Which law governs the succession of a Franco-Lebanese person with property in Lebanon and in France?
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Short answer
No published source settles it for dual nationals. Lebanese inheritance follows the deceased's religious community[1,2]. Kallas Law Firm says the succession may be affected by the Law of 18 June 1929[1] and by conflict-of-laws rules that decide which country's law governs which assets. Mattar Law Firm says the estate opens at the deceased's last domicile[3]. Ask a lawyer qualified in both countries and a French notaire.
Also asked as: “Which law governs the succession of a French-Lebanese dual national with property in Lebanon and in France?” · “French-Lebanese inheritance which law applies” · “Is a French will valid for property in Lebanon?” · “Dual national estate France and Lebanon”
No source we found covers a France-Lebanon succession or tax convention, dual nationals, or how French and Lebanese forced-heirship rules interact over Lebanese property. This page covers what was published up to 17 October 2026.
Key facts
- Foreign element
- May be affected by the Law of 18 June 1929[1] and by conflict-of-laws rules, according to Kallas Law Firm
- Where the estate opens
- the deceased's last domicile[3], according to Mattar Law Firm
- A will made in France
- Enforced in Lebanon only after exequatur from a Lebanese court of appeal[2]
- France-Lebanon convention
- Not covered by any source we found
What Lebanese law says, and what it leaves open
Lebanon has no single civil inheritance code. Muslims inherit under Islamic law and non-Muslims under a civil statute, so the deceased's community decides the shares[1,2]. For Christians and Jews, that statute is the Law of 23 June 1959[1,2,4]. More in which inheritance law applies to your family and how the 1959 law divides an estate.
When a foreign national is involved, Kallas Law Firm says the succession may be affected by the Law of 18 June 1929[1] and by conflict-of-laws rules that decide which country's law applies to which assets. Kallas advises mixed families to settle this question at the outset. We did not read that law, and no source explains how it treats someone who is both Lebanese and French.
Mattar Law Firm says the estate opens at the deceased's last domicile, wherever the property lies, and that this also governs cross-border estates[3]. Mattar does not say which law's article it relies on. It is probably the 1959 law, which covers non-Muslims only. We have no source at all on the French rules, so a French notaire is the person to tell you how France treats the estate, Lebanese property included. A Lebanese lawyer can tell you how a Lebanese court will see it.
A will made in France
For non-Muslims, Kallas says a Lebanese person's will made abroad may follow the foreign country's formalities for authentic instruments, and a handwritten will made abroad may be deposited with the Lebanese consul[4,5]. Kallas warns that a handwritten will left undeposited or unsealed is open to being declared void.
According to PBL Law Group, a foreign will is enforced in Lebanon only after exequatur by a Lebanese court of appeal. That can be the court of the legatee's residence, the court where the assets lie, or the President of the Beirut Court of Appeal, and exequatur can be refused if the will breaches Lebanon's forced-heirship rules[2]. Under the 1959 law, a protected portion is kept for the descendants, parents and spouse[1,2,5], and a will cannot defeat it. One Kallas page says parents are protected only when there are no descendants; a Lebanese lawyer can confirm. Kallas says a will that gives away too much is not void but is cut down to the disposable portion, and only a reserved heir can ask for that[4,5].
As Kallas reads the 1959 law, a bequest to someone who is not Lebanese is valid only if that person's national law allows bequests to Lebanese, and only as far as it allows[4]. We have no source on what French law allows. Ask the French notaire.
French heirs, Lebanese property and Lebanese tax
Two law firms say a foreign heir can inherit Lebanese property on a reciprocity basis, meaning as far as the heir's own law lets Lebanese inherit. Kallas adds that inherited shares do not need the licence foreigners need to buy[3,5]. No source says whether inherited area counts towards the foreigners' limits[5,7]. See foreign heirs and the 3,000 m² limit.
