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Brussels IV - New EU Succession Rules

Posted: Mon 20 Jul 2015 18:02
by QB
Has anyone any experience of writing a UK will which will comply with the new EU Succession Rules, part of Brussels IV, which come into force on 17 August. This will will allow a UK national who is the owner of assets abroad to opt for UK rather than French, say, rules of succession?

I have a scan of an article from last Saturday's Daily Telegraph which I can forward on if you send me your e-mail address.

Posted: Mon 26 Oct 2015 16:48
by martyn94
Perhaps time to refresh this, now it's been in force for a couple of months. My experience of notaires is that they are pretty dozy about almost anything (which doesn't stop them being condescending). But I am not confident enough to make a home-made will in France. One thing I know (I think) is that your will needs to say very explicitly that it is relying on the specific provision of EU law to attract the succession law of your country of origin.

Posted: Mon 26 Oct 2015 21:59
by Kate

Posted: Tue 27 Oct 2015 11:15
by martyn94
Many thanks. But God how I hate these mealy-mouthed expressions like "succession planning". I bet they call tax fiddling "wealth protection". More to the point, I know how it is meant to work, but has anyone tried to use it? Does the average MaƮtre Quelquechose know how to do it?

dissolving the sci

Posted: Sun 17 Jan 2016 15:46
by shimself
we bought using an sci with a tontine arrangement between the two of us some years ago, purely to get round succession law (we have children, who are still children). We are now pacsed.
We are minded to try to wind up the sci and move to a straightforward will according to British succession law (in short - the children can wait their turn)

Has anyone trod this path?