cornemuser Posted March 22, 2020 Share Posted March 22, 2020 Hi, I have been looking at the issue of succession, but I am not getting very far..... I am trying to find out if, after Brexit, we can still choose the laws of our own country (UK) to apply to our will ? Does anyome have any information ?Thanks Link to comment Share on other sites More sharing options...
pomme Posted March 22, 2020 Share Posted March 22, 2020 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.https://www.vwv.co.uk/news-and-events/blog/private-client-law-brief/eu-succession-regulation-recent-developmentsandhttps://www.taylorvinters.com/article/will-the-eu-succession-regulation-brussels-iv-affect-your-estate-even-after-brexit Link to comment Share on other sites More sharing options...
cornemuser Posted March 22, 2020 Author Share Posted March 22, 2020 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 ! Link to comment Share on other sites More sharing options...
NormanH Posted March 22, 2020 Share Posted March 22, 2020 I am not sure if this has ever been tested in French law Link to comment Share on other sites More sharing options...
cornemuser Posted March 22, 2020 Author Share Posted March 22, 2020 Thanks Norman, interesting, but it reallybdoes not help. Link to comment Share on other sites More sharing options...
cornemuser Posted March 22, 2020 Author Share Posted March 22, 2020 I was referring to your BR quote Link to comment Share on other sites More sharing options...
pomme Posted March 22, 2020 Share Posted March 22, 2020 NormanH wrote: I am not sure if this has ever been tested in French lawWhat 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. Link to comment Share on other sites More sharing options...
idun Posted March 22, 2020 Share Posted March 22, 2020 Have to ask cornemuser, what sort do you play? Link to comment Share on other sites More sharing options...
cornemuser Posted March 22, 2020 Author Share Posted March 22, 2020 Irish Uilleann Pipes, Northumbrian Smallpipes, Border Pipes, Scottish Smallpipes - http://www.raysloan.com and http://www.borderbagpipes.com Link to comment Share on other sites More sharing options...
cornemuser Posted March 22, 2020 Author Share Posted March 22, 2020 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.http://www.raysloan.comhttp://www.borderbagpipes.com Link to comment Share on other sites More sharing options...
idun Posted March 22, 2020 Share Posted March 22, 2020 I am very fond of northumbrian and we have a set of uilleann pipes here, but it is not I, who is the musician. [:)] Link to comment Share on other sites More sharing options...
cornemuser Posted March 22, 2020 Author Share Posted March 22, 2020 Sorry idun, I have no idea if you have received my reply because a reply from you, nor my reply to you, simply does not appear ? Link to comment Share on other sites More sharing options...
Judith-aka-Judith Posted March 23, 2020 Share Posted March 23, 2020 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 a recorder ... so I use my voice instead ... Link to comment Share on other sites More sharing options...
cornemuser Posted March 23, 2020 Author Share Posted March 23, 2020 [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 ... [/quote] Link to comment Share on other sites More sharing options...
idun Posted March 23, 2020 Share Posted March 23, 2020 I wish you had not mentioned 'recorder' Judith, it is a subject best not mentioned in this house[:D] Link to comment Share on other sites More sharing options...
parsnips Posted March 23, 2020 Share Posted March 23, 2020 Hi,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. Link to comment Share on other sites More sharing options...
cornemuser Posted March 23, 2020 Author Share Posted March 23, 2020 Thank you parsnips ! ? Link to comment Share on other sites More sharing options...
idun Posted March 23, 2020 Share Posted March 23, 2020 And finding a really good notaire will be hard. There are so many that are terrible, that I don't think that you should hesitate to get in touch with quite a lot of them. Link to comment Share on other sites More sharing options...
ericd Posted March 25, 2020 Share Posted March 25, 2020 I just happen to know a Solicitor/Notaire in Newcastle Upon Tyne who is qualified in both systems and currently deals with Brits buying/selling in France. Try Anglo French Law http://www.anglofrenchlaw.co.uk/ Link to comment Share on other sites More sharing options...
ericd Posted March 25, 2020 Share Posted March 25, 2020 I just happen to know a good Solicitor/Notaire in Newcastle Upon Tyne who is qualified in both systems and currently deals with Brits buying/selling in France. Try Anglo French Law http://www.anglofrenchlaw.co.uk/ Link to comment Share on other sites More sharing options...
cornemuser Posted March 25, 2020 Author Share Posted March 25, 2020 Oh, thanks ericd, I am a Geordie ! Are they any good ? Link to comment Share on other sites More sharing options...
ericd Posted March 25, 2020 Share Posted March 25, 2020 Why yee ask like ? ..... I wouldn't recommend them if a) I didn't know them and b) didn't respect the work they do. Ask to speak to Marcel and tell him you are being sent by Eric. Link to comment Share on other sites More sharing options...
cornemuser Posted March 25, 2020 Author Share Posted March 25, 2020 Taa, canny champion like ! Link to comment Share on other sites More sharing options...
ericd Posted March 25, 2020 Share Posted March 25, 2020 It's alreet yee kna. Link to comment Share on other sites More sharing options...
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