Three Statuses, Three Legal Universes
France recognises three legally distinct forms of couple life: marriage (mariage), the civil solidarity pact (pacte civil de solidarité, PACS), and cohabitation (concubinage or union libre). The hierarchy is stark. Married spouses benefit from the fullest legal framework. PACS partners occupy an intermediate position — many fiscal advantages of marriage and some of its obligations, but no automatic succession rights and no protective family home rules. Cohabiting partners are, in the words of the Civil Code's draftsmen, treated as strangers to each other: the law offers them almost no patrimonial protection whatsoever.
For international couples and expats living in France, the consequences of not understanding this distinction can be severe: a partner dying intestate in cohabitation leaves their surviving companion with nothing but a tax bill at the 60% rate — the rate applicable to strangers.
Cohabitation (Concubinage): Maximum Freedom, Minimum Protection
Definition and Daily Life
Cohabitation is defined in Art. 515-8 of the Civil Code as a union of fact, characterised by a shared life of stable and continuous character, between two persons of different or the same sex, living as a couple. No formality is required to enter into — or exit from — cohabitation. Cohabiting partners owe each other nothing by law: no obligation to contribute to household expenses (a duty imposed on both spouses by Art. 214 C. civ. and on PACS partners by Art. 515-4). Each cohabitant answers only for debts they personally contracted. The joint and several liability for household debts under Art. 220 C. civ. does not extend to cohabitants.
Married spouses and PACS partners are jointly and severally liable for household debts contracted by either of them. Cohabitants are not. This cuts both ways: the cohabitant non-debtor is protected from their partner's creditors, but neither can compel the other to contribute to shared household costs without a specific written agreement.
Housing Rights
The Art. 215(3) protection of the family home does not apply to cohabitants. A cohabitant who is the sole owner of the shared home can sell it, mortgage it, or rent it out without the other partner's agreement. A cohabitant whose name is not on the lease has no automatic right to remain if the lease-holding partner gives notice to quit. Where only one partner holds the lease and that partner dies or abandons the home, the lease transfers to the surviving cohabitant — but only if they can prove they have been living together for at least one year at the relevant date (Loi 89-462, Art. 14 and 15). Where the couple has purchased jointly, ownership is held in indivision in proportion to contributions in the deed. A large discrepancy between stated ownership and actual financial contribution risks requalification as an indirect gift by the tax authority (Cass. com. 7-7-2009 n° 08-18.365).
Inheritance: The Fundamental Void
Cohabitants do not inherit from each other under intestate succession. Even if the deceased had no other heirs, the estate goes to the State. The only way a cohabitant can inherit is through a will — taxed at the 60% rate after a negligible allowance of €1,594 (CGI Art. 777, tableau III and Art. 788, IV). Gifts between cohabitants are also subject to the 60% rate after the same minimal allowance.
A cohabitant who dies without a will leaves their surviving partner with nothing — no right to the home, no share of assets, no pension rights. Even with a will, the surviving partner faces a 60% inheritance tax rate. Life insurance with the partner named as beneficiary is the single most effective planning tool available to cohabitants, as life insurance proceeds fall outside the succession estate and are transmitted free of inheritance tax up to applicable thresholds.
When Cohabitation Ends: Separation
Either partner can end cohabitation at any time, for any reason, with no legal formality. There is no prestation compensatoire, no duty of financial support, and no right to compensation for economic imbalance. Damages may be awarded only where the breakup was caused by proven fault — extreme brutality, incitement to give up employment. The mere end of a long relationship, even after decades, gives rise to no claim (Cass. 1ère civ. 7-4-1998 n° 96-10.581). There is no attribution préférentielle available to cohabitants on separation unless expressly provided for in a co-ownership agreement (Cass. 1ère civ. 26-9-2012 n° 11-12.838).
