There are about 450,000 international successions each year in the EU, representing more than EUR 120 billion. As owners of properties –houses and bank accounts – families are confronted with different rules on jurisdiction and applicable law in the 27 EU Member States. For example, if a British citizen with a house in southern France dies, would French or UK succession law apply to his property?
To help citizens become better informed about these laws, the Council of the Notariats of the EU, with the support of the European Commission, launched a website in 22 EU languages plus Croatian.
The website provides answers to the main questions raised during a succession. For example, citizens could find out which authority would be competent and which law would apply, if it is possible to choose the applicable law and who the heirs are. For legal practitioners, there will also be detailed reports on succession law available in English, French and German.
The project’s total cost amounts to almost EUR 280,000 and the Commission contributed about EUR 158,400.
The website is available at www.successions-europe.eu
Background
On 14 October 2009, the Commission proposed a Regulation to simplify the settlement of international successions. Under the Regulation, there would be a single criterion for determining both the jurisdiction of the authorities and the law applicable to a cross-border succession: the deceased's habitual place of residence. People living abroad will, however, be able to opt to have the law of their country of nationality apply to the entirety of their succession.
EU Justice Ministers, during a meeting on 4 June 2010 in Luxembourg, underlined the importance of the proposed Regulation. Negotiations are ongoing in the Council.