A new succession law came into effect throughout the European Union last week. In terms of this rule, the law of the country where the deceased was a habitual resident will govern succession to their estate as a whole, including any assets held in different European jurisdictions.
For example a woman in the UK with a property in France would have been obliged to leave it to her husband and children under French forced heirship rules. Under the new rule, she could instead choose to apply UK law to the property, which would allow her to leave the house to her brother.
The intention of the rule is to simplify a frequently encountered and complex area of international law.
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