The PACS: A Civil Contract with Growing Legal Substance
The PACS (pacte civil de solidarité), governed by Art. 515-1 to 515-7 C. civ., is a contract entered into by two adults to organise their shared life. Registered at the civil registry of the couple's common residence municipality (or before a notary), it creates mutual material assistance obligations and household debt solidarity (Art. 515-4 C. civ.) — functionally equivalent to Art. 214 and 220 C. civ. for spouses. The default patrimonial regime since 2006 is separation of property; partners may contractually opt for indivision. See our dedicated PACS guide for the full treatment.
Housing Rights
PACS partners who jointly request co-tenancy acquire joint tenancy rights equivalent to those of spouses under Art. 1751 C. civ. Unlike married spouses, PACS partners do not benefit from the Art. 215(3) family home protection — a PACS partner who owns the shared residence can in principle sell or mortgage it without the other's consent.
Because Art. 215(3) does not protect the PACS couple's home, partners who own their shared residence as sole owner should consider a contractual arrangement — a usufruct, a clause in the PACS convention, or a testamentary bequest — to secure the other's right of occupation. Life insurance designated in favour of the surviving partner provides additional liquidity to fund any tax charge.
Inheritance and Tax
The PACS confers no automatic inheritance rights. A PACS partner must be named in a will to inherit. With a will, surviving PACS partners benefit from the same total exemption from inheritance tax as married spouses (CGI Art. 796-0 bis). For gifts, PACS partners benefit from the same €80,724 tax-free allowance as spouses, renewable every fifteen years — making the PACS fiscally equivalent to marriage for estate planning, so long as the will is in place.
Marriage: The Fullest Legal Framework
Marriage activates the entire statutory architecture of the statut impératif de base — the choice of matrimonial regime, the protection of the family home, and the full succession rights of the surviving spouse. Three aspects stand out for comparison:
Family home protection: Under Art. 215(3), neither spouse can sell, encumber, or otherwise dispose of the shared residence without the other's written consent, regardless of who owns it. This protection is d'ordre public and cannot be contracted away. It does not apply to PACS partners or cohabitants.
Automatic succession rights: A surviving spouse is a legal heir with substantial rights even in competition with children — at minimum, the usufruct of the entire estate or full ownership of one quarter (Art. 757 C. civ.). The surviving spouse also enjoys a one-year right of free occupation of the family home as a direct effect of marriage (Art. 763 C. civ.). Married surviving spouses are fully exempt from French inheritance tax with no cap and no condition of having been named in a will.
Income tax: Married spouses and PACS partners equally benefit from joint filing and the quotient familial from the year the PACS is registered or from the year of marriage. Cohabitants file separately.
The Three Statuses at a Glance
| Area | Marriage | PACS | Cohabitation |
|---|---|---|---|
| Household expense obligation | Yes — Art. 214 C. civ. | Yes — mutual material assistance, Art. 515-4 C. civ. | No — each partner is independent |
| Joint liability for household debts | Yes — Art. 220 C. civ. | Yes — Art. 220 C. civ. applies by reference | No — each answers for their own debts only |
| Family home protection | Full — Art. 215(3): no unilateral disposal | None — Art. 215(3) does not apply to PACS | None |
| Default asset regime | Communauté réduite aux acquêts (if no contract) | Separation of property (since 2006 reform) | Full separation — each owns what they acquire |
| Automatic inheritance rights | Yes — surviving spouse is a legal heir with minimum guaranteed share | No — PACS partner must be named in a will | No — no rights at all without a will |
| Inheritance tax on survivor's share | 0% — full exemption | 0% — full exemption if named in will (since 2007) | 60% after €1,594 allowance — stranger rate |
| Gift tax allowance | €80,724 per 15 years | €80,724 per 15 years | €1,594 only — 60% rate |
| Income tax filing | Joint return, quotient familial | Joint return, quotient familial from year of PACS | Separate returns |
| IFI (wealth tax) | Joint declaration as one fiscal household | Joint declaration as one fiscal household | Concubins notoires: joint declaration in principle |
| Survivor's right to family home | 1-year free occupation — Art. 763 C. civ. (direct effect of marriage) | None — must be provided by will or contract | None — must be provided by will or contract |
| Ending the relationship | Divorce — judicial process; prestation compensatoire possible | Unilateral declaration — no court, no cause required; no automatic financial compensation | No formality; no compensation unless fault proven |
IFI: The Cohabitation Trap
France's wealth tax on real estate assets (IFI) treats married spouses and PACS partners as a single fiscal household, meaning all their real estate is aggregated for the IFI base. Cohabiting partners who are concubins notoires — a publicly acknowledged, stable couple — are in principle also subject to joint IFI assessment. This means a couple who chooses cohabitation to avoid the joint succession consequences of PACS or marriage may still face consolidated IFI treatment — without any of the corresponding inheritance tax advantages.
