| Titre | La taxation des héritages et donations : éléments de comparaisons internationales | |
|---|---|---|
| Auteur | Anne Laferrère | |
 |
Revue | Economie et prévision |
| Numéro | no 100-101, 1991/4-5 | |
| Rubrique / Thématique | Héritage Fiscalité |
|
| Page | 177-188 | |
| Résumé anglais |
Inheritance and Gift Taxes: Bases for International Comparisons,
by Anne Laferrère.
There is a wide range of ways countries handle the transmission of wealth from one generation to the next. The very concept of property can differ as do the rules governing matrimony, children's rights and the freedom to testate. Inheritance taxes can also be different from gift taxes, such differences having to do with history and civil laws. The USA and Great Britain are considered to be different from countries whose legal system is based on Roman law, and rightly so. For the former, freedom is the basis of the system and the inter vivos tax rate is lower than the post mortem one, the more wealthy being more heavily taxed. Even if these taxes only account for a small percentage of the GDP in France, (as is the case everywhere else), heirs are taxed more heavily on an average and the tax rate for gifts and inheritance are the same. A few details are given for Germany and Japan. Source : Éditeur (via Persée) |
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| Article en ligne | http://www.persee.fr/web/revues/home/prescript/article/ecop_0249-4744_1991_num_100_4_5262 |
