The setup
Our client (anonymised "Mr. A. Sr."), Moroccan-French, 72, retired executive, died at his Paris home in January 2026. He left:
- A 350 m² built / 700 m² plot villa in Casablanca Anfa Supérieur, ANCFCC-titled, acquired 2005 at 2.4M MAD.
- Three adult children (2 sons, 1 daughter), all French tax residents — Paris, Lyon, Bordeaux. None had visited the villa in 3 years.
- A surviving widow, also French resident, 68.
- No written will. No SCI. No prior lifetime gift arrangement.
The children engaged ReaConsult in March 2026, overwhelmed by the administrative and legal complexity. Objectives: (a) precisely value the villa for equitable partition, (b) handle Moudawana requirements on the Moroccan side, (c) advise on options (retain in joint ownership / sell / buy-out by one heir), (d) coordinate French + Moroccan notaries on the double succession declaration.
Applicable legal framework
For any property in Morocco, regardless of the deceased's or heirs' domicile, lex rei sitae imposes Moroccan law:
- Moudawana (Family Code) — mandatory partition: widow 1/8, sons double share, daughter single share (classical rule without testamentary disposition).
- France-Morocco 1983 succession treaty + 1970 revised France-Morocco tax treaty.
- Acte d'hérédité (fraïdh) drawn up before adouls in Morocco, listing all legal heirs.
- Appraisal at date of death mandatory for: (a) fair partition, (b) Moroccan DGI tax basis, (c) French succession declaration.
- Moroccan registration duty: preferential 1.5% for direct heirs.
- On the French side: Forms 2705/2709, 14-month deadline (12 + 2 for foreign). Parent-child abatement €100,000.
ReaConsult intervention — timeline
- March 2026 — Video scope call with the 3 children + widow — understand intentions (sell or retain?), identify potential conflicts, map the steps.
- March — Villa visit & RICS Red Book valuation — 3 hours on site, detailed condition survey, recent Anfa Supérieur comparables. Market value at 7.1M MAD (38-page signed and timestamped report).
- March — Adouls coordination in Casablanca for the acte d'hérédité. Required: apostilled death certificate, family record book, CIN, certificates of life for heirs.
- April — French notary liaison in Paris. The French notary issued an acte de notoriété confirming the devolution per Moroccan law (lex rei sitae). French + Moroccan asset transfer recorded in Form 2705.
- April — Arbitration between heirs — mediation. The daughter wanted to keep, the sons wanted to sell. Solution: buy-out by the daughter of the 2 brothers' 2/3 share + maintained joint ownership 1/6 widow / 1/6 daughter. Licitation deed before Moroccan notary.
- May — Liquidation-partition deed signature in Morocco + registration duties paid at 1.5% on transferred fraction (~72,000 MAD).
- May — French succession declaration — Form 2705 filed within 14 months, ReaConsult report annexed to justify valuation. French tax: 0 for the €100k abatement + 20% marginal on balance (after Moroccan FTC).
Outcome — by the numbers
Key take-aways for any MRE
- Plan during your lifetime — a lifetime gift up to the tax-abatement ceiling (€100k parent-child in France) can save up to 30% of future duties.
- Consider a Moroccan family SCI — simplifies governance, enables usufruct/bare-ownership split, structures inter-generational transfer.
- Moroccan law always applies to property in Morocco (lex rei sitae) — a foreign will cannot override Moudawana on Moroccan assets.
- Valuation at date of death is critical — prevents disputes between heirs + anchors tax basis on both sides.
- Expect 4-8 months to cleanly resolve a cross-border MRE France-Morocco succession.
- Two notaries needed (Paris + Casablanca) — no single notary can handle both sides of a transnational estate.
Ongoing succession — or planning ahead?
RICS valuation + adouls coordination in Morocco + liaison with your French notary. Quote within 24h.