?new law of succession?

[Patf]

Has anyone heard of this possible new European law ? Reported in the July Connexion:

A new law yet to come in enabling foreign nationals to choose their country of nationality as that under which their succession would fall.

This was in the context of an english couple being refused a loan en viager because the outstanding amount would be difficult to reclaim if the borrower opted for non-France inheritance regulations.

If correct, another big benefit for british immigrants (among others.)

[minnie]

I believe it is that, if introduced, you would be able to adopt the succession rules of your country of citizenship or residency. However, which ever rules you choose you would still have to pay the French inheritance tax at the appropriate rate (or those inheriting would)

[parsnips]

[quote user="minnie"]I believe it is that, if introduced, you would be able to adopt the succession rules of your country of citizenship or residency. However, which ever rules you choose you would still have to pay the French inheritance tax at the appropriate rate (or those inheriting would)[/quote]

Hi,

     The recent developement is an agreement on guidelines for future work by the relevant committee. The full documentation on this subject is available on Google. The basic proposal is that the law of the country of residence will apply, but individuals will be able to opt for the law of the country of their nationality. From previous discussion documents it seems that this measure will only affect legal forms and certification of heirs rights, and crucially will not over-rule the forced heirship and taxation rules for those who die french resident.  From what I have read it appears likely that the UK will refuse to participate in any new arrangements, due to its radically different "common law" succession law. The new rules will be mainly for the convenience of lawyers.

[Rabbie]

There is a difference between English and Scottish law on Succession. In Scotland the surving spouse is entitled to half the total estate and the children are entitled to one third shared equally between them. Whereas in England you can leave everything to whoever you like except, of course, you have to pay the Government any death duties that may occur.

[NickP]

[quote user="Rabbie"]

 Whereas in England you can leave everything to whoever you like except, of course, you have to pay the Government any death duties that may occur.[/quote]

Not if your dead you don't. [:D]

[Rabbie]

[quote user="NickP"]

[quote user="Rabbie"]

 Whereas in England you can leave everything to whoever you like except, of course, you have to pay the Government any death duties that may occur.[/quote]

Not if your dead you don't. [:D]

[/quote]True[:D] But your executors will have to pay it on your behalf ifyou are rich enough[:(]