from €975 travel not included, with the report usually delivered three weeks after the inspection. An old valuation date, with reconstruction of the condition of the property, may require a few extra hours, stated in the quote. If the property has been sold and is no longer accessible, a desktop valuation can be prepared from the documents, from €325, stating its limits (Charte, Title II, § 8.6). Attendance at the conciliation commission is charged on time spent, €65 per hour.

Travel is charged at €65 per hour or part hour from PONT-L’ABBÉ, 50 % deposit on ordering, VAT not applicable, article 293 B of the French General Tax Code. The Market value page describes the report and the Fees page gives the full scale. Given the thirty-day time limit, ask for the extension as soon as the letter arrives, then for the quote.