Lebanese inheritance tax applies to all assets in Lebanon passed on death, whatever the deceased's nationality[2,6]. Kallas adds that it also reaches assets abroad when the deceased was resident in Lebanon, and PBL notes that tax treaties may create exceptions. We found no source on whether a France-Lebanon treaty covers inheritance. Ask the Ministry of Finance and a French tax adviser before anyone pays twice.
What heirs abroad do first
- Identify each Lebanese property on paper. Ask the lawyer for each property's plot number and real estate district, and the section number for an apartment, as shown on the deceased's title deed. Then ask for a recent Land Registry extract for every plot, so you can match each one to the right property. The extract shows the owner, mortgages and restrictions[8,9]. Shares are written out of 2,400 shares[10,11,12], so check the deceased's fraction. Here is how to get a Land Registry extract.
- Register the death in Lebanon. For a death abroad, the death certificate goes through the Lebanese embassy or consulate, then the Ministry of Foreign Affairs, then the Ministry of Interior. Kallas puts this at about two months[13].
- Get advice in both countries before the court step. Ask the French notaire and a Lebanese lawyer which law governs the Lebanese property, whether any will is valid in both countries, and whether the Lebanese reserve rules apply.
- Obtain the Probate Decision (hasr irth). No property can be transferred to heirs until it exists[1,2,13]. No source we found gives the cost or time to obtain it; ask the Lebanese lawyer handling the file. For non-Muslims, PBL says it is issued by a single judge of the first-instance court of the last residence[2,3]. For other communities, see which court issues the hasr irth.
- Act through a power of attorney. Kallas says heirs can name a lawyer or relative in Lebanon to cover the declaration, the Probate Decision, the tax and the transfer or sale, and that selling needs an express special mandate[1]. You sign at a Lebanese mission, or before a French notary, then have it authenticated by the French authorities and legalised by the Lebanese embassy or consulate[15,16,17,18]. An apostille will not do, because Lebanon is not a member of the Apostille Convention[19]. See acting for heirs from abroad.
- Clear the tax, then register. Notaries and the registry will not act on the estate before the Ministry of Finance authorises it[13]. Kallas says the authorisation is issued only after the tax is paid, or security is given for twice its maximum amount. The transfer is made at the Land Registry office of the property's location[2,13], with the Probate Decision, the clearance, the title deeds and a notarised transfer deed. No source we found gives a registry or notary fee, or a timeline, for this transfer; ask the lawyer or the notary for a written estimate.
It depends on
- The last domicile. According to Mattar, the estate opens at the deceased's last domicile[3]. Whether that was in France or Lebanon may matter, so ask a lawyer qualified in both systems.
- Whether there is a will, and where it was made. According to PBL, a French will needs Lebanese exequatur and can be refused if it breaches the reserve[2]. Ask the French notaire and a Lebanese lawyer.
Common questions
Does French law decide what happens to an apartment in Lebanon?
No source we found answers this for a Franco-Lebanese person. Kallas Law Firm says the succession may be affected by the Law of 18 June 1929 and by conflict-of-laws rules that decide which country's law governs which assets[1]. A lawyer qualified in both systems is the right person to ask.
Is a French will valid in Lebanon?
According to PBL Law Group, a foreign will is enforced in Lebanon only after exequatur by a Lebanese court of appeal. The court can refuse if the will breaches Lebanon's forced-heirship rules[2].
Do French heirs need a licence to inherit Lebanese property?
Sources
Checked against these sources. The numbers in the text point here.
