International inheritance

The questions around international inheritance are complex, considering the fact that rules with respect to successions vary depending on the countries and evolve through time. The assistance of a lawyer expert in international inheritance may present as very useful.

The cases of international inheritance

The international inheritance concerns :

• Individuals who died abroad
• Individuals who possess some assets abroad
• Individuals whose heirs/legatees are abroad

The cases of international inheritance are more and more frequent. Nowadays in Europe, one death out of ten contains an international element, that is to say it incorporates an international dimension.

Numerous questions are then raised :

• Is the law applicable to the succession the one of the country of nationality of the deceased ? The one of his place of residence ? The one of his tax residence ?
• Who are his heirs ? What are their rights and duties ?
• What is the validity of a will established abroad ?
• What are the formalities to accomplish and in which country ?
• Which taxation is applicable ?

The legal frame of successions with an international dimension

The legal frame which rules international inheritance evolves very frequently, in France as well as abroad.
In France, a new regulation entered into force in August 2015 in order to simplify international successions. From now on, the entire set of assets of the deceased person is ruled under the law of the State in which the person usually resided at the time of their death. It is nonetheless possible to derogate this principle of usual residence with a will and a person living abroad at the
time of their death may have chosen to have their inheritance ruled by their national law.

The advice of an international lawyer

The regulations of international inheritance vary greatly depending on the country concerned and are very complex. It is highly recommended to use the competences of an international lawyer.
Our firm has had to work on many cases of international inheritance and has acquired a solid experience in the field. We can advise you and assist you in your proceedings for a succession with an international dimension.