International estates

Assets in several countries, heirs abroad, choice of law.

Since 17 August 2015, the EU Succession Regulation generally applies the law of the deceased's last habitual residence to the whole estate; anyone may choose the law of their nationality by will.

We advise on applicable law, the European Certificate of Succession and assets outside the EU.

Frequently asked questions

Which law governs the estate of a French national living abroad?

As a rule, the law of the State of their last habitual residence, under the European Succession Regulation, unless they chose French law, the law of their nationality, in a will.

Can I choose the law that will govern my estate?

Yes. The EU Succession Regulation, which applies to deaths since 17 August 2015, generally subjects the whole estate to the law of the State of the deceased's last habitual residence, but allows anyone to choose, in a will, the law of their nationality. Since 2021, where the applicable foreign law does not provide for a reserved share for children, the children may, under certain conditions, claim a compensatory levy on assets located in France.

Official source: EUR-Lex

What is the European Certificate of Succession?

Created by the EU Succession Regulation, this certificate allows heirs, legatees and executors to prove their status and rights in the other Member States bound by the Regulation without further formalities. In France, it is issued by a notary. It makes it easier, in particular, to access bank accounts and transfer assets located in several EU countries.

Official source: EUR-Lex

Is a will made abroad valid in France?

Usually, yes. The Hague Convention of 5 October 1961, in force in France, recognises the formal validity of a will that complies in particular with the law of the place where it was made, the law of the testator's nationality, domicile or habitual residence, or, for real estate, the law of the place where it is located. Its content, however, depends on the law applicable to the succession.

All our frequently asked questions