IHT

Introduction

We believe that our mother, Claudette (CRL), domiciled in France at the date of her death on 24 September 2024.

CRL was French domiciled by origin and, throughout her life, maintained strong legal, financial, and personal ties to France. At no point did she form a clear and settled intention to abandon France as her permanent home. She had two permanent homes in France, one in Paris and the other in Gan, South of France. Both properties were available for her occupancy day and night. She ensured they were insured, fitted with telephones, paid the rates, maintained them, employed gardeners, and paid for electricity.

CRL did not have a permanent home in the UK.

Domicile of Origin

CRL’s domicile of origin was unequivocally French.

Her ancestry, parentage, and adoption establish a clear and continuous connection to France:

Family Tree - Appendix 1
Her father, Camille Ferri-Pisani, was born and died in France - Appendices 2 • 3
Her birth mother, Claire Clavenad, was born and died in France - Appendices 4 • 5
Her adoptive mother, Victorine Ferri-Pisani, was also born and died in France - Appendices 6 • 7
Her adoption was formalised - Appendix 8.

Citizenship and Legal Status

CRL remained a French citizen throughout her life.
She retained and renewed her French passport, including renewal in 2023 - Appendix 9.
She had French birth certificates - Appendices 10 • 11.
Her French citizenship was formally examined and upheld in 1952 and 1985, confirming that she had not acquired British nationality through marriage - Appendices 12 • 13.

Property, Financial and Legal Ties

CRL maintained ties to France over many years:
Ownership and continued maintenance of the farmhouse in Gan
Payment of all property-related outgoings, including utilities, insurance, local taxes, and upkeep
Maintenance of French bank accounts
Execution of a French will in 2019 through a French solicitor - Appendix 14.
Lifetime gifting arrangements consistent with French legal and cultural practice

These actions demonstrate a sustained and practical connection to France.

Ongoing Connection to France

CRL’s life remained actively connected to France:

She was recorded on the electoral register in Gan and participated in the French census in 2007 - Appendices 15 • 16.
She spent extended periods in France following the 2008 HMRC non-domicile decision - Appendix 17.
She undertook professional and cultural activities in France, including theatre productions and lectures - Appendices 18 • 19 • 20 • 21.
She planned and carried out works to the farmhouse, including repairs, maintenance, and improvements - Appendices 23 • 24 • 25 • 26 • 27 • 28.
She regularly saw her GP in Gan and renewed prescriptions for medications.

Final Years Intention

CRL’s actions in her final years demonstrate a clear intention to return to France as her permanent home.

The farmhouse in Gan, her childhood home, remained her only enduring property and the centre of her long-term plans:

She obtained estimates and formulated a plan for refurbishment of the farmhouse Appendices 22 • 27.
She requested the planting of additional hedging to improve privacy and define the boundaries of the property
These actions are consistent with preparing the property for future occupation
She also expressed a clear wish to be buried in the village graveyard in Gan, where her family and ancestors are buried.
In a recorded statement, she confirmed her intention to return and live at the farmhouse.

Her absence from France in her final years was not due to any change in intention, but to external circumstances:

Enforced confinement during the COVID period
Subsequent physical incapacity following hip fractures

These factors prevented her return but did not alter her intention.

Conclusion

Claudette’s French domicile of origin was never displaced.

The evidence shows:

Continuous legal identification as French
Sustained financial and property ties to France
Ongoing personal and professional engagement with France
A clear and expressed intention to return

There is no evidence of a settled and permanent intention to abandon France.

While she maintained a presence in England, this did not displace her enduring connection to France, which remained the centre of her long-term intentions.

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Appendix Index

Appendix Description