NickP Posted March 29, 2012 Share Posted March 29, 2012 I was interested to notice that in a well known French/English publication there is a storey that the French inheritance laws affecting Expats are to be changed, due to an EU regulation that states that the inheritance laws of your native country will prevail should you so wish. Considering the mind boggling importance and how much it will affect Brits in France I'm surprised that no one has yet commented on this on this forum. By the way it does mean according to the information supplied that you must live for at least another three years, as it will take that amount of time for Europe to pass this regulation. Well what do you think? Personally I will try my hardest to live another three years and spend it anyway so nothing will change for me. So hopefully neither Cameron or Sarkozy will get their greasy mitts on my hard earned.[:P] Link to comment Share on other sites More sharing options...
Pickles Posted March 29, 2012 Share Posted March 29, 2012 Some info on this is here:http://www.toutsurlasuccession.com/succession-transfrontaliere-le-parlement-europeen-simplifie-les-regles.htmlIf/when it does happen, it will not affect the TAX rules: ie if it comes to pass then a UK expat would be able to leave whatever he/she wants to whomever he/she wants, but the French rules on the taxation of such amounts will remain the same. So (worst case scenario) if you want to leave money to someone not related to you, anything over the first 1594€ will still be taxed at 60%. All the proposal would do is simplify the legalities of administering and executing a will in multiple EU jurisdictions (which is admittably a big step in itself). Link to comment Share on other sites More sharing options...
nectarine Posted March 29, 2012 Share Posted March 29, 2012 I read about this but understood that most European countries would abide by this but the UK was going to opt out. So how would that affect a Brit in France ... because they are in France could they opt for UK inheritance laws? But then would a French person in the UK be bound by UK inheritance laws because the UK isn't part of this agreement?It looks promising for those of us with complicated family arrangements who want the spouse to inherit all, but there's probably a lot to work out first. Link to comment Share on other sites More sharing options...
AnOther Posted March 30, 2012 Share Posted March 30, 2012 I expect the reason the UK has opted out because the law there is that you can leave your estate to whomever you like already so it's irrelevant! Link to comment Share on other sites More sharing options...
parsnips Posted March 30, 2012 Share Posted March 30, 2012 Hi, As Pickles says this measure (if adopted) is really only for the benefit of lawyers. It specifically excludes national tax and forced heirship rules, so is of little practical interest to UK expats in France. Link to comment Share on other sites More sharing options...
Boiling a frog Posted March 30, 2012 Share Posted March 30, 2012 [quote user="AnOther"]I expect the reason the UK has opted out because the law there is that you can leave your estate to whomever you like already so it's irrelevant![/quote]Scotland has it's own Inheritance laws and you cannot disinherit ,a widow/widower/civil partner have prior rights and children have legal rights.I do not know the situation in N Ireland.So bang goes your reason. Link to comment Share on other sites More sharing options...
AnOther Posted March 30, 2012 Share Posted March 30, 2012 Maybe pre-empting Scotland's suicide, sorry independence referendum, around the time this comes in [:D] Link to comment Share on other sites More sharing options...
Pickles Posted March 30, 2012 Share Posted March 30, 2012 IIRC, I think that essentially it is extending to expats the system that is already available to non-resident owners of property in France. Link to comment Share on other sites More sharing options...
Boiling a frog Posted March 30, 2012 Share Posted March 30, 2012 It will not apply to England and Wales as they have opted out .Was your quip about suicide an attempt at being funny or are you just a natural boor Link to comment Share on other sites More sharing options...
NickP Posted March 30, 2012 Author Share Posted March 30, 2012 [quote user="Pickles"]IIRC, I think that essentially it is extending to expats the system that is already available to non-resident owners of property in France.[/quote] Forgive my ignorance but that system is? Thanks in anticipation Link to comment Share on other sites More sharing options...
Pickles Posted March 30, 2012 Share Posted March 30, 2012 [quote user="NickP"][quote user="Pickles"]IIRC, I think that essentially it is extending to expats the system that is already available to non-resident owners of property in France.[/quote] Forgive my ignorance but that system is? Thanks in anticipation[/quote]I was thinking of the Hague Convention of 5th Oct 1961, but on reflection I think that I have tripped myself up and am confusing myself with the Hague Convention of 14th March 1978 - which applies to matrimonial regimes. Link to comment Share on other sites More sharing options...
