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A reminder that European Union inheritance regulations will change as of August 2015
International inheritances amount to some €100 billion per year, but the rules governing cross-border inheritance are complex.
Inheritance laws are different in each European Union (EU) country. This web page set up by the notaries of Europe, explains the current rules in each EU state.
Under French law, your heirs have a prescribed right to a certain proportion of your estate. And if you own real estate in France, French law currently specifies who can inherit and the rates of taxation that your heirs will pay.
This is set to change as of August 17th 2015. We reported on the changes and their implications here.
Briefly, as of August 17th a citizen of another country who owns property in a participating EU state can choose which country’s law will apply. This concerns certain aspects of their will, including who can inherit. They can choose either the law of the country where they are normally resident, or of their country of nationality, or of one of their nationalities if they have several.
The rules about taxation of inheritance will not change.
For these rules to apply, you must take action during your lifetime. This means stating in your will which law will apply to your property. You can do this now in preparation for the changes, but they will not come into effect until August 17th.
If you do not make an explicit choice, the law of the country where you are normally resident will apply. If you live in France, this will be French law.
Determining your inheritance objectives and taking advice from qualified experts in international inheritance law is essential.
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