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If I understand correctly from the articles below, there is no change as a result of Brexit.

If you are resident in France you can opt to have your succession according to English/Welsh or Scottish law (there is no UK law). However, the inheritance will still be taxed according to the French inheritance rules.




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Thanks Pomme ! Do you happen to know if a Will preferring English law has to be done officially with a Notaire or can we write one ourselves specifying our preference for English law ? I am not sure how we might find a Notaire who is familiar with this scenario ?

Thanks very much for your help !
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NormanH wrote: I am not sure if this has ever been tested in French law

What do you think hasn't been tested? The EU Succession Regulation itself or something more specific?

There is already some confirming ECJ case law as detailed in the links.
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Hi idun, I have replied but I do not see my reply...... and so I am replying 'again' so excuse me if this comes through twice.

Irish Uilleann Pipes, Scottish Smallpipes, Border Pipes, Northumbrian Smallpipes.


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[quote user="Judith-aka-Judith"]Cornemuser, all your postings are there, worry not. The forum sometimes takes time to  post them.   Lovely choice of instruments.  Me, I can't get a sound out of even au recorder ... so I use my voice instead ...


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I can't see an answer to this question anywhere  among the pipe posts. Here is what I have read in various sources;

  To opt for UK succession law you should see a notaire and have a french will drawn (best to ask for a draft "holograph will" -in english if you prefer - which you can then write in your own handwriting ,and register with the notaire).  You should start the will with the words "In accordance with EU succession regulation 650/2012 (BrusselsIV) I opt for English Law*for the whole of my worldwide assets."  

*or Scottish or whichever other country may be appropriate.

You then go on to list your wishes for the disposal of your assets after your death.

It is vital to remember that making an English Law Will does NOT AFFECT THE OPERATION OF FRENCH SUCCESSION TAX RATES AND ALLOWANCES . 

This means ,that if ,for example ,you cut out your blood relations , and leave all your assets to a friend or to your mistress, they will have a 60% tax bill on all they receive , if you die french resident.
  Your children , in this example, could bring an action in the french courts, but there is no guarantee that they would win.

  Before doing anything else , find a competent notaire and discuss with him/her.

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