NickP Posted March 30, 2012 Author Share Posted March 30, 2012 [quote user="Pickles"][quote user="NickP"][quote user="Pickles"]IIRC, I think that essentially it is extending to expats the system that is already available to non-resident owners of property in France.[/quote] Forgive my ignorance but that system is? Thanks in anticipation[/quote]I was thinking of the Hague Convention of 5th Oct 1961, but on reflection I think that I have tripped myself up and am confusing myself with the Hague Convention of 14th March 1978 - which applies to matrimonial regimes.[/quote] And that states what? Link to comment Share on other sites More sharing options...
Pickles Posted March 30, 2012 Share Posted March 30, 2012 The Hague Convention of 14th March 1978 on the Law Applicable to Matrimonial Property Regimes basically gives married people the choice of which country's matrimonial law they wish to apply to their property: that of either the country of birth of either party, the country of residence or the country in which they are about to take up residence. IIRC only 3 countries have signed up to this, but France is one of them. Link to comment Share on other sites More sharing options...
AnOther Posted March 30, 2012 Share Posted March 30, 2012 [quote user="Boiling a frog"]Was your quip about suicide an attempt at being funny or are you just a natural boor[/quote]It's my opinion which I'm entitled to express just as you are free to disagree with it. Link to comment Share on other sites More sharing options...
Boiling a frog Posted March 30, 2012 Share Posted March 30, 2012 Very true but nothing forces me to respect those views. Link to comment Share on other sites More sharing options...
Rabbie Posted March 30, 2012 Share Posted March 30, 2012 [quote user="AnOther"]Maybe pre-empting Scotland's suicide, sorry independence referendum, around the time this comes in [:D][/quote]You seem to have pre-knowledge of the result of this referendum not indicated by the results of a a poll I have carried out among friends and acquaintances currently resident in Scotland. It would appear that many Scots are by no means intent on independence but are prepared to consider the arguments put forward during the campaign.Funnily enough some of the most fervent nationalists are those with the greatest doubts about an irreversible split with England Link to comment Share on other sites More sharing options...
AnOther Posted March 31, 2012 Share Posted March 31, 2012 [quote user="Boiling a frog"]Very true but nothing forces me to respect those views.[/quote]A reasonable person should be able to disagree with another's opinion without disrespecting it or throwing insults at it's holder [;-)]Rabbie: No pre-knowledge, it was a jocular comment aimed at the referendum itself and like you I know more people who are opposed to it than for but with all his obfuscating and fiddling Salmond could just pull it off and if he did then that would, IMO, be a day the Scottish would live to deeply regret [:(] Link to comment Share on other sites More sharing options...
NickP Posted April 1, 2012 Author Share Posted April 1, 2012 Sorry for the delay, but thank you for the reply Pickles. Link to comment Share on other sites More sharing options...
Rabbie Posted April 1, 2012 Share Posted April 1, 2012 [quote user="AnOther"]Rabbie: No pre-knowledge, it was a jocular comment aimed at the referendum itself and like you I know more people who are opposed to it than for but with all his obfuscating and fiddling Salmond could just pull it off and if he did then that would, IMO, be a day the Scottish would live to deeply regret [:(][/quote]I agree with you but that does not of itself make the referendum suicidal. I could have a fatal accident next time I go to the shops but that does not make me suicidal Link to comment Share on other sites More sharing options...
Russethouse Posted April 1, 2012 Share Posted April 1, 2012 There's a difference between an accident and Alex Salmond purposefully steering Scotland in this direction.My feeling is (rather meanly) that if they decide on independence that must be how they stay, no rescue by the rest of the union should it not work, furthermore, no more Scottish MP's deciding the rules for the rest of us in the House of Commons, which might make a difference to who holds power in Westminster Link to comment Share on other sites More sharing options...
woolybanana Posted April 1, 2012 Share Posted April 1, 2012 Can Scotland afford to bankroll the bankrupt Scottish banks. Will England repatriate companies based in Scotland, such as the Student Loan Company? Will Shetland reclaim its oil? Link to comment Share on other sites More sharing options...
Boiling a frog Posted April 1, 2012 Share Posted April 1, 2012 Perhaps the Scots should seek compo for the invasion and destruction of property in 1314 Link to comment Share on other sites More sharing options...
NickP Posted April 1, 2012 Author Share Posted April 1, 2012 That's no problem, tell us where to send the 5 shillings and we'll be out of your debt. Link to comment Share on other sites More sharing options...
Boiling a frog Posted April 1, 2012 Share Posted April 1, 2012 With interest Link to comment Share on other sites More sharing options...
Recommended Posts
Please sign in to comment
You will be able to leave a comment after signing in
Sign In Now