Article 784 C of the French General Tax Code
In the case of gradual or residual gifts as referred to in articles 1048 to 1061 of the Civil Code, at the time of the transmission, the legatee or donee established first is liable for transfer duties on the assets transmitted under the conditions of ordinary law. The legatee or donee established second is not liable for any duty. On the death of the first legatee or donee, the assets…