Planning for Cohabitants and PACS Partners
Specific Issues for International Couples and Expats
For couples with cross-border elements, a PACS registered in France is treated as equivalent to marriage for all French fiscal purposes, including the inheritance tax exemption — but only where French tax jurisdiction applies. A couple who entered into a civil union or registered partnership abroad — a British civil partnership or a German Lebenspartnerschaft — is generally recognised by French tax authorities as equivalent to a PACS for French fiscal purposes, subject to specific administrative confirmation in individual cases.
Cohabitation, as a situation of fact, is recognised across jurisdictions without formality — but the patrimonial consequences depend entirely on which country's law governs the couple's assets. An international cohabiting couple with real estate in France will find their French assets governed by French law — meaning the 60% inheritance tax rate, no automatic succession rights, and no family home protection — regardless of more favourable rules that might apply in their country of origin.
Whether you are planning a PACS, considering marriage, or simply want to understand the patrimonial implications of your current situation, our guides and resources cover every dimension of French family and wealth law for international couples.
Book a ConsultationThis article is provided for general information and educational purposes only. It does not constitute legal advice. French family law and tax law are technical and fact-specific. The applicable rules depend on each couple's individual circumstances, residence, nationality, and the location of their assets. Always seek advice from a qualified French notary or lawyer.
Get Advice
Contracting with a French Party?
We advise sellers and buyers on French sales law, warranties, retention of title and cross-border terms. Speak to our team.
Get Legal AdviceKey Legal References
Cohabitation (concubinage): definition — union of fact, characterised by shared life of stable and continuous character between two persons living as a couple; no formality required. No obligation to contribute to household expenses; no joint liability for household debts (Art. 220 C. civ. does not apply to cohabitants). Each partner answers only for debts they personally contracted
Lease rights for cohabitants: lease transfers to surviving cohabitant on partner’s death or abandonment of home only if cohabitant can prove at least 1 year’s shared residence at relevant date
Inheritance tax for cohabitants: strangers rate of 60% applies after €1,594 allowance, even where named in will. No quotité disponible spéciale entre époux; no €80,724 allowance. Gifts also at 60% after €1,594
Large discrepancy between stated co-ownership and actual financial contribution risks requalification as indirect gift by tax authority
No attribution préférentielle available to cohabitants on separation unless expressly provided in co-ownership agreement; no prestation compensatoire; no duty of financial support; damages only for proven fault
PACS: mutual material assistance and household debt solidarity; default asset regime = separation of property (since 2006 reform); no Art. 215(3) family home protection; no automatic succession rights; full inheritance tax exemption if named in will (since 2007); €80,724 gift allowance same as spouses
Marriage household obligations: contribution to household expenses proportional to means (Art. 214); joint and several liability for household debts (Art. 220). Family home: Art. 215(3) protection — neither spouse may dispose of shared residence without other’s written consent, regardless of who owns it; d’ordre public, cannot be contracted away
Surviving spouse: legal heir with minimum guaranteed share (usufruct of entire estate or 1/4 in full ownership depending on heirs composition); full inheritance tax exemption with no cap and no condition of being named in will
Surviving spouse 1-year right of free occupation of family home and furnishings as direct effect of marriage (not subject to will)
Full inheritance tax exemption for surviving PACS partner named as legatee and for married surviving spouse
IFI wealth tax: married spouses, PACS partners, and concubins notoires all constitute single fiscal household for IFI assessment; all taxable real estate aggregated regardless of couple status