- 1.Inheritance Law in Lebanon: A Guide for Heirs and Families Abroad
Kallas Law Firm · 20 Jun 2026 · read 17 Oct 2026
- 2.International Estate Planning in Lebanon: A Clear Overview for High Net-Worth Families
PBL Law Group · 5 Apr 2025 · read 17 Oct 2026
- 3.Mattar Law Firm: Inheritance and Wills in Lebanon
Mattar Law Firm · undated · read 17 Oct 2026
- 4.How to Make a Valid Will in Lebanon: A Guide for Christian Families
Kallas Law Firm (klfi.net) · 21 Jun 2026 · read 17 Oct 2026
- 5.Christian Inheritance in Lebanon: How an Estate Is Divided Under the 1959 Law
Kallas Law Firm · 20 Jun 2026 · read 17 Oct 2026
- 6.Inheritance Tax in Lebanon 2026: Rates, Exemptions and Calculator
Kallas Law Firm · 20 Jun 2026 · read 17 Oct 2026
- 7.Palestinian Refugees' Right to Inherit under the 2001 Amendment Law – Beirut Test Case
Norwegian Refugee Council · January 2016 · read 16 Oct 2026
- 8.The Land Registry in Lebanese Law — Part Six of the Practical Guide to the Code of Real Property
Kallas Law Firm · 25 May 2026 · read 16 Oct 2026
- 9.How to Buy Property in Lebanon: The Legal Steps from Verification to Inscription
Kallas Law Firm · 9 Jun 2026 · read 16 Oct 2026
- 10.Land Delimitation and Registration Works in Lebanese Law — Part Seven of the Practical Guide to the Code of Real Property
Kallas Law Firm · 25 May 2026 · read 17 Oct 2026
- 11.How to Find Real Estate and Land Register Information in Lebanon
Legalmondo · 17 Jun 2025 · read 17 Oct 2026
- 12.Legislative and Administrative Land and Property Rights Framework. Lebanon
GLTN / UN-Habitat · May 2024 · read 16 Oct 2026
- 13.Inheritance in Lebanon: Probate, Estate Declaration and Inheritance Tax (2026)
Kallas Law Firm · 27 Jun 2022 · read 17 Oct 2026
- 14.Declaration within 90 days: Finance Minister memo on liquidating estates and inheritance
Annahar · 15 Apr 2025 · read 17 Oct 2026
- 15.Power of Attorney
Embassy of Lebanon, Washington DC · undated · read 17 Oct 2026
- 16.Legalization of Powers of Attorney not Drafted at the Consulate
Consulate General of Lebanon, New York · undated · read 17 Oct 2026
- 17.Power of Attorney
Embassy of Lebanon, The Hague · undated · read 17 Oct 2026
- 18.Services consulaires supplémentaires par courrier
Embassy of Lebanon, Brussels · undated · read 17 Oct 2026
- 19.Status table – 12: Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents
HCCH (Hague Conference on Private International Law) · 30 Jun 2026 · read 16 Oct 2026
Related questions
- Which inheritance law applies to me in Lebanon: Muslim, Christian, Druze or foreigner?It follows the deceased's religious community: Islamic law for Muslims, the 1959 civil law for Christians and Jews. Courts, shares and foreign heirs.
- I'm an heir abroad: can someone act for me in Lebanon, and how do I sign the power of attorney?Yes: a lawyer or relative can act under a POA signed at a Lebanese mission, or notarised locally and legalised. Steps, fees, deadlines and risks.
- Do foreign heirs need a licence or face the 3,000 m² limit when they inherit property in Lebanon?Two sources say foreign heirs need no licence and inherit by reciprocity; none says if inherited area counts toward 3,000 m². What is known, whom to ask.
- How is an estate divided under the Lebanese inheritance law for non-Muslims?Under the 1959 law, as one law firm reads it, children share equally and the spouse's share depends on who survives. Heir order, reserves, wills.
- Which court issues the hasr irth in Lebanon: the Sharia court or the civil court?It depends on the community: a civil first-instance judge for non-Muslims; for Muslims, law firms disagree on the court. Steps and checks.
- How do I transfer inherited property into the heirs' names at the Land Registry?Heirs file the estate declaration, get the hasr irth, pay or secure the tax, then register at the local Land Registry. Documents and steps.
- Is there inheritance tax in Lebanon, and how much is it?Yes: each heir pays a progressive tax of 3% to 45% on their share above a personal exemption. 2026 exemptions, brackets, deadlines and older estates.
- How long do heirs have to declare an estate in Lebanon, and what are the penalties for being late?Heirs declare within 90 days of the death and complete the file within six months; late fines run monthly. Extensions for heirs abroad, penalties and